Privacy Policy Keeping your data safe

Introduction

At Lincolnshire Housing Partnership (LHP), we value the trust of our customers. We understand that you are aware of and care about your personal data and privacy, and we take this seriously and always process your personal information in a fair and transparent way. This Privacy Policy describes LHP policies and practices regarding its collection and use of your personal data, and sets forth your privacy rights under the Data Protection Act / General Data Protection Regulation.

This Privacy Policy tells you what to expect when LHP processes your personal information. It applies to information about housing applicants, residents and other service users.  This is the main privacy notice for LHP.  However, some of our services or tenancy agreements depending on the customer region may have additional privacy notices which will have been provided to you when you  registered for such a service or by notification. It is important for you to read this policy in full to understand what information we hold about you, how we may use it and your rights in relation to your data.

We recognize that the management of personal data and information privacy is an ongoing responsibility, and we will be regularly reviewing and we will from time to time update this Privacy Policy, as we undertake new personal data practices or adopt new privacy policies. The latest updated version will be placed on our website (s) www.lincolnshirehp.com

If you ever require further information you can contact the organisations Data Protection Officer as follows;

 

Data Protection Officer

LHP has appointed a Data Protection Officer for you to contact if you have any concerns or questions about the LHP personal data policies and practices in relation to your data.

The Data Protection Officer

Westgate Park

Charlton Street

Grimsby

North East Lincolnshire

DN31 1SQ

 

What is Personal Data?

AT A GLANCE

The principals for what is personal data are based on current legislation which identifies that Personal Data is any information that relates to you whether directly or indirectly.

 

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What is Personal Data?

 Under the EU’s General Data Protection Regulation:

Personal Data is defined as “any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Special Categories of Personal Data

Certain data are classified under the Regulation as “special categories”:

  • Racial
  • Ethnic origin
  • Political Opinions
  • Religious Beliefs
  • Trade-union membership
  • Genetic Data
  • Biometric Data
  • Health Data
  • Data concerning a natural person's sex life
  • Sexual orientation
  • Other

 

Information Lincolnshire Housing Partnership may need to collect and store from you

 

AT A GLANCE

LHP needs to process personal data in order to deliver our services to you:

  • To provide, manage and develop affordable housing for all.
  • To provide property management & property maintenance services.
  • In the provision and management of care and support services.
  • To deliver on our ambition to ‘transform lives and communities’.  
  • We are committed to treating your information securely, with respect and in line with data protection law.

 

Information you give us > you may give us information about you in housing applications, tenancy agreements or by corresponding with us by phone, email or otherwise. We will only collect personal information when we need this.  The type of information we need from you will vary depending on our relationship with you.  When we ask you for information, we will make it clear why we need it.  We will also make it clear when you do not have to provide us with information and any consequences of not providing this. 

Most information we hold will be collected from you but we may also obtain this from third parties such as the local authority, your doctor (or other health professional), a previous landlord or other relevant community partner.  In addition, we may also obtain information from publicly accessible sources to enhance the information that we hold.

 

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We collect the following information from you (as applicable):

  •  We will need your name and contact details (including telephone numbers, email addresses and details of anyone you may choose to represent you) for use across the organisation and by our contractors, suppliers and partners.
  • We will/may also collect detailed personal information about you and other household members*, including age, sex, date of birth, ethnicity, income, National Insurance number, income and benefits details, employment status, gender identity, relationship status, any disabilities, any communication and accessibility requirements, religion, sexuality, nationality, caring responsibilities, access to financial services such as banks, bank details, benefits, council tax, housing benefits, universal credit details, medical information, details of any unspent criminal convictions.
  • We may also capture recordings of telephone conversations, you have with the organisation.
  • We may also capture your image on our CCTV systems if you visit an estate, office or community facility which is covered by this facility.

* When you provide information about household members we assume that you do so with their full knowledge and consent.

Provision of some of the information requested by us is part of a ‘contractual requirement’.  Without this information, we will be unable to accept an application for services. For example, we cannot see if you are eligible for a tenancy or check that an application is not fraudulent without being able to verify your identity. Please speak to us with any concerns.

Where enquiries relate to household members, it is in our legitimate interests to know who will be living in our premises to, check that accommodation offered is adequate for current and near future needs of the household, to check that household members’ needs are being met

 

How Lincolnshire Housing Partnership uses your information

 LHP will process – that means collect, store and use – the information you provide in a manner that is compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date and will not keep it for longer than is necessary. In some instances, the law sets the length of time information has to be kept, but in most cases LHP will use its discretion to ensure that we do not keep records outside of our normal business requirements.

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Using your personal data

We will use the information you provide for the following purposes:

  • To assess housing applications, service eligibility and complete tenancy sign-ups
  • To manage your tenancy or lease
  • To meet your needs in delivering our services
  • To prevent fraud and illegal sub-letting and to confirm eligibility for housing
  • To assist with personal security and prevention and detection of crime
  • To manage the legal process if you apply to buy your home or want to access another home ownership route
  • When you engage with our additional guidance, advice and support services 
  • Meeting our legal obligations including the requirements of our regulators.
  • To improve and personalize your experience when you use our any portals owned or delivered by LHP;
  • To improve our products and services and for the development of future products and services;
  • Direct marketing activities, subject to an expression of interest of a particular service or general consent
  • For internal record keeping and administration of records;

How Lincolnshire Housing Partnership may share your data

Sometimes we need to share personal information we hold about you with other organisations that we work with or who provide services on our behalf.  When sharing information we will comply with all aspects of data protection law.

Where the information is of a sensitive nature, for example about your health, we will generally obtain consent from you prior to sharing this information, unless we are required or permitted to share this by law.

Where ‘sharing’ is in our ‘legitimate business interests’, we may share your information without seeking your consent first.  This may be with:

  • Our contractors to facilitate repairs, maintenance or improvement works.
  • Local authority teams such as housing, social services, environmental health and benefit agencies.
  • Utility companies (and their representatives) and Council Tax Departments to ensure billing details are correct.
  • Independent mortgage advisors and solicitors.
  • Third parties providing services on our behalf. For example a mailing company distributing our newsletter; a research company carrying out a customer satisfaction survey, or a debt collection agency pursuing former tenant arrears.
  • Credit Reference Agency Experian as part of the Rental Exchange
  • Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative. More information can be found on the work undertaken by the Cabinet Office at: https://www.gov.uk/government/collections/national-fraud-initiative
  • Police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime, the apprehension of offenders or the collection of tax or duty.
  • Other statutory organisations e.g. social services, health authorities, occupational health organisations, Homes England, Housing Ombudsman, the National Housing Federation, as necessary for exercising statutory functions.
  • We may also share information when required by law for example where ordered by the Court or to protect an individual from immediate harm.
  • There may be occasions where we need to process your information outside of the European Economic Area (EEA), for example where we use a third party computer system supported by employees in the USA. Where we do this we will take all necessary steps to ensure that your information remains secure.  You can ask us for more information about how our International Processing arrangements affect you by using the contact details above.

Your Rights

AT A GLANCE

The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects. A good explanation of them (in English) is available on the website of the Information Commissioner’s Office.

LHP under the General Data Protection Regulation provides the following rights for individuals in regard to their personal data:

1.The right to be informed

2.The right of access

3.The right to rectification

4.The right to erasure

5.The right to restrict processing

6.The right to data portability

7.The right to object

8.Rights in relation to automated decision making and profiling.

These collectively give you the rights to withdraw consent at any time where relevant.

 

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The right to be informed

AT A GLANCE

When LHP obtains your personal data, we have a duty to inform you how your data will be used which encompasses fair processing information. The Right to be informed laid out in this Privacy Policy.

 

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The information we supply you is determined on whether we obtained the personal information from you directly or from another party. The Privacy Policy is set out to give you all the information you need to feel that you are well informed and that it is clear, concise, transparent, intelligible and easily accessible.

 

The right of access

AT A GLANCE

You have a right to understand what personal data is being processed and have access to this personal information.

 

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LHP will provide a copy of this information with 30 days of the request on validation of your identity and your rights to have this information.

If we do not respond to your request, we will explain why to you, informing you of your right to complain to the supervisory authority and to a judicial remedy without undue delay and at the latest within one month.

Please contact the Data Protection Office for more information.

 

The right to rectification

 

AT A GLANCE

You have a right to have your personal data corrected if you believe there is inaccuracies or incompleteness.

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LHP will respond to rectification requests within 30 days of the request on validation of your identity and your rights to have this information rectified.

Where we are not taking action in response to a request for rectification, we will explain why and inform you of your right to complain to the supervisory authority and to a judicial remedy.

Please contact the Data Protection Office for more information.

The right to erasure

 

AT A GLANCE

You have a right to have your personal data erased, this is also known as the right to be forgotten. This broad principle gives you the right to have your personal data removed if there is no compelling justification or legislative / regulatory reason to either retain your personal data or continue processing.

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LHP will respond to erasure requests within 30 days of the request on validation of your identity and your rights to have this information erased.

The right to erasure does not provide an absolute ‘right to be forgotten’. You have a right to have personal data erased and to prevent processing in specific circumstances:

  • Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
  • When the individual withdraws consent
  • When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
  • The personal data was unlawfully processed (ie otherwise in breach of the GDPR).
  • The personal data has to be erased in order to comply with a legal obligation

Where we are not taking action in response to a request for erasure, we will explain why and inform you of your right to complain to the supervisory authority and to a judicial remedy. 

Please contact the Data Protection Officer for more information

The right to restrict processing

 

AT A GLANCE

You have a right to block or supress processing of your personal data.

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The right to block or supress processing of your personal data is allowed under certain circumstance

  • If you contest the accuracy of your personal data
  • If you object to the processing and are contesting the legitimate grounds LHP are using to process your personal data.
  • If processing is unlawful and you request restriction rather than erasure
  • If personal data is no longer used, but is needed to establish, exercise or defend a legal claim.

LHP will respond to restriction of processing requests within 30 days of the request on validation of your identity and your rights to have this information rectified.

Where we are not taking action in response to a request to restrict processing, we will explain why and inform you of your right to complain to the supervisory authority and to a judicial remedy.

Please contact the Data Protection Officer for more information.

The right to data portability

 

AT A GLANCE

You have a right to data portability allowing you in certain circumstances to have your personal data ported across to another IT environment in a safe and secure way without hindrance to usability.

Please contact the Data Protection Officer for more information.

The right to object

AT A GLANCE

You have a right to object to the processing of your personal data under certain circumstances.

 

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LHP will respond to objection request within 72 hours on validation of your identity and your rights to object to your personal data being used.

We will stop processing of any your personal data for direct marketing immediately

Please contact the Data Protection Officer for more information.

 

Transfers to third countries

LHP as part of offering certain features may use third party service providers within the European Economic Area (the “EEA”). As a consequence, whenever LHP Warehouse is using or otherwise processing your Personal Data for the purposes set out in this Privacy Statement, LHP may be party to the transfer of your Personal Data to countries outside of the EEA.

LHP ensures that any such transfer to such countries are listed by the EU, as being recognised as providing adequate level of protection for personal data or has the provision of adequacies such as in the US (limited by the Privacy Shield Framework) .

If a statutory level of data protection applies that is not comparable to the level of data protection within the EEA. If such transfer occurs, it is based on the Standard Contractual Clauses (according to EU Commission Decision 2010/87/EC or any future replacement) in order to contractually provide that your Personal Data is subject to a level of data protection that applies within the EEA. You may obtain a redacted copy (from which commercial information and information that is not relevant has been removed) of such Standard Contractual Clauses

 

The right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint at any time with the Information Commissioner’s Office (ICO) if you feel that LHP has at any time neglected to satisfactorily look after your personal data or has failed to comply with your rights under the General Data Protection Regulation. 

The Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

 

Helpline: 0303 123 1113

Website: https://ico.org.uk/concerns/

We would advise if you are having any problems that you contact the company Data Protection Officer

The Data Protection Officer

Westgate Park

Charlton Street

Grimsby

North East Lincolnshire

DN31 1SQ

 

 

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