Our Privacy Notice describes the categories of personal data we process and for what purposes. We are committed to collecting and using such data fairly and in accordance with the requirements of the General Data Protection Regulation (GDPR).
1.1 We take your privacy seriously and you can find out more here about your privacy rights and how we collect, use, share and secure your personal identifiable information. This includes the personal identifiable information we already hold about you now and the further personal identifiable information we might collect about you, either from you or from a third party. How we use your personal identifiable information will depend on the products and services we provide to you.
1.2 This Privacy Notice is a public document available when Aldwyck Housing Group obtain and use your personal identifiable information. It explains how we and appointed third party organisations/people use your personal identifiable information and it details your rights. We obtain your personal identifiable information in order to conduct our normal business operations as a registered social housing provider.
1.3 Our Mandatory Data Protection Officer (MDPO) provides help and guidance to make sure we apply the law to the processing and protection of your personal identifiable information. Our MDPO can be reached by email or by post at Aldwyck Housing Group, 6 Houghton Hall Business Park, Porz Avenue, Houghton Regis, Bedfordshire, LU5 5UZ if you have any questions about how we use your personal identifiable information.
1.4 See section 3 Your privacy rights for more information about your rights and how our MDPO can help you.
1.5 This Privacy Notice provides up to date information about how we use your personal identifiable information and now updates any previous information we have published/supplied about using your personal identifiable information. If we make any significant changes affecting how we use your personal identifiable information, we will make changes to this Privacy Notice, and we will contact you to inform you of these changes.
2. Who we are
2.1 Where we refer to ‘we’ or ‘us’ in this Privacy Notice, we are referring to Aldwyck Housing Group.
2.2 Aldwyck Housing Group are a 'Group' of companies. In this Privacy Notice, when we refer to ‘Group’, we mean other members of our ‘Group’ of companies, including holding and subsidiary companies. Our group of companies and their ICO References are:
|Aldwyck Housing Group Limited||Z5308774|
|Connect Property Services Limited||ZA009858|
|King Street Lettings Limited||ZA240872|
As Aldwyck Housing Group Limited is a registered social housing provider, it is regulated by the ‘Regulator of Social Housing’. Each of the listed companies are committed to protecting your privacy and are joint data controllers within the meaning of data protection laws applicable in the European Union (EU) and European Economic Area (EEA).
2.3 As our Group companies are joint data controllers, we have arrangements between us to ensure that we handle your personal data correctly and in accordance with data protection law.
3. Your privacy rights
3.1 From 25 May 2018 you will have eight rights relating to the use and storage of your personal identifiable information. These are:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling
Please see further information about your Individual rights or contact our MDPO.
3.2 In brief, you have the right to be informed who is obtaining and using your personal identifiable information, how this information will be retained, shared and secured and what lawful grounds will be used to obtain and use your personal identifiable information. You have the right to object to how we use your personal identifiable information in certain circumstances. You also have the right to obtain a copy of the personal identifiable information we hold about you.
3.3 In addition, you can ask Aldwyck Housing Group to correct inaccuracies, delete or restrict personal identifiable information or to ask for some of your personal identifiable information to be provided to someone else. You can make a complaint if you feel Aldwyck Housing Group is using your personal identifiable information unlawfully and/or holding inaccurate, inadequate or irrelevant personal identifiable information which if used may have a detrimental impact on you and/or has an impact on your rights.
3.4 You can also make a complaint to the data protection supervisory authority. In the UK, this is the Information Commissioner's Office, please visit the ICO website.
3.5 To make enquires for further information about exercising any of your rights in this Privacy Notice, please contact Stephen Rosser, Head of Legal & Governance by email, or by post at Aldwyck Housing Group, 6 Houghton Hall Business Park, Porz Avenue, Houghton Regis, Bedfordshire, LU5 5UZ.
4. What kinds of personal identifiable information we use
4.1 We use a variety of personal identifiable information depending on the services we deliver to you. For all services, we need to use the following information about you and any occupant of your home:
4.2 Personal information
- Contact details - name, address, email, home and mobile telephone numbers
- Age – date of birth
- Identification - information to allow us to check your identity
- Credit information – information about your credit history
- Photograph – information to record your identity
- Online computer identification (IP address) – information recorded when you engage with us by email
- National Insurance numbers – information to carry out functions such as universal credit and/or supporting people contracts
- Next of kin.
There are other types of personal information which we do not collect for the occupants of your property unless they have a direct relationship with us (e.g. applied for housing in their own right or obtain services from us directly):
- Telephone contact details
4.3 Special information
- Health - to support our housing functions and vulnerable customers
- Race – optional, and solely to support our equality monitoring purposes
- Ethnic origin – optional, and solely to support our equality monitoring purposes
- Religion – optional, and solely to support our equality monitoring purposes
- Sexual life or sexual orientation – optional, and solely to support our equality monitoring purposes
- Convictions – to prevent and detect crime, fraud, anti-money laundering and to aid in the prosecution and rehabilitation of offenders.
There are other types of special information which we do not collect but are deemed important under the law:
- Trade union membership
- Biometrics (where used for ID purposes).
4.4 Sometimes where we ask for your personal identifiable information to enter into a contract or agreement with you (for example: tenancy agreement, lease, housing application, support and/or care plan agreement) or to meet our legal or regulatory duties (for example: to process housing applications, council tax benefit, equality monitoring and/or government or housing regulator reports), we will not be able to provide some of our housing, support or products or services without this information.
5. How we gather your personal identifiable information
5.1 We obtain personal identifiable information by various means. This can be by face-to-face, email, telephone, correspondence and / or by receiving this information from others, for example, a local elected member who is representing you, police, health or social care agencies or benefit agencies. We can also receive information about you from other people you know you and / or are linked to you, for example a relative, person nominated to act on your behalf or your legal representative.
5.2 Some further examples of how we may gather your personal identifiable information are:
- Directly from you, for example: when you fill out an application, transfer or mutual exchange form or as part of your right to buy application
- By observing how you use our housing, support, products and services, or those of other members of Aldwyck Housing Group, for example from the transactions and operation of your accounts and on-line services
- From other organisations such as former housing and support providers, health and social care agencies, law enforcement agencies, debt collectors, energy or utility companies, benefit agencies and / or credit reference and fraud prevention agencies
- From other people who know you including joint account holders and people you are linked to or live in the same community as you when reporting antisocial behaviour
- From monitoring or recording calls as part of quality and complaints monitoring. We record these calls for training and to ensure the safety of our staff. We will not record any payment card details as part of our accounts and payments operations
- From our CCTV systems for the prevention and detection of crime or to detect damage / vandalism to our properties and to ensure the safety and security of our staff and individuals obtaining services from us.
6. How we lawfully use your personal information
6.1 To provide you with our housing services we have a legal duty to confirm a person(s) has the right to reside in the country. We will need to obtain your name, contact details, date of birth, your current and previous countries of residence/citizenship, and a copy of identification documents (such as passport, home office residence papers and driving licence).
6.2 We might also need health and social care information (such as physical, social or mental health information or medication) to help support our customers who have a vulnerability and / or receive a support or care service from us.
6.3 We sometimes need to gather, use and share your personal identifiable information for particular reasons, which are set out in more detail below:
To operate and administer our housing, support and care products and services, including managing and responding to complaints:
|a)||Contact and occupation information with third parties who help us deliver our repairs, support, care and housing services. For example, our repairs contractors and their appointed sub-contractors|
|b)||Letting, renting and leasing properties|
|c)||Carrying out research|
|d)||Administering housing and property grants|
|e)||Providing associated welfare services, advice and support|
|f)||Maintaining our accounts and records.|
The categories of third party contractors and sub contracts we use are:
- Suppliers and service providers
- Financial organisations
- Central government
- Survey and research organisations
- Other housing associations or trusts
- Health authorities
- Health and social welfare organisations
- Professional advisors and consultants
- Probation services
- Charities and voluntary organisations
- Police forces
- Courts and tribunals
- Credit reference agencies
- Press and the media.
To administer payments to and from your accounts or other agencies (e.g. benefits agency):
|a)||Contact and occupation information with benefit agencies and financial advisors who as agencies or financial organisations help us to process payments to your account(s)|
|b)||To supply our appointed financial advisors with information to carry out home ownership affordability tests to advise on the suitability of a mortgage|
|c)||To prevent financial crime including money laundering, benefit fraud or illegal subletting.|
We use your personal identifiable information in this way because it is necessary to meet the conditions set out in the contract/agreement with you and/or to meet our legal and regulatory obligations.
To carry out our duties under health and safety and to support our vulnerable people:
|a)||Vulnerability indicators with contractors and sub-contractors to ensure services are tailored to meet your needs|
|b)||Concerned / Warning / Be Aware indicators with contractors and sub-contractors to ensure health and safety measures are in place. We would have informed you of this indicator and when it will be applied and for how long, for example: A warning marker will be applied when an incident has occurred which results in a threat being made by you to a member of staff or contractor team.|
We use your personal and special identifiable information in this way because it is necessary to meet the conditions set out to meet our legal and regulatory obligations in relation to health and safety.
To report or share information with agencies where it is believed you or another person’s vital interests are at risk:
|a)||Where you or another person is at risk of physical, mental or sexual harm or damage|
|b)||Where you or another person is in need of being protected as a vulnerable person from significant harm or serious exploitation.|
We use your personal and special identifiable information in this way because it is necessary to meet our legal and regulatory obligations and to protect yours and others’ vital interests.
To carry out our lettings and home ownership affordability assessments and former debt decisions about you:
|a)||Information you give to us about your former addresses will be used to carry out a a) credit history check with approved suppliers (e.g. Experian). No credit ‘footprint’ will be left as part of this process|
|b)||Information about those you are linked with in the proposed agreement or contract with us, for example, a joint tenant or owner|
|c)||Information about how you or the person linked to you has former debts owing to us or other landlords.|
For these purposes, we share and receive information with and from banks, building societies, credit reference and fraud prevention agencies. The credit or fraud prevention agency might add details of our search to the records they hold about you, whether or not your engagement with us proceeds. The use of your information is based on our legal obligations.
We engage the following credit reference and fraud prevention agencies:
- Rent Shield
- Hertfordshire Shared Anti-Fraud Service
To carry out market research and analysis to develop and improve our housing, support, care and products and services.
7. Automated decision making
7.1 Sometimes we use your personal identifiable information in automated processes to make decisions about you, such as credit scoring. We might also use automated processes to create a profile of you. We do this to help ensure decisions are made accurately, fairly and efficiently and to offer you services tailored to you.
7.2 Please contact our MDPO to learn more about when we use automated processes and the logic, significance and consequences of these processes.
7.3 We have informed you that we are part of the Experian ‘Rent Exchange Scheme’ and we share information as follows:
|a)||Information about you to Experian as part of the ‘Rent Exchange Scheme’.|
8. Our legal basis for using your personal identifiable information
8.1 We only use your personal identifiable information where that is permitted by the laws that protect your privacy rights. This will be where:
- We need to use the information to comply with our legal obligations
- We need to use the information to perform a contract with you
- It is fair to use the personal identifiable information either in our interests or someone else's interests, where there is no disadvantage to you – this can include where it is in our interests to contact you about products or services, market to you, or collaborate with others to improve our services
- Where we need to seek your consent (if consent is needed).
8.2 Where we have your consent, you have the right to withdraw it. We will let you know how to do that at the time we gather your consent. See section 12 Keeping You Up to Date, clause 12.2 for details about how to withdraw your consent to marketing.
8.3 Special protection is given to certain kinds of personal information that is particularly sensitive. This is information about your health status, racial or ethnic origin, political views, religious or similar beliefs, sex life or sexual orientation, genetic or biometric identifiers, trade union membership or criminal convictions or allegations. We will only use this kind of personal information where:
- We have a legal obligation to do so (for example to protect vulnerable people);
- It is necessary for us to do so to protect your vital interests (for example if you have a severe and immediate medical need whilst on our premises);
- It is in the substantial public interest;
- It is necessary for the prevention or detection of crime;
- It is necessary for insurance purposes; or
- You have specifically given us ‘affirmative’ consent to use the information.
9. Sharing your personal identifiable information with or getting your personal identifiable information from others
9.1 We will share personal identifiable information within Aldwyck Housing Group and with others outside Aldwyck Housing Group where we need to do that to make products and services available to you, market products and services to you, meet or enforce a legal obligation or where it is fair and reasonable for us to do so. See section 6, How we use your personal identifiable information for more information.
9.2 Who we share your personal identifiable information with depends on the products and services we provide to you and the purposes for which we use your personal identifiable information. For most products and services, we will share your personal identifiable information with our own service providers such as our IT Suppliers, with credit reference agencies and fraud prevention agencies. See section 6, How we use your personal information for more information on who we share your personal identifiable information with and why.
9.3 Most of the time the personal identifiable information we have about you is information you have given to us, or gathered by us in the course of providing products and services to you. We also sometimes gather personal information from and send personal information to third parties where necessary for credit checking and fraud prevention or marketing purposes, for example so you can receive the best offers from us and our partners. See section 6, How we use your personal information for more information on who we get your personal information from and why.
10. Transfers outside the UK
10.1 We may need to transfer your information outside the UK to and to companies, service providers, agents, subcontractors and regulatory authorities in countries where data protection laws may not provide the same level of protection as those in the European Economic Area, such as the USA.
11. How long we keep your personal information for
11.1 How long we keep your personal information for depends on the services we deliver to you. We will never retain your personal identifiable information for any longer than is necessary for the purposes for which we need to use it.
11.2 To see how long we keep your data for, view our Data Retention Document [pdf] or contact our MDPO.
12. Keeping you up-to-date
12.1 We will communicate with you about products and services we are delivering using any contact details you have given us - for example by post, email, text message, social media, and notifications on our app or website.
12.2 Where you have given us consent to receive marketing, you can withdraw consent, and update your marketing preferences by contacting us directly. For contact details, visit our websites:
or contact our MDPO.
13. Your online activities
13.2 Find out more about cookies and how to manage them on your browser go to the cookies section on the Direct.gov website.