General Data Protection Regulation (GDPR), which replaces the Data Protection Act (DPA) 2008 and comes into force on 25th May 2018, is a significant change to data protection law, encompassing all personal data held and processed either wholly or partly by automated means.
This Privacy Notice is a public document available to anyone and applies to residents and other service users of Hornsey Housing Trust, to explain how the Trust collects and processes personal information in order to conduct normal business activities as a UK charitable housing association. We are a Registered Social Landlord (RSL) regulated by the Homes and Communities Agency (HCA). Normal activities can be summarised as:
1. Providing social housing for people in need.
2. Carrying out property maintenance and repairs on properties we own and let.
3. Managing your housing, tenancy and rent account as your landlord.
We also provide additional optional services including:
4. Organising and assisting community and social events.
5. Offering opportunities to be involved.
6. Providing welfare, benefits and debt advice.
7. Making disability adaptations to the properties we manage.
8. The Dementia Service
Who we are
Hornsey Housing Trust is a social landlord whose head office is located at 62 Mayfield Road, London, N8 9LP. We own around 400 properties in Haringey and employ around 14 staff, mostly based at our head office.
How we collect your information
Hornsey Housing Trust collects information from you via a variety of sources, including when you apply for one of our properties or services, complete one of our forms, when you call, write, e-mail or meet with us or when you respond to a survey.
We operate a CCTV system at our Abyssinia Court, Margaret Hill House, Palm Tree Court, Olive Tree House, Sheba Court and Waverley Road premises for the detection and prevention of crime. It operates continuously and recordings are held for 14 days. All recordings are held on encrypted discs and accessible only to the Chief Executive, Housing Services Manager and Support Services Officer based at the location where the CCTV is hosted.
From time to time we may operate sound recording and / or use photography to capture evidence of breach of tenancy, alleged anti-social behaviour or crime. We may also take photographs and video footage at our events, at our properties and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent.
We may receive information about you from third parties including:
• Prior landlords and credit agencies when you apply for housing.
• Police, welfare or support organisations working with you.
• Councillors, MPs or other representatives acting on your behalf/instruction.
• Financial institutions and creditors when you request welfare or debt management advice.
What information we collect about you
The information we require from you, the tenant(s) includes:
• Full name (and proof of your identity / photo ID).
• Date of birth.
• National Insurance number (your unique identifier).
• Contact details (phone, e-mail and correspondence address).
• Details of anyone authorised to act on your behalf if applicable.
• Basic details (name and DOB) of all household residents.
• Banking details if you pay your rent by Direct Debit.
• Card details if you pay your rent by card (however card details are not stored).
• Proof of housing eligibility, any interest or equity in other property.
The information we may collect from you includes:
• Disabilities or vulnerabilities. We use this information to tailor our service to better meet your particular circumstances and needs. If you are a sheltered tenant, we use this information in the support planning you take part in. We may also use this information to ensure contractors working on our behalf are aware of any needs or requirements you may have when they visit or contact you, and for safeguarding of staff.
• Financial information. We may use this to help resolve arrears payments and optionally to provide welfare, benefits and debt advice as a free service to help you budget and pay your bills. We may use this to apply for funding on your behalf, with your permission or at your request.
• Health information when we require this to support funding for adaptations made to the property you are living in.
If you do not provide the information we need then we may not be able to provide all our services to you, and ultimately you may not be able to hold a tenancy with us.
What processing we do with information collected
The information we require from you is used to manage your tenancy agreement and other contract between you and Hornsey Housing Trust. Please read your tenancy agreement carefully for specific details as ‘performance of a contract’ is usually the legal basis for processing your information and carrying out our activities.
The processing activities we conduct can be summarised as:
• Managing your account charges and payments, including arrears.
• Managing the repairs, maintenance and adaptations of our properties.
• Ensuring tenancy conditions are complied with, such as dealing with anti-social behaviour or fraud.
• Complying with relevant legislation and regulation.
Hornsey Housing Trust from time to time carries out research and analysis to help improve our business processes and the services offered to our residents, as well as to evaluate our performance against other benchmarks. Data presented in this manner is always anonymised.
Hornsey Housing Trust conducts surveys regularly and periodically relating to our services in order to gauge satisfaction and make improvements based on feedback. Any reporting of the survey outcomes is always anonymised.
Hornsey Housing Trust operates a range of information and communications systems and technologies for efficient operation of the business. Personal information is stored and managed within those systems which are maintained to achieve a high level of Confidentiality, Integrity and Availability (CIA) including following best practice cyber security standards.
We hold information in IT systems which may be copied for testing, backup, archiving and disaster recovery purposes. All data is held within the UK.
Hornsey Housing Trust carries out a number of additional voluntary services including organising social and community events, publishing a tenant newsletter, providing money and debt advice, adapting the property you live in, and gathering information to improve our services.
For these voluntary services, where your personal information is needed, we will always notify you about the service being offered, explain the service and obtain your consent to proceed, usually by way of a sign up / consent form for that service.
For the additional voluntary services, much of the information contained in our Privacy Notice is still relevant, such as details about Hornsey Housing Trust as the Data Controller, contact information for the Data Protection Officer and the rights you have under the legislation, including the right to withdraw your consent and the right to complain.
Hornsey Housing Trust does not normally process children’s information as part of a tenancy, as all tenants are adults. However, we record children’s basic information if they are resident in one of our properties, including their name and date of birth. This is required for checking the property is not overcrowded, for health and safety (e.g. alerting emergency services to the presence of a child) and to assess other tenancy management issues where all householders and ages are required to be known. We may receive children’s information if we are involved in the housing aspects of a child welfare or protection case as part of a multi-agency working solution.
Much of the data we use relates to our properties and their maintenance and repair. We do not consider property information used in conjunction with the property address to be your personal information. For example, the age of the kitchen, results from an asbestos survey, planning to replace windows or a repair to a tap. We are usually happy to provide you with answers to questions you may have about the property you are living in and work done to it.
As soon as your name, contact details or other personal information is used in conjunction with property information, such as to complete a property repair visit, then this is treated as personal information.
How we will communicate with you
Hornsey Housing Trust needs to communicate with our tenants and this will usually be in writing or by telephone, but may sometimes be by email or text messaging. If you have a preferred means of communication please let us know so that we can use this method wherever possible.
Our tenants receive our newsletter ‘The Link’ with information about what is going on within the organisation. We are required by our regulator to keep our tenants informed and to offer opportunities for involvement, but you may opt-out of receiving the newsletter by contacting us on 020 8340 6374 or email@example.com
We will only discuss or communicate your tenancy details with those named on the agreement, those authorised (temporarily or permanently) by you, or with court-appointed Guardians or named people with Power of Attorney in the case of tenants lacking capacity.
Who we share data with and how long we keep information
Hornsey Housing Trust shares limited personal data with our contractors who are carrying out services on our behalf. Our contractors are required to comply with the law and our own Data Protection Policy to ensure data is managed appropriately and for specified purposes, including to run our out-of-hours telephone service or to complete emergency, responsive or planned property repairs.
Hornsey Housing Trust may need to share personal information with government departments and agencies, with our regulator and auditors, with utility companies or with other organisations and agencies where we are legally allowed to do so.
Information relating to a tenancy or lease agreement will be kept for as long as the agreement is active or where money is owed on the account, and for a period not exceeding three years afterwards. The basic history of who held a tenancy at which property and when will be held forever.
What we will not do
• We will not send you unsolicited marketing material.
• We will not sell your personal data on to third parties.
• We will not pass on your personal data to unrelated third parties unless we are allowed or required to do so by law or we have your explicit permission to do that.
• We will not transfer or store your personal data outside of Europe (the European Economic Area) outside of the control of the UK / European regulations.
Your rights, the right to complain and the ICO
You have the right to request a copy of the data we hold about you. Please contact the Corporate Services Manager at firstname.lastname@example.org if you wish to request access to any of your personal data and we will always endeavour to answer your questions as part of our friendly, helpful service.
After 25th May 2018 we will not normally make a charge for a request to see copies of data we hold, and will respond within one month of receiving your request.
It will always help if you can be as specific about what personal data you want to see, what it relates to and within what timeframe, as that will assist our search.
You have the right to correct information that we hold. Please advise us of any changes or corrections by contacting us on 020 8340 6374 or email@example.com.
You may withdraw your consent to use any information that was previously provided with your consent. Please advise us if you wish to withdraw any consent previously given.
You also have other rights which can be seen by visiting the Information Commissioner’s Office (ICO) website and reading about Data Protection law at https://ico.org.uk/.
You have the right to complain about any matter relating to our service, including how we use your personal data. In the first instance please contact us on 020 8340 6374 or firstname.lastname@example.org.
If you are still not happy with our service you may complain to the Housing Ombudsman Service at http://www.housing-ombudsman.org.uk/.
If you wish to complain about our use of your personal data you may complain to the UK Information Commissioner’s Office (ICO) at https://ico.org.uk/