Sussex Housing & Care Privacy Notice
Sussex Housing & Care needs to process personal data in order to deliver our services to you:
- To provide, manage and develop sheltered housing & care services
- To provide property management & property maintenance services
- To deliver our ambition of ‘helping people live their later lives to the full’
We are committed to treating your information securely, with respect, and in line with data protection law.
This privacy notice tells you what to expect when we processes your personal information. It applies to applicants, residents, staff and other services users.
This is the main privacy notice for Sussex Housing & Care.
It is important to read this notice in full to understand what information we hold about you, how we use it, and your rights in relation to your data.
For further information, you can contact the Data Protection Officer as follows:
The Data Protection Officer
Sussex Housing & Care
Ronald Simson House
24 Sutton Avenue
Further independent information can also be found on the Information Commissioners website – www.ico.org.uk
We are registered with the Information Commissioners Office under register number Z4867804.
What information do we collect about you & how is it used?
We only collect personal information when needed. The type of information collected will vary depending on our relationship with you.
When we ask for your information, we will tell you why we need it and if you do not have to provide it, along with any consequences of not providing it.
Most of the information we hold will be collected from you, but we may also obtain some information from third parties such as local authorities, health professionals, or previous landlords.
We collect information from you:
To prioritise and assess housing applications, service eligibility and complete tenancy sign-ups.
We will need your name, and contact details (address, telephone numbers, and email, and details of anyone you may choose to represent you e.g. power of attorney or next of kin) for use across the organisation and by our contractors.
We will collect detailed personal information about those living with us including age, date of birth, ethnicity, income & benefits, national insurance number, employment status, gender identity, disabilities, communication/accessibility requirements, religion, sexuality, nationality, bank details, medical information.
When you provide information about family members or other third parties, we assume that you do so with their full knowledge and consent.
Collection of some of this information is part of a ‘Contractual Requirement’ – without this information we will be unable to accept your application for services. For example we cannot see if you are eligible for a tenancy without being able to verify your identity.
Where enquiries relate to other household members, it is in our legitimate interests to know who will be living in our premises to check they qualify for housing with us.
To manage your tenancy or lease.
We need up to date contact information so we can reach you when we need to discuss issues relating to your tenancy or lease, for example income collection, essential servicing, maintenance and repairs in your home.
We will also use your contact information to resolve or investigate complaints or housing management issues such as anti-social behaviour.
We will hold records of all our contact with you, your contact with us, and any contact from third parties representing you or about you.
Financial records about the amount of money you have paid us, any amounts outstanding and associated recovery action.
Depending on your payment method, we may hold your bank account details.
Provision of this information is a ‘Contractual Requirement’ – without it, we may be unable to manage your services.
To Provide an Online Tenant Portal (MyAccount)
We will use your basic information such as name, contact details, tenant key, and date of birth to provide an online tenant portal (MyAccount).
To meet your needs in our service delivery
We will keep information to ensure our services are accessible, that we take account of any support needs in our dealings with you and to improve our communications with you. For example if there are considerations we need to apply when we or our contractors visit your home, or if you need large print or translated text.
When processing information about you or your household members, we may have a legal or contractual obligation to process this information, e.g. to provide inclusive services.
It is also in our legitimate interests to ensure we meet the needs of our service users.
To prevent fraud and confirm eligibility for housing
We will ask for proof of ID – processing for this purpose is required in order to meet our legal obligations. Therefore, if you are unable to verify your identity we may not be able to progress your application.
To assist with personal security and prevention and detection of crime.
We may capture your image on CCTV if you visit an estate or office, which is covered by this facility.
To understand how we’re performing.
We may use your contact details to carry out customer satisfaction surveys to help us monitor performance of us & our contractors, and to improve our services.
It is in our legitimate interest to understand how we and our contractors are performing so we can meet our objectives.
There may also be a legal obligation for us to process the information or to demonstrate to our regulator that we are fulfilling our obligations for example around anti-discrimination laws.
Your personal information may also be used to fulfil our legal obligations, including requirements of our regulators.
Special categories of personal data.
As well as personal information, such and name & address, we may collect sensitive personal information (also known as special categories of data) which may include:
- Racial or ethnic origin
- Religious or philosophical beliefs
- Sexual orientation
- Health/medical information
- Criminal convictions
We use this data to ensure services are delivered appropriately, to monitor equality, diversity, and inclusion, and to aid in the safeguarding of our residents.
We will ask for your specific informed consent at the time of collecting some of this type of data, and will make it clear where providing this data is optional.
You have the right to withdraw this consent at any time.
We may also store confidential data about you including bank account information and property access codes.
How will we protect information about you?
We will apply appropriate technical and organisational measures to ensure your personal information is secure. For example, we have systems in place to ensure that access to personal information is restricted to authorised individuals on a need to know basis.
When we need to share personal data with our contractors, our relationships are governed by our contracts with them, which include confidentiality. Information shared in this way will be limited to your contact information (for arranging repair appointments), and basic information regarding any special considerations – for example if you have a disability which means you may take longer than usual to answer the door.
Who will we share your information with?
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 will data protection law.
Where the information is of a sensitive nature, for example about your health, we will normally obtain consent from you prior to sharing this information, unless we are required to permitted to share this by law or the performance of our contract with you for example sharing this information with medical professionals in order to provide you with care.
Where sharing is in our legitimate business interests or performance of our contract with you, we may share your information without first seeking consent. This may be with:
- Our contractors to facilitate repairs, maintenance, improvements, or compliance works
- Our Tenant Portal (MyAccount) hosting provider, enabling us to provide the online tenant portal allowing you to access your rent account from your own home.
- Local authority teams such as social services, environmental health, and benefit agencies
- Utility companies, Council tax departments, and their representatives to ensure billing details are correct
- Agencies protecting public funds and/or preventing fraud in line with the National Anti-Fraud Network
- Police and other relevant authorities (e.g. Department for work & pensions, and HMRC) in relation to the prevention and detection of crime, and the apprehension of offenders or the collection of tax or duty.
- Other statutory organisations 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.
We will routinely use your contact details to send you information and communicate with you about your tenancy, lease, or service. If you have a preferred method of contact, you can make this known to us, but we will use all means available should we need to contact you or your representatives in the event of an emergency.
Sussex Housing & Care will never sell your personal information to third parties for marketing, or any other purpose.
How long will you keep my data?
We will only hold records during the period of our relationship, and for a set period afterwards to allow us to meet our legal obligations including resolving and following up issues between us. This will be:
- Seven years after the end of a tenancy, providing there are no outstanding arrears
- Eight years after the end of a care home residency, providing there are no outstanding arrears
- Twelve years after you sell your leasehold property, providing there are no outstanding arrears
Your rights in relation to your data
Sussex Housing & Care is committed to upholding your rights in respect of your personal data.
The right to be informed
We will be open and honest about how and why we use your personal data, through this and other privacy notices.
The right of access
You have a right to ask us what personal information we hold about you and request a copy of your information. This is known as a “Subject Access Request” (SAR) – this should be made in writing.
If you are seeking to obtain specific information (e.g. about a particular matter, or from a particular time period), it helps if you clarify the details of this in your written request.
If someone is requesting information on your behalf, they will need written confirmation from you to evidence your consent for us to release this, and proof of ID.
We have one month within which to provide you with the information you’ve asked for.
In response to SAR’s, we will provide you with a copy of the information we hold that related to you. This will not generally include information about your property such as repair logs, contractor visits, or general property maintenance information as this is unlikely to constitute your ‘personal information’.
Please be clear if you are seeking property or repairs related information, as a SAR is unlikely to fulfil your requirements.
The right to rectification
You can ask us to correct your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by keeping us informed if your details change.
The right to erasure
Also known as the right to be forgotten – In some circumstances, you can ask us to delete or remove your personal data where there is no compelling reason for its continued processing.
Data, which we may not erase by request, includes:
- History of anti-social behaviour (ASB)
- Payments/arrears history
- Any other information we are required to keep to fulfil our regulatory or legal obligations
Data, which may be erased by request includes:
- Equalities monitoring information (ethnicity, sexuality, religion, etc)
- Details of your next of kin
- Medical/health information
This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data.
The right to data portability
In the event that you move away from Sussex Housing & Care, you have the right for your data to be transferred to your next landlord or care provider in a commonly used format.
Please contact us to discuss.
The right to object
You can tell us if you object to our processing of your personal data:
- Based on legitimate interests
- For the purpose of direct marketing including profiling
If at anytime you are unhappy with the way in which we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner. More information can be found at www.ico.org.uk