Stafford and Rural Homes (SARH) complies with its obligations under the General Data Protection Act by keeping your personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
The remainder of this policy outlines the various ways the Stafford and Rural Homes Group collects, stores and uses different forms of information that is unique and personal to you.
Fair Processing Notice
The Stafford and Rural Homes Group (SARH) takes your privacy and the security of your personal information very seriously. This Fair Processing Notice is a public document that sets out our approach to safeguarding the privacy of the personal information we hold. It is available to everybody and applies explicitly to our customers (tenants and leaseholders), staff, contractors and other agents who deliver services to, or on behalf of SARH.
SARH communicates with customers, staff and other stakeholders in many different ways. This ranges from telephone calls or in writing through to electronic paperless forms of communication such as texts and e-mail.
This Fair Processing Notice (sometimes referred to as Privacy Notice) applies to all personal information collected by Stafford and Rural Homes Limited and its staff, our subsidiaries, partners, and contractors or agents acting on our behalf.
Data Controller – SARH is the Data Controller and is responsible for making sure the personal data that falls under its remit complies with regulation requirements when it is being processed.
Data Subject – The person who the personal information is about.
Data Protection Officer (DPO) – A Data Protection Officer (DPO) is a person in charge of ensuring an organisation’s compliance with the Data Protection legislation.
Information Commissioner’s Office (ICO) – The UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals.
Personal data – Information relating to living people who can be identified from that data and other information which is in the possession of, or is likely to come into the possession of, the data controller.
Processing data – Includes obtaining, sharing, disclosing, recording, holding, using, erasing or destroying personal information.
About Stafford and Rural Homes
Stafford and Rural Homes is defined as ‘the Data Controller’. This means the organisation decides why, and in what way personal data is managed.
SARH owns and manages over 6,000 homes across Stafford and the surrounding area. We also deliver a number of local Independent Living schemes and employ almost 200 staff.
SARH has a number of wholly-owned Subsidiary companies who conduct work for us as well as independent work, including Housing Worx Limited, Development Worx Limited and County Town Homes Limited.
- Housing Worx Limited – a company limited by shares established to carry out commercial activities on behalf of SARH;
- Development Worx – a company limited by shares established to manage diversification into property investment and market sale; and
- County Town Homes Limited – a company limited by shares established to develop homes for sale at market rates.
SARH Head Office is located at The Rurals, 1 Parker Court, Staffordshire Technology Park, Beaconside, Stafford, ST18 0WP. Telephone 0800 111 4554
About the information collected and used by SARH
Stafford and Rural Homes is responsible for collecting, processing and storing securely both personal and other general information that is required as part of our day-to-day business activities. We manage personal information in accordance with data protection legislation, including the General Data Protection Regulation (2016). SARH is registered with the Information Commissioner’s office (ICO).
- SARH (Reg. No Z9313273)
- Housing Worx (Reg. No Z353773)
Development Worx and County Town Homes are exempt from ICO registration, data is processed for core business purposes only, but as Subsidiaries they comply with the data protection provisions of the SARH Group.
About the personal information we collect
SARH collects information from you in a variety of ways, including when you apply for one of our homes or services, complete one of our forms in hard copy or online, when you write, e-mail or meet with us or respond to a text message or survey. We also collect information when you use our social media sites, website or the customer self-service portal ‘SARH Online’.
Phone calls, Live Chat, E-mails and Text messages may be recorded for business related purposes. Safeguards are in place to store recordings securely.
We operate a CCTV system at SARH Head Office and other premises such as Pennycrofts Court and William Horton Court for the detection and prevention of crime and evidencing anti-social behaviour.
From time to time we may operate CCTV / sound recording and / or use photography to capture evidence about a breach of tenancy, alleged anti-social behavior or other forms of crime.
We may also take photographs at our customer 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 will not collect information about you that we do not need and we will ensure that the personal information we collect is updated to our systems in a timely and accurate manner.
We may apply markers to your information (for example, in relation to your vulnerability or health status) to enable us to tailor and deliver services to you and ensure your welfare and that of our staff. We will write to advise that this marker has been added.
The information we may collect about you could include, but is not limited to:
- Date of birth
- National Insurance number
- Contact details (phone/mobile/email)
- Details of anyone authorised to act on your behalf (if applicable)
- Disabilities or vulnerabilities (so services can be tailored to your needs)
- Convictions, proceedings and criminal acts
- Photographs and CCTV images
- Banking details if you pay your rent by Direct Debit.
- Card details if you pay by card (however card details are not stored).
- Proof of housing eligibility, including any interest or equity in other property
- Other personal information that will vary on a case by case basis to help us resolve a breach of tenancy, alleged anti-social behaviour or fraud.
About additional information we may collect
SARH manages a number of additional services including:
- organising community events,
- providing a Money Advice Service for our customers to help maximise your income and reduce any outstanding debts,
- adapting the property you live in,
- You First Telecare Service (helping the elderly and vulnerable customers remain safe at home) and;
- Health and Wellbeing Services for specific customers according to need,
- gathering information to improve our services.
Other information we may collect from you, in relation to delivering these services includes:
- Financial information. We gather financial information before confirming an offer of accommodation to assess affordability. We may use this information 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.
- Additional health or disabilities information to support requests for adaptations made to the property you are living in or to assess your eligibility for support.
- Photo ID, bank statements, pay-slips or income details when we require this information for processing a house sale or purchase
For additional services, where your personal information is needed, we will 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.
If you indicate that you wish to be part of the Mutual Exchange list, SARH may display or make available the contact information you have provided for this purpose on sarhomes.wpengine.com or in its public reception areas in order that other members of the Mutual Exchange list may contact you. You may request that your information be removed from this list at any time by contacting us.
What if you choose not to provide the information that is required?
There are occasions where, as a customer, member of staff, volunteer or contractor, you may not want to share your information with us or decide to withdraw the consent you have previously given. It is within your rights to refuse or withdraw consent, however, it may mean that the services we are able to offer you are limited and you are unable to access more personalised features of those services.
Some items of information you cannot refuse to supply (or withdraw consent to allow its use). For example, you will not be able to exercise a choice when you are required by law to provide information. Not supplying information when required could invalidate your contract or tenancy with SARH.
If you decide not to provide the information that SARH needs, then we may not be able to provide all our services to you, and ultimately you may not be able to hold a tenancy or lease a property with us or purchase a property through us. This also applies to offers of employment or awarding contracts to provide services to or on behalf of SARH
About the personal information we receive
We may receive information about you from third parties including:
- Your council or benefits office relating to your housing.
- Prior landlords and credit agencies when you apply for housing.
- Police, welfare or support organisations dealing with you.
- Councillors, MPs or other representatives acting on your behalf/instruction.
- Financial institutions when you apply for our services.
How we use your personal information
SARH uses your information to respond to your enquiries, provide you with services and oversee the relationship and interaction you have with us.
The information we require from you may be used to manage your tenancy or leasehold agreement or as part of another contract between you and SARH (such as a contract of employment or to provide services).
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 (or contract) conditions are complied with, such as dealing with anti-social behavior or fraud.
- Complying with relevant legislation and regulation.
- Processing contracts of employment
- Processing contracts to provide services to or on behalf of SARH
We will regularly review the personal information we hold about you and make changes to any service or information-handling processes when the law or the Information Commissioner’s Office (ICO) requests such changes.
Processing data through contracts
The basis for processing personal data in relation to a contract applies when SARH:
– has a contract with an individual and it is necessary to process their personal data to comply with our obligations under the contract.
– Has not yet got a contract with the individual, but they have asked SARH to do something as a first step (e.g. provide a quote) and it is necessary to process personal data to do what they ask.
Please read contracts carefully for specific details. Look for headings such as ‘performance of a contract’ because this is usually the legal basis for processing your personal information. ‘Processing is necessary in the context of a contract or the intention to enter into a contract’.
SARH conducts research and statistical analysis to help improve our business processes and the services we offer to our customers, as well as to evaluate our performance against other benchmarks. When possible, statistical information is anonymised or ‘pseudonymised*’. (*Pseudonymised Data is created by taking identifying fields within a database and replacing them with artificial identifiers or pseudonyms)
SARH conducts surveys regularly and periodically relating to our services in order to gauge satisfaction and make improvements based on your feedback. SARH use third parties to conduct research on our behalf.
Keeping your information secure
We store personal information both electronically and in paper form.
SARH operates a range of information and communications systems and technologies for the efficient operation of the business. Personal information is stored and managed within those systems. They are maintained to achieve a high level of security and confidentiality including following best practice in cyber security.
Security policies, processes and technical security solutions are designed to protect the personal information we hold from:
- Unauthorised access
- Improper use or disclosure
- Unauthorised modification
- Unlawful destruction or accidental loss
When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, support workers, solicitors) act on your behalf we will take steps to ensure that you have agreed for them to do so. This may include asking them to provide us with supporting information to confirm they have your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.
Employees and third parties who have access to, or are associated with the processing of, your personal information are obliged to ensure its confidentiality.
The information we hold in IT systems may be copied for testing, backup, archiving and disaster recovery purposes. All data is held within the UK.
When browsing the SARH website and communicating electronically with us, you are asked to acknowledge and give your consent to our processing your personal data.
Applying to work at SARH
If you submit an application to work for SARH we will use your personal information to process your application and to produce and monitor recruitment statistics.
We will not take up references without your prior permission.
We will not share or disclose your information unless you have given us your consent; or we are required to do so by law. Where we are required to carry out a Disclosure and Barring Service check we will comply with the law and your rights when carrying out these checks.
We retain personal information relating to unsuccessful applicants for no longer than 6 months.
As An Employer
As your employer, SARH needs to keep and process information about you for normal employment purposes. The information we hold and process will be used for our management and administrative use only. We will keep and use it to enable us to run the business and manage our relationship with you effectively, lawfully and appropriately, during the recruitment process, whilst you are working for us, at the time when your employment ends and after you have left. This includes using information to enable us to comply with the employment contract, to comply with any legal requirements, pursue the legitimate interests of the Company and protect our legal position in the event of legal proceedings.
As an employee, you will, of course, inevitably be referred to in many company documents and records that are produced by you and your colleagues in the course of carrying out your duties and the business of the company.
As a housing association we may sometimes need to process your data to pursue our legitimate business interests, for example to prevent fraud, administrative purposes or reporting potential crimes.
We will only disclose information about you to third parties if we are legally obliged to do so or where we need to comply with our contractual duties to you, for instance we may need to pass on certain information to pension providers etc. information may also be transferred about you to other group companies for purposes connected with your employment or the management of the Company’s business.
How we share your personal information
We will not normally share your information without your consent unless we are required to by law.
We will usually seek your consent directly and also explain to you about how your information may be used at the time you provide information e.g. sign a tenancy agreement or enter other forms of contractual arrangement with us.
Information may be shared with our Subsidiary Companies, which provide services to you on behalf of SARH and in which SARH has overall control through direct ownership.
Our legal obligations
We will share specific and relevant information with law enforcement and government agencies or public bodies where we are legally required to do so. Processing of personal data may not always require your consent.
Examples may include:
- The prevention or detection of crime and fraud
- The apprehension or prosecution of offenders
- The assessment or collection of tax or duty owed to customs and excise
- Sharing in connection with legal proceedings
- Sharing in relation to the physical or mental health of an individual, disclosure is required to protect them or others from serious harm
- Research and statistical purposes
We may also share your information with emergency services and local authorities, where this is necessary to help them respond to an emergency situation that affects you.
Sharing information with our partners
In some areas we may enter into partnerships with other organisations such as local authorities and the police. For example, we may join a partnership to help prevent and control anti-social behaviour. We will enter into a data sharing agreement before any information sharing takes place with a partner organisation.
Sharing information with our Subsidiaries, contractors and suppliers
There are some cases when we will share your information to support appropriate business purposes.
We do this to ensure that we can meet your needs, and also to meet our health and safety obligations towards those delivering services on our behalf. This may include sharing information with our Subsidiaries, contractors and suppliers to enable them to carry out duties on our behalf or to meet contractual obligations they may have. For example, we may share information to enable our maintenance contractors to make appointments with you to carry out repairs and/or deliver services.
How we use your telephone number
Text messages and contact via telephone provide a direct way to contact and share information with you about the services we can deliver to you.
We may use your telephone number that you have provided us with to keep in contact with you by text. When we send SMS/text messages, there may be someone in your household who may read the message before you are able to. You may like to inform the people who live with you that you may receive text messages from SARH from time to time.
Operational SMS/text messaging and calls
If you supply us with your telephone contact details, we may use them to call or send you operational text messages.
Examples of operational text messages include:
- Confirming a repair and/or a time and date for a repairs contractor to visit
- Confirming a home visit
- Sending a reminder about an appointment
- Asking you to contact a named person
You cannot opt-out of the use of your telephone numbers for operational purposes.
Sharing your telephone number with third parties
We may pass your telephone number to third parties so that we can meet our contractual obligations with you. We may also share your telephone numbers if we are required to by law. In doing so, we will comply with the data protection legislation.
We may supply the details to our third party contractors who are delivering or performing services on our behalf. These companies must not use your information for any other purpose. We never share with or sell your telephone numbers to telesales/marketing companies.
Telling us about changes to your personal information
If the information we hold about you is incorrect you have the right to ask us to correct it without undue delay and free of charge. You can exercise this right at any time by contacting us on tel. 0800 111 4554 or emailing firstname.lastname@example.org. There may be occasions where we require additional information in order to process your request – such as a name change needing proof of the change of name – and you will be required to specify the information that is incorrect and what it should be replaced with.
Contacting us about your personal information
We will be as open as possible with you about the personal information we hold about you, and if something is wrong we want to work with you to put it right.
Right of Access
You have the right to access the personal information that we hold about you, to know what we hold, what format it is in, and to have a copy of it if you wish.
The context in which individuals may make requests for their own personal data can often be readily met in the normal line of business e.g. by asking for and receiving feedback on the progress of their housing application or the request for a repair.
When a request for personal data may be more complex, the management of such requests is governed by a process called a Subject Access Request. This is a more formal process than, for example, simply requesting a second copy of your rent statement. Our staff will explain when your enquiry falls under the Subject Access Request process.
Right of Erasure / Right to be Forgotten
You have the right to request that all data held by SARH which identifies you is deleted. We may be compelled to maintain your information due to specific legislative or regulatory requirements, for example we keep copy invoices in case of an HMRC investigation and if you have held a contract with us we will retain that information.
Requests to erase a data subject’s personal data can be refused where personal data is processed
- to exercise a right of freedom of expression and information;
- to comply with a legal obligation or for the performance of a task of public interest;
- for the exercise or defence of legal claims; or
- for purposes relating to public health, archiving in the public interest, scientific/historic research or statistics.
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Questions and complaints
Please tell us if you have a concern about the personal information we hold about you, or how we use it. We’ll do our best to help.
If, after contacting us, you are still not satisfied you can complain to the Information Commissioner.
If you are a SARH customer, our customer services team will be able to help you with most queries and requests you may have. If you want to contact us specifically about the privacy of your personal information, please contact:
Data Protection Officer
Executive Director Resources
The Rurals, 1 Parker Court, Staffordshire Technology Park, Beaconside, Stafford ST18 0WP
Or email email@example.com
Keeping this Fair Processing Notice updated
We keep our Privacy Notice under regular review. This privacy notice was last updated in May 2018.