Housing Privacy Statement

Who we are and what we do

The Housing and Maintenance Team at Papworth Trust is responsible for letting, managing and maintaining the Trust’s housing stock including services to tenants. We undertake day to day repairs, compliance activity and planned maintenance programmes. The service also delivers new accommodation either directly or via partners including Housing Associations and wholly owned trading companies. We collect and recover income for the Trust’s housing stock.

Retention – Why we need your information and how we use it

The processing of this information is necessary for compliance with legal obligations primarily under the Housing Acts 1985, 1988, 1996, and 2004, the Crime and Disorder Act 1998, the Anti-social Behaviour, Crime and Policing Act 2014 and the Localism Act 2011. We take your privacy seriously and will only use your personal information to administer your Housing account and to provide services you have requested from us or that we need to provide/enforce. We follow the principles of Data Protection legislation, as well as respecting people’s rights to confidentiality and privacy. Personal data can include information supplied to us such as:

• Asking people for their names, addresses and health information on an official form, either online or in paper form
• Proof of ID, such as passport, driving licence
• Photograph to be held with your tenancy

Papworth Trust is required to collect certain information about you and your household to carry out services and other activities associated with managing its housing functions and to comply with statutory responsibilities. We will collect information from you in line with Article 6(1) of the UK General Data Protection Regulation for the following purposes:

• To allow us to manage your housing, tenancy or lease and rent account as your landlord and to communicate with you in this regard
• Assessment, allocation and management of housing stock
• Property and grounds maintenance and repairs
• Property adaptations

We share your information with service delivery partners who deliver services on our behalf, such as contractors for the delivery of maintenance services and provision of support services. We may also share your information with government and welfare agencies to support the detection and prevention of fraud and crime. We rely on contract and legitimate interest as a lawful basis on which we collect and use personal data. We rely on consent as the lawful basis on which we collect and use special category data.

The Data Protection law gives you the right to apply for a copy of information about yourself. This is called a ‘Subject Access Request (SAR)’. Under a SAR, we will also tell you:

• How we collect your information
• What we use it for
• How we process the data
• Who else we share it with

There are some exceptions, set out in the legislation, where we won’t be able to provide you with your personal data. Examples of this include where it’s been used by us in order for us to seek legal advice, or where we’ve received it from someone else in confidence and we’re bound by that obligation.

Using your personal information

Personal information which you supply to us and information about other household members* may be used in a number of ways, for example:

• To make housing decisions
• For fraud prevention
• For audit and debt collection
• For statistical analysis
• To arrange access for repairs and servicing
• To ensure ourselves and our contractors are aware of any vulnerability
• To complete regulatory and statutory returns to government departments

* When you provide information about household members we assume that you do so with their full knowledge and consent. We may share your information with, and obtain information about you from, central government agencies, credit reference agencies or fraud prevention agencies. We routinely share information with other local authorities, in safeguarding cases and as part of multi-agency meetings. We will not disclose any other information, unless required to do so by law.

Information we hold about you and how we use it:

• We keep financial records about the amount of money you have paid us, any amounts outstanding and action taken to recover money you owe
• We hold names and dates of birth and information about your previous housing circumstances to assess housing applications and help prevent tenancy fraud and illegal subletting
• We hold contact details for you so we can communicate with you, and to keep you informed about other services we offer which may be useful to you
• We record information about your needs and requirements 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
• We record information to assist us in delivering housing management services including reports of anti-social behaviour, complaints, change in circumstances
• We may capture your image on our CCTV systems if you visit an office which is covered by this facility. Any recordings will be held in accordance with our corporate retention policy before being erased. This data may be shared with the Police in relation to the prevention or detection of crime or fraud
• We may carry out customer satisfaction surveys to help us to monitor our performance and to improve our services to our customers

Generally, the information we hold will have been provided by you (on application or enquiry forms or when we communicate with you), but we may also hold information provided by third parties where this is relevant to your housing circumstances (e.g. from social workers and health professionals, doctors and occupational therapists) as well as information based on our interactions with you. We will only ask for personal information that is appropriate to enable us to deliver our services. In some cases, you can refuse to provide your details if you deem a request to be inappropriate. However, you should note that this may impact on our ability to provide some services to you. We are committed to keeping your personal details up to date, and we encourage you to inform us about any changes needed to ensure your details are accurate.

How long we keep your information: We will only hold your records during the period of our relationship with you and for a set period afterwards to allow us to meet our legal obligations including resolving any follow-up issues between us (for example, if you live in one of our properties we will hold information about you for the duration of your tenancy). If you move and are no longer a tenant, we will usually keep records about you for up to 6 years.

Who your information may be shared with (internally and externally): When sharing information, we will comply with all aspects of the Data Protection Act. Where necessary or required, we may share your personal information as follows:

• With our contractors, in order to undertake repairs, maintenance, compliance or improvement works
• With third party service providers in connection with services performed on our behalf, e.g. if we use a research company for a resident satisfaction survey or if a reference is requested by another housing provider
• Our relationships with such providers are governed by our contracts with them which include strict data sharing and confidentiality protocols
• With utility companies (and their representatives)
• With credit reference agencies and debt collection agencies, in connection with some housing applications and in relation to any outstanding charges
• With local authorities and government departments, as necessary for administering justice or for exercising statutory, governmental, or other public functions
• With police and other relevant authorities (e.g. Probation Service, Department of Work & Pensions, HM Revenue & Customs) in relation to prevention or detection of crime and fraud, the apprehension or prosecution of offenders and the assessment or collection of tax or duty
• With other statutory organisations, e.g. social services and health authorities, as necessary for exercising statutory functions

This list is not exhaustive. There are other circumstances where we may also be required to share information, e.g. to meet our legal obligations. We will use all information held by us for law enforcement, regulation and licensing, criminal prosecutions and court proceedings.

International transfers: Your data will be processed in the UK.

Protecting your information

Any information held by us about individuals is held securely and in compliance with the General Data Protection Regulation. We are committed to protecting personal data. The information security measures we've put in place include:

• Following good Information Governance practice and the law when it comes to collecting, handling and giving access to information
• Training staff in their data protection responsibilities
• Processes to ensure good Information Governance practices for information we collect, hold or handle in both manual and electronic forms
• Access to your information is only given to those who need to know and where it is necessary
• Information will not be held for longer than required and will be disposed of securely

We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Your information choice and rights

Where we use your personal data for other purposes other than what you have consented to, fulfil a statutory obligation, or where data protection law allows, we will let you know so you can make an informed choice. You have the right to request that any incomplete personal data are completed, including by means of a supplementary statement. You have the right to request that your personal data are erased if there is no longer a justification for them to be processed. You may not be able to object to your information being used, held, or shared in certain circumstances: for example, where there is a duty to safeguard an adult at risk, prevent and detect crime, or fulfil statutory obligations. To withdraw your consent or opt out of information use:
Papworth Trust
1 Saxongate
Bradbury Place
Huntingdon, PE28 3RR
Email: dataprotection@papworthtrust.org.uk

Information Commissioner’s Office

If we are unable to resolve your complaint to your satisfaction, you can make a complaint to the Information Commissioner’s Office at www.ico.org.uk.

The Information Commissioner is the UK's independent body set up to uphold information rights.