Wandle Housing Association (Wandle) processes personal data to allow us to deliver services to our customers. In legal terms Wandle is the controller of the personal data you have provided to us. This Statement explains what personal information we collect from you, how we collect it and what we use it for.
The information we collect
Wandle will only collect the personal data we need from you to deliver our services. The type of information we collect from you depends on our relationship with you. We will have different data for people who rent homes from us, than those who use our community investment services, or are our employees.
We collect information about you when you make an application with us or a referral is made by you for one of our services. We also collect information when you voluntarily complete customer surveys, provide feedback or through general correspondence. Website usage information is collected using cookies. Further information may be collected during the course of a tenancy, for example photographs of properties when assessing repairs requests, or if your personal circumstances change.
The information we process about you may include;
- Details about you and your household, including:
- date of birth,
- copies of relevant identification documents,
- employment details.
- Details about your home, your housing needs and tenancy agreement.
- Rent and service charge information, including details of any arrears.
- Financial information, including:
- credit checks,
- income details,
- bank details,
- housing benefit information,
- any guarantor details.
- References received about you (for example from your employer or previous landlord).
- Medical information and emergency contact details, next of kin and any advocate.
- Information about any accidents or incidents which involve you or your home.
- Information about any complaints made by you, or which relate to you.
- Photographs taken of you or your property, such as CCTV footage or photos taken for repairs assessments.
- Audio recordings of calls made to our contact centre and other correspondence you have with Wandle.
Why we collect this information
We collect the majority of the information contained on your application or referrals to provide you with housing and associated services, such as carrying out of repairs and monitoring any defects. In technical terms this means we mainly use ‘performance of a contract’ as our legal basis for processing your data.
Further information is also collected at the point of tenancy sign-up, for the purposes of equal opportunities monitoring. Where this information is collected it is always with your explicit consent.
We may collect other information as part of our community investment work. This will only ever be done with your consent and when you sign-up to a particular service or opportunity.
We do process some personal data because it is in our legitimate interest to do so. Such examples may include sharing personal data with a contractor so that they can complete works to your property or communal areas.
We may also have to process personal data because we are obliged to by law. An example would be where we collect information via a CORE form so that we can submit data to our regulator.
How we collect this information
Information will be collected from you personally when you enter into an agreement or contract with us, such as through a tenancy agreement. This will be in the form of applications and any other forms which may be completed to apply for one of our properties.
It is possible that we will receive referrals containing your information from public bodies such as local authorities, but this should be done with your consent and knowledge of why they are making the referral to our services.
We may generate further personal data regarding our tenants during the course of the tenancy. This could be in the form of general correspondence, or to satisfy our statutory obligations. An example of fulfilling our statutory obligations and collecting personal data would be where photographs of properties are required for the purposes of monitoring defects or for assessing any health and safety risks.
How we will use the information
We use this data in the following ways
- To allocate homes;
- To manage tenancies (including collecting rent and other charges);
- To provide key services including repairs, ongoing support, and benefit advice;
- To make financial arrangements related to your home, such as to enable automatic rent payment through direct debit or housing benefit payments, or deal with any mortgage arrangements;
- To set up arrangements relating to your home, such as informing the Local Authority of your tenancy arrangements for council tax and housing benefit purposes;
- To help other people or companies to provide services or utilities to your home or to contact you. This may include where they need to contact you when you first move in, to set up payments or about any unpaid bills while you live at your home and/or after you leave your home;
- To investigate and address complaints, accidents or incidents and prevent reoccurrences;
- To provide information to our staff to enable them to provide services that meet your needs, and to train and protect them where necessary;
- To deal with any medical or other emergencies and to carry out your wishes or requirements, including any religious or cultural wishes;
- To act in someone’s best interests, for example where we have concerns about a person’s health or welfare and may need to involve agencies such as social services or the police;
- To ensure fair and equal access for all to our services;
- To help us plan and improve the services we provide, personalise our customer services and meet our tenants’ needs;
- To provide care/support services to you, or work alongside other organisations who provide care/support to you and to deal with any issues arising about your care/support services;
- To meet our obligations to bodies involved with your care/support (such as the relevant Local Authority department, Social Services or the Care Quality Commission) and show that we are meeting our obligations as your care/support provider;
- To meet any legal and regulatory requirements and show that we are meeting our obligations as your landlord (including allowing access to information when we are audited);
- To help us put together statistics to give to our regulator or other government organisations;
- To provide information to you about Wandle, including our newsletter;
- To provide references to third parties where we are asked to (such as to a new landlord);
- To prevent and detect crime (this will include the usage of CCTV).
Special Category Data
Wandle sometimes processes special category personal data about you. Special categories of personal data which we might process includes: racial or ethnic origin, religious or philosophical beliefs, sexual orientation, information about your health, and sometimes information about criminal convictions.
We use this special category data to ensure services are delivered appropriately and to monitor equality, diversity and inclusion. In the case of certain health information, this may be needed for health and safety purposes and / or social protection.
Where Wandle processes this type of data about you we will do so given one or more of the following:
- When we have your consent to do so (such as equality monitoring oinformation);
- Where we need to protect the vital interests (i.e. the health and safety) of you or another person;
- Where you have already made your personal information public;
- Where we or another person need to bring or defend legal claims; and/or
- Substantial public interest grounds (usually for equal opportunities monitoring)
Where we process personal data about criminal convictions or offences we will always have a lawful basis for doing so and make sure we satisfy the requirements of the DPA 2018 as set out by the ICO here.
We will apply strict security and confidentiality measures when processing any special category data and limit its accessibility and use to only those who require it for legitimate use.
Where provision of this information is optional, we will make this clear at the point of collection and we will ask for your specific informed consent at the time of collecting this type of data. Where you provide consent for us to process sensitive personal information, you have the right to withdraw this consent at any time.
There may be times where we will not need your consent to process (including sharing) this type of data. This will apply where we are permitted or required to do so by law, for example under Health and Safety Legislation or where processing of this data is necessary in order for us to carry out our obligations under Social Protection Law.
If you have been the subject of a complaint or we consider you to be a risk to our staff, we will inform you and place a “flag” over your tenancy. This is to protect our staff and contractors.
Who we will share your personal data with
Where information is used for the reasons listed above, we may need to share the information about you and the people you live with to other organisations. This will include:
- Companies which provide services or utilities to your home (such as the gas, electric or water board) and the relevant Council Tax department. This may be while you are living at your home or after you leave your home and may include providing a copy of your tenancy agreement when you move in and providing a forwarding address when you leave. This information may be provided to enable the company to set up your payment arrangements and/or to pursue any unpaid bills.
- People who provide services on our behalf, such as a managing agent or contractors carrying out repairs etc.
- A credit checking agency, your bank and mortgage company or other financial institutions and (where necessary) a debt collection and/or tracing agency.
- The Housing Benefit department and other Government departments which provide funding for your housing or care/support services. In particular, we may be legally required to give information about any changes in your financial circumstances to the Housing Benefit department.
- Resident representatives and board members involved in our complaints process.
- A doctor, hospital, paramedic or health worker where you require medical attention and are unable to provide the information yourself.
- Your next of kin or other people acting on your behalf in an emergency and a member of your church or religious leader, where you have requested this.
- People or agencies who provide services to you or who work with us to provide services to you, such as your care/support provider.
- The bodies involved with your care/support such as the relevant Local Authority departments, or Social Services and any alarm call centre.
- Our regulator or other bodies which look at how we provide services as your landlord and other people where we are legally required to provide information to them.
- Our legal advisors, the courts and the police. This may include information about anti-social behaviour, which we may also share via a joint website accessed by landlords, the police, social services and other bodies with the aim of reducing anti-social behaviour.
- Relevant Local Authority departments (including housing benefit, council tax, elections, adult services, fraud teams etc.)
- To relevant people and authorities such as the police, adult and child protection and social services. This may include sharing information when we have concerns about a person’s health or welfare, or where there are investigations being carried out, such as sharing information in a case conference with such bodies and other parties involved (such as teachers, nurses, etc.) or where we have concerns about possible criminal activity.
- Companies who process information on our behalf such as an external mailing company (who send out our newsletter), our archiving company, our confidential waste disposal company and providers of our information technology services and software.
- To another landlord or housing association where you are looking to move or exchange your property (e.g. where they request your details and/or a reference from us).
- Companies who help us survey our customers, to gather feedback on quality of services and other issues relating to our work as a social landlord.
How long we will keep your data for
Wandle will hold your personal data for the length that it is required to provide you with services. We may be required to retain some of your data after this time, for a set period, for us to meet our legal obligations including resolving any follow up issues.
We maintain a data retention schedule which sets out how long we keep different types of information for. This is based on guidance from our membership body, the National Housing Federation, and certain legal requirements.
Please contact our Data Protection Officer if you would like further information on how long we keep certain types of data.
Occasionally, we may need to transfer your personal data outside of the UK to other contractors.
For example, if we were to use a software system that is hosted on servers outside of the UK.
Where this is the case, we take appropriate steps to ensure that we only contract with organisations that have the appropriate security measures in place.
Access to your information and correction
You have the following rights regarding your personal data:
|Right available||Description of right||The right in practice|
|Right of access||You have the right to obtain confirmation from Wandle as to whether or not personal data concerning you are being processed, and, where that is the case, access to that personal data.||Wandle will provide a copy of all personal data belonging to you, or specific personal data if you so require it. This will not include the personal data of any other individuals, or information regarding Wandle’s operations. We will redact where necessary for the purposes of confidentiality.We are often asked to provide a copy of a resident’s tenancy file. There is no one definition of what a ‘tenancy file’ includes. At Wandle we consider your tenancy file to be anything saved on our Housing Management System and Storage Management System . This does not necessarily include data we may hold on team or individual files or all the correspondence you have had with Wandle.Your tenancy files does include:Logs of calls and some other correspondence which has been logged by our staff under your tenancyImportant documents such as your tenancy agreement, plus other documents which may have been stored under your name throughout your tenancyYour historical rent payments|
|Right to rectification||You have the right to oblige Wandle to rectify inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed by providing a supplementary statement.||This will only apply to inaccurate personal data; information contained on your application form or any “flags” placed on your record. This will not lead to any other information which you disagree with being rectified, merely personal data which is inaccurate.|
|Right to erasure (right to be forgotten)||You have the right (under certain circumstances, but not all) to oblige Wandle to erase personal data concerning you. This will never include current tenancy details as necessary to fulfil our contractual obligations, or any information we are required to process under law.||The right to be forgotten only applies:|
– Where the personal data is no longer necessary
– If you withdraw consent
– If we unlawfully held your personal data
– If you successfully object to our processing
– If we have to follow a legal obligation to delete.
|Right to restriction of processing||You have the right (under certain circumstances, but not all) to oblige Wandle to restrict processing of your personal data. For example, you may request this if you are contesting the accuracy of personal data held about you.||This right only applies:|
– Where you contend the accuracy of any personal data until it has been made accurate
– Where you have objected to any processing whilst we present our evidence
– If we are processing anything unlawfully and you do not wish for it to be erased
– If we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.
|Right to data portability||You have the right (under certain circumstances, but not all) to oblige Wandle to provide you with the personal data about you which you have provided to in a structured, commonly used and machine-readable format.You also have the right to oblige Wandle to transmit those data to another controller.||This right only applies to data collected by automated means (i.e. excluding paper files) and where the legal basis for us processing this data is consent or for the performance of a contract (AKA your tenancy agreement). If you wish to obtain your data for the purposes of data portability then please contact our DPO.|
|Right to withdraw consent||If the lawful basis for processing is consent, you have the right to withdraw that consent. If you wish to withdraw your consent, contact us immediately.||Processing based on consent is likely to be limited to photographs at events, equal opportunities monitoring and non-housing related work by our Community Investment Team, such as employment training. Withdrawing consent will not affect the legality of any processing carried out before consent is withdrawn e.g. leaflets distributed will not be recalled.|
|Right to object to direct marketing||Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for marketing, which includes profiling to the extent that it is related to such direct marketing.||This right will apply instantaneously in most instances. While Wandle does not engage in direct marketing activities, we still reserve the right to contact you regarding important matters unrelated to marketing e.g. chasing rent arrears.|
|Rights in relation to automated decision making and profiling||Wandle does not perform any automated decision-making based on personal data that produces legal effects or similarly significantly affects you.||Unlikely to occur in practice; Wandle does not carry out any automated decision making based on profiling. Where profiling is carried out without automated decision making, we will inform you if it crosses a certain threshold.For more information about any of your rights, please visit: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/|
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Who to contact and how
For further information regarding your personal data or about Wandle’s approach to data protection in general please contact:
The Data Protection Officer
Wandle Housing Association, Second Floor, 230 Blackfriars Road, London SE1 8NW
If you are not satisfied with the response you receive you have the right to lodge a complaint with the supervisory authority. In the United Kingdom this is:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
0303 123 1113