Privacy policy

Crosby Housing Association Ltd

Crosby Housing Association Ltd recognises the importance of respecting your personal privacy and the need to have in place appropriate safeguards surrounding the processing of personal data. As a company who has access to and controls your personal data (a ‘Data Controller’) we are required to provide you with certain information about how we collect, store, destroy and otherwise deal with (also known as ‘process’) your personal data. We are also registered with the Information Commissioner’s Office (‘ICO’) as a Data Controller.

Who is the data controller and what are their contact details?

The Data Controller is the company that decides the purpose for and the way in which any personal data is processed. Crosby Housing Association Ltd is a data controller and is registered with the ICO. Details are set out below:

Crosby Housing Association Ltd
10 Church Road
Waterloo
Liverpool
L22 5NB
ICO registration number: Z6786706
Registered as a Community Benefit Society with FCA registration number: 19175R
Housing Regulator registration number: L1719

 If you are in any doubt as to who your Data Controller is please contact us in writing at the above address.

Do we have a Data Protection Officer?

Crosby Housing Association Ltd. does not have a designated Data Protection Officer. However, the Association can be contacted with queries and information requests in writing at:

Crosby Housing Association Ltd
10 Church Road
Waterloo
Liverpool
L22 5NB

What information do we collect/receive about you and how?

We hold personal data that may include your household’s names, dates of birth, contact details and records of any transactions such as payments or requests for information as well as sensitive personal data such as gender, ethnicity, religion or other beliefs, sexual orientation and medical history.

We may collect information about you in a variety of ways including (and this list is not exhaustive):-

  • we receive a nomination from a local authority or referring partner;
  • various forms, and contracts (such as application forms, tenancy agreements, etc);
  • you apply to become a tenant; we obtain information to determine your housing needs from relevant organisation and in order to help us assess your application we may take up references from organisations such as housing providers/private landlords, credit reference agencies;
  • request any of our services;
  • you voluntarily complete our customer surveys;
  • Provide feedback or make a complaint;
  • Make an application and become a member of staff;
  • Make an application and become a Board member;
  • Our officer/agents/contractors attend appointments with you;
  • You contact us or use our services and we note any action taken, for example logging repairs, so that we have a record of what happened;
  • We engage in other aspects of routine contact with you;
  • from support agencies and third parties which relates to you;
  • from people associated with you such as family, friends and neighbours;
  • through your use of our websites, social media sites and self-service portal;
  • We may take photographs at events organised and hosted by Crosby Housing Association Ltd. The images would be used on websites of Crosby Housing Association Ltd, in brochures and other publicity material (such as newsletters) and may be provided to the media for publication in local or national newspapers. You will always be given the option not to be included in a photograph and use of any images would only be with your consent.
  • at some housing schemes and our charity shop we have CCTV cameras to record events in public areas and we monitor and collect visual images for:-
    • Security reasons
    • Prevention and detection of crime; and
    • Staff safety and monitoring purposes.

Please be aware that if you provide us with personal information relating to members of your family or your associates we will assume that you do so with their knowledge and consent.

It is important that you notify us of any changes to your personal information as soon as possible so that we can contact you easily.

What is the lawful basis under which we use your data?

Processing personal data is lawful if the data subject (eg. you as our customer) has given consent or where the processing of personal data is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Processing of your data is lawful if you apply for housing with us, apply for a job with us or have been housed by us. We do not need your explicit consent to process your data in these circumstances.

Do I have to provide this information and what will happen if I don’t?

Where you are a tenant of ours we will use your personal data to contact you about your rent, repairs or other housing management issues. The consequences of not providing accurate and up to date personal data in this example may mean that we could not properly and effectively manage your tenancy under the agreement we have with you.

Who the personal information relates to

We collect and hold personal information about:

  • Customers – This includes current, former and potential customers who live in our properties or access our support and other services and includes members of their family and people associated with them.
  • Visitors – Visitors to our website and our offices.
  • Anyone who makes a complaint or enquiry to Crosby Housing Association Ltd.
  • Partners – employees and representatives of organisations with whom we do business including contractors, suppliers and other agencies.

How will we use the information about you?

We use your personal information to:

  • Enable us to provide you with accommodation and to communicate with you
  • Undertake Property and grounds maintenance and repairs
  • Manage your housing, tenancy/lease and accounts as your landlord or provider of another service to you
  • Ensure that we meet all our legal and statutory duties such as those which apply under the Equality Act, Fire safety etc and those owed to our funders and regulators
  • Promote equal opportunities and fair treatment for all our customers
  • Provide information you request from us
  • Help with crime prevention, prosecution of offenders and resolve disputes
  • Prevent and detect fraud and money laundering
  • Promote safety and the quiet enjoyment of our neighbourhoods and communities in our capacity as social housing providers
  • Engage with customers and make improvements to our products and services
  • Improve services by gathering your feedback through surveys
  • To protect individuals from harm as part of our safeguarding and other obligations
  • Keep in touch with our customers, understand your needs and preferences and invite you to events.
  • Carry out research and to provide anonymised information to help improve our services

Sensitive personal data

Certain personal information is classified as ‘special categories data’ and means any personal data which tells us about your ethnic origin, political opinion, religious or philosophical beliefs, trade-union membership or anything revealing your genetic data, biometric data or anything which has the purpose of uniquely identifying you, anything concerning health or data relating to a person’s sex life or sexual orientation, allegations of criminal offences and criminal convictions and offences.

We minimise our holding and use of special categories data but, given the services we provide, there are times when we use it to understand our customers and their needs better, for example when providing accommodation for disabled persons or those with problems around substance abuse, when resolving neighbourhood disputes involving alleged criminal activity or when helping someone to access care services. When we collect specific sensitive data we will notify you of how we will use it, including who it may be shared with, and seek your consent to this.

Will you be using my information to make any automated decisions?

We do not propose to use your personal data to make any automated decisions. Should our policy change, we will write to you and tell you this.

Who we will share/send your information to:

Your personal information will be kept secure and confidential and access to it by staff of Crosby Housing Association Ltd is managed and monitored.  We may share information with contractors or agencies we work with such as Local Authorities, Social Services, Police, other social landlords and any other situation where we are required by law and/or where we believe it is in your or the public’s interest to do so.

We may share your data with companies who provide cloud-based information services and systems. Any third party asked to process your personal data on our behalf will be bound to strict terms and conditions outlined by us and will not be permitted to share your data with other organisations.

We will not transfer your data with any organisation outside of the European Economic Area.

The list below sets out specific examples of where we may share your information but this is not an exhaustive list. In processing your personal data we may:-

  • share information with contractors concerned with providing services in line with your tenancy agreement
  • share current or forwarding addresses with utility companies and Council Tax offices to ensure billing details are correct
  • share information about you with authorised debt recovery agencies to enable them to recover the debt if you default on any tenancy/licence conditions. This may affect future applications for tenancies credit and insurance
  • discuss your financial situation and share information about rent payments (including any arrears) and any claims made for welfare benefits with the local authority housing benefit department, the local authority’s housing advice and homeless prevention team or the Department of Work and Pensions to make sure that benefits are paid correctly
  • pass your contact information to a third party to conduct surveys and research on our behalf which allow us to gather feedback and improve the services we offer you
  • share your National Insurance number to verify your Universal Credit application and manage these payments
  • also share your National Insurance number in order to prevent and investigate tenancy and Right To Buy application fraud
  • share information with government bodies and organisations to inform social housing funding, regulatory and housing policy decisions (click to view Annex 2 of the CORE data sharing agreement)

Changes to this privacy notice

This privacy notice will be updated from time to time to reflect any changes either to the way in which we operate or changes to data protection legislation. We will bring any significant changes to your attention.

How long will you store my personal data for?

We store personal data in line with guidance from the National Housing Federation, a copy of which is available on request. Examples are:

Applications for accommodation: kept for 6 years after offer accepted;

Tenancy files: kept for 6 years after the end of the tenancy;

Application forms for shortlisted job applicants: 1 year;

Application forms for non-shortlisted job applicants: 6 months.

How will my personal data be stored and kept secure?

The Associaiton applies technical measures to keep personal data stored securely on information systems, including controls over the organisation’s information network perimeter, such as firewall, anti-virus software and back-up/replication measures to prevent data loss. Access to personal data held on systems is controlled by password and can be monitored by audit records. Sharing of data with third parties is controlled by the use of secure transfer measures such as encypted email and secure file transfer protcols.

The data held on mobile devices (smart phones, tablets and lap-tops) used by staff are encrypted. Staff are equipped with lockable bags for carrying personal data files outside of the office and we apply a clear desk policy in our offices.

The technical measures are supported by training and awareness raising exercises to ensure that staff understand the risks and their responsibilities for keeping personal data secure.

Your rights in relation to the personal data you provide: 

We have set out below some information on the rights you have under the General Data Protection Regulation effective from 25 May 2018. More information can be found by visiting the ICO website at www.ico.org.uk.

You have the right to:

  • be informed about our collection and use of your personal data;
  • access the personal data we hold about you (see below);
  • ask us to rectify any personal data we hold about you if it is inaccurate or incomplete;
  • be forgotten – i.e. the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time as explained above but if you would like us to delete it sooner please contact us). Please be aware however that we need to maintain certain records to enable us to provide you with the services you enjoy and that we may have a contractual or statutory obligation to provide so certain information may still be retained despite any such request to be forgotten;
  • restrict (i.e. prevent) the processing of your personal data;
  • data portability (obtaining a copy of your personal data to re-use with another service or organisation);
  • object to us using your personal data for particular purposes;
  • rights with respect to automated decision making and profiling (we will inform you where such decisions and profiling occur); and
  • you may withdraw your consent to our use of your information where the information was previously provided with your consent, please advise us if you wish to withdraw any consent previously given by writing to:

Crosby Housing Association Ltd
10 Church Road
Waterloo
Liverpool
L22 5NB

If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 2 above and we will do our best to solve the problem for you. If we are unable to help you also have the right to lodge a complaint with the ICO; please go to www.ico.org.uk.

Accessing your information

You have the right to access any personal information we hold about you. There is a formal process for this known as a Subject Access Request (SAR).  If you would like to make a SAR please send a request in writing to our registered office address above.  We may require some proof of identity from you before releasing information. From 25th May 2018, we are required to provide this information within one month of receiving your request and will not normally make a charge for this service. However, we may make a charge where we consider the amount of information you have requested to be complex or if you make numerous requests, and we may then take up to three months to fulfil your request.

Website Privacy Policy

For more details on how we treat information that we gather about your activities on our websites please view our Website Privacy Policy here.