Privacy Notice Tenants
Author: Carl Dixon
Effective Date: December 2024
Next Review Date: December 2027
If you require this document translated or issued in a format which is more appropriate for you, please contact us.
Introduction
Agamemnon Housing Association Limited, is a registered social landlord, regulated by the Financial Conduct Authority, with Register Number 21084R, of Agamemnon House, Lindisfarne Close, Portsmouth, Hants PO6 2SB. We are committed to protecting your privacy. Please read this notice carefully as it contains important information on how we collect and process your personal information. It applies to our tenants and applicants for tenancy; emergency and other care contacts of our tenants; and other visitors to our website.
Agamemnon Housing Association Limited is a data controller.
1. Where we collect information from
a. We collect information about you from a number of sources, including from you directly and from third parties. We will collect personal information from you when:
i. you apply for one of our properties;
ii. you fill in one of our forms or respond to a survey;
iii. you call, write, e-mail or meet with us;
iv. you visit our website.
b. We collect information about visitors to our website, this is mostly statistical data about pages used.
c. We may also collect information such as your image on CCTV or through sound recording equipment at our properties. We sometimes use these to gather evidence of breach of tenancy, alleged anti-social behaviour or crime. We also sometimes take photographs at events, at our properties and in our communities to use in our marketing and publicity materials. Please let us know if you do not wish us to use these photos.
d. We may receive personal information about you from third parties, including:
i. Your local council or benefits office;
ii. A previous accommodation provider;
iii. Welfare or support organisations;
iv. NHS or adult social care professionals or other emergency services;
v. Councillors, MPs or other representatives acting on your behalf;
vi. Family members, Next of Kin or others with Power of Attorney;
vii. Our Alarm Receiving Centre (ARC);
viii. HMRC, child maintenance services, pension providers, the Regulator of Social Housing & Housing Ombudsman or other related services.
2. What information we may collect
a. The information about you that we may collect and store includes:
i. Your name and address;
ii. Your contact details including your email address and phone number;
iii. Proof of your identity, your national insurance number and date of birth;
iv. Financial information including income, benefits and payment details;
v. Details of your Next of Kin and of anyone else who is authorised to act on your behalf;
vi. General details of other household residents;
vii. Details and dates of relevant military service;
viii. Information about your tenancy including anti-social behaviour and complaints made by you, or about you or your household;
ix. Statistical information such as postcode, preferences and interests and other information relating to surveys.
b. We may also collect special categories of personal information, including:
i. Details about any medical conditions which are relevant to your tenancy or that arise whilst resident with us;
ii. Criminal records and convictions;
iii. Information about your ethnicity.
c. Information that we may collect and use includes information on disabilities or other vulnerabilities of tenants and other residents which enable us to tailor our services to support the individual needs and circumstances. This information is also used to safeguard our colleagues.
d. If you do not give us the information we ask for, we may not be able to provide you with all of our services or you may not be able to hold a tenancy with us.
3. How we use your information
a. We use the information we collect about you to help to make sure that our service meets your particular circumstances and needs, and to manage your tenancy. This will include managing your account, undertaking repairs, maintenance or adaptation to our properties, ensuring tenancy terms are followed, and to protect you and other tenants from anti-social behaviour or fraud. We will use the information to comply with our legal obligations towards you, and to safeguard our colleagues where needed. We will also use the information to check how well we are doing so that we can improve our services.
b. We will also use your personal information to contact you directly, including about your tenancy, the housing association and/or to offer opportunities for voluntary involvement. We will only discuss your tenancy with you, those named on your agreement or authorised by you or where it is necessary to do so to enable us to provide services to you or other tenants. We usually communicate with tenants in writing (including email), by telephone or in person. We offer tenants a newsletter with general information and a copy of our Annual Report. We are required by our regulator (the Regulator of Social Housing & Housing Ombudsman) to keep our tenants informed and to offer opportunities for involvement.
c. We may share some of the information we have collected about you with others. But we will only do this where we are allowed to or required to do so by law, or where we have your permission to do so. Before we share your information, we make sure that those we are sharing it with will look after it securely and appropriately.
d. We have the following lawful basis for using your personal data: (i) for the purpose of delivering contracted services, or considering an application for a tenancy, or position or role with us; (ii) to protect the vital interests of you or another person at our properties; (iii) with your consent which may be implied if you voluntarily share information with us; (iv) for our legitimate interests as a housing association, and/or your landlord (as appropriate) which will include ensuring the appropriate management of a tenancy and the property, understanding our tenants needs and support requirements; obtaining feedback or other information to comply with our statutory obligations as a housing provider and/or to improve our services.
e. We may share your information with:
i. Contractors who carry out services on our behalf;
ii. Utility companies;
iii. Government departments and local councils;
iv. Solicitors, professional advisors and consultants;
v. Representatives acting on your behalf e.g. your M.P.;
vi. Organisations carrying out surveys or other kinds of research for us;
vii. Auditors;
viii. The police and other security organisations involved in investigating crimes;
ix. Other housing associations or trusts;
x. The NHS and other health and welfare organisations;
xi. Probation services;
xii. Charities and voluntary organisations;
xiii. Courts and tribunals;
xiv. Debt collection agencies.
f. We will not give, sell or lease your information to any third parties for marketing purposes. We may use your information to send you details of events or support available at our premises, including information relating to maintenance services where appropriate.
4. How we take care of your information
a. All of your personal information is kept on computer systems in the UK. The information on these systems may be copied for testing, backup, archiving and disaster recovery reasons. Our computer systems are maintained carefully to provide a high level of security.
b. We will not transfer or store your personal data outside of Europe (the EEA) or to a country outside of the control of the UK or European regulations.
c. We store personal information for different lengths of time depending on your relationship with us.
i. If you are a tenant, we will keep your information for as long as you are a tenant or where money is owed to us, and for a maximum period of three years afterwards except for financial information which we will keep for seven years after your tenancy ends. We will keep the basic history of who was a tenant at which property indefinitely.
ii. CCTV images are usually only held for 30 days before being overridden, unless there is a specific incident which requires a portion of the CCTV to be recorded for a longer period – when we will hold it as required by the law.
iii. If you are not a tenant, we will keep your information for a maximum period of three years.
d. We will destroy your information securely when we no longer need it.
5. Your Rights
a. You have rights under data protection law to protect and take care of your personal information. Where you have given your consent for us to use some of your personal information, you can withdraw this at any time. You can also ask us:
i. For a copy of the personal information that we hold and process about you;
ii. To give you your information in a portable way;
iii. To correct any inaccurate information about you;
iv. To delete your personal information;
v. Not to make decisions about you in a fully automated way.
b. These rights may apply in limited circumstances, and we may not always be able to comply with your request. We will tell you when this is the case.
c. We will aim to respond to your request within one month of receiving it. If you would like any of your information to be corrected, please contact us using the details below. Where information is corrected, we will provide you with proof of this.
d. If you have any questions or concerns about this notice or how your personal information is being processed, please contact our Data Protection Officer at our head office. The address is: Agamemnon House, Lindisfarne Close, Portsmouth, PO6 2SB; enquires@agamemnon.org.uk.
e. The Information Commissioner can provide independent information about keeping your personal information private, and you can also complain to them about how we have used your personal information if you wish to. Their website is: https://ico.org.uk/
6. Changes to this Privacy Notice
a. This Privacy Notice will be updated from time to time. When this happens, the most up to date version will always be available on our website: https://agamemnon.org.uk.
7. Summary
When and how we collect your information
|
Information that we usually collect
|
Why we collect it
|
How long we will normally hold it for
|
---|---|---|---|
Information provided during our application processes and during your tenancy |
About you: your name, address and contact details, proof of your identity; relevant financial information such as your income and benefits; details of anyone who is authorised to act on your behalf and/or who is an emergency contact; general details of other household residents; relevant military service details; statistical information such as postcode, preferences and interests and other information relating to surveys. About your tenancy, including: anti-social behaviour and complaints made by you, or about you or your household. Other sensitive information, including: details about any relevant medical conditions; criminal records and convictions; your ethnicity. |
To manage your tenancy, lease or application To improve our services to you To communicate with you about your tenancy and our services To make sure that our services can meet your needs To comply with our legal obligations towards you and others |
For three years after you stop being a tenant, or for three years after you clear any debt owed to us. For 12 months if your application does not result in a tenancy with us. If you do not give us the information we ask for, we may not be able to provide you with all of our services or a tenancy. |
When you complete one of our forms on our website or on paper, contact us or meet with us | Your name, address and contact details together with the details that you provide to us about the purpose of your contact. |
To deal with your enquiry To manage your tenancy, lease or application To improve our services to you To communicate with you about your tenancy and our services |
This information is held with a tenancy file, for three years after you stop being a tenant; or for 12 months for other enquiries which do not result in a tenancy with us. If you do not give us the information we ask for, we may not be able to deal with your enquiry |
Where you make payment(s) to us by direct debit | Your bank account and other financial information | To process your direct debit payments and to allocate payments to your tenancy | For seven years after you stop being a tenant, or for three years after you clear any debt owed to us. |
When we use CCTV, sound recording or take photographs at our properties | Images and/or sounds of you and your household from time to time |
To gather evidence of breach of tenancy, alleged anti-social behaviour or crime. To promote and market our services, but only with your permission |
CCTV images are usually only held for 30 days, unless there is a specific incident which requires a portion of the CCTV to be recorded for a longer period – when we will hold it as required by the law |
When you fill in one of our surveys | Your name, contact details and anything else relevant to our services |
To analyse how well we are doing To improve our services to you |
Survey responses will be held for 12 months or as long as you are a tenant, unless it needs to be kept for legal reasons. Anonymised summaries will be kept indefinitely. |