1. Important information and who we are
1.1.2 This policy applies to personal information about applicants, customers, and other service users.
1.1.3 This website is not intended for children under the age of 16 and we do not knowingly collect data relating to children unless it is legitimately required.
1.1.5 By giving Homes for Lambeth your information or by using our website you are confirming that you’re agreeing to be bound by this policy.
1.2.1 To ensure that all processing and controlling of information adheres with the data protection policy and complies with Data Protection Act 2018 and UK GDPR.
1.2.2 This policy covers and applies to all users of HFL’s website and “Addition” websites: www.additionhomes.co.uk
1.2.3 This policy covers all stakeholders (internal and external), who have any relationship with HFL
1.2.4 This policy applies to all previous, current, and prospective tenants and interested parties.
1.2.5 To create and maintain a positive and pro-active approach to data protection when working with tenants’ information.
1.4 Contact details
1.4.2 Full name of legal entity: Homes for Lambeth Group Limited
1.4.3 Email address: firstname.lastname@example.org
1.4.4 Postal address: [DPO, Homes for Lambeth, Lambeth Town Hall, 6 Brixton Hill, SW2 1RW.
1.4.5 Telephone number: 0204 526 9326
1.4.6 You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), who is the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
1.5.2 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.6 Third-party links
2. The data we collect about you
2.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
2.1.1 Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2.1.2 Contact Data includes billing address, delivery address, email address and telephone numbers.
2.1.3 Financial Data includes details related to your financial history and credit worthiness, bank account and payment card details.
2.1.4 Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
2.1.5 Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
2.1.6 Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
2.1.7 Usage Data includes information about how you use our website, products, and services.
2.1.8 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.2 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, doctors, occupational therapists, etc.
2.3 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 our ability to provide some services to you if you refuse to provide information that stops us from doing so.
2.5 In order to access some of Homes for Lambeth services and for legislative purposes it may be necessary to collect your sensitive personal / special category information, which may include gender, race, ethnicity, physical or mental health needs, income and outgoings and bank details.
2.6 In order to manage anti-social behaviour, it may be necessary for applicants and existing tenants to disclose their unspent criminal convictions and offences.
2.7 If you fail to provide personal data that we need to collect by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you tenancy services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
3. How is your personal data collected?
3.1 We need to collect, process and store personal information about you and other household members or sometimes relatives in order to fulfil our obligations as a landlord and to deliver efficient and effective services.
3.2 We use different methods to collect data from and about you including through:
3.2.1 Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
(a)apply for our products or services;
(b)create an account on our website;
(c)subscribe to our service or publications;
(d)request marketing to be sent to you;
(e)enter a competition, promotion, or survey; or
(f)give us feedback or contact us.
3.2.3 Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
(a) analytics providers such as [Google] [based inside OR outside] the UK]
(b) advertising networks such as [Google] based [inside OR outside] the UK]; and
(c) search information providers such as [Google] based [inside OR outside] the UK].
(d) Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
(e) Identity and Contact Data from data brokers or aggregators
(f) Identity and Contact Data from publicly available sources [such as Companies House and the Electoral Register based inside the UK].
4. How we use your personal data
4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
4.1.1 Where we need to perform the contract, we are about to enter into or have entered into with you.
4.1.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4.1.3 Where we need to comply with a legal obligation.
4.2 Please see Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
4.3 Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
4.4 Purposes for which we will use your personal data
4.4.1 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
4.4.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of Data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity
|Performance of a contract with you|
|To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(b) Asking you to leave a review or take a survey
(c)Retaining your information for a reasonable amount of time after the relationship has ended
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
4.5.1 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
4.6 Promotional offers from us
4.6.1 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
4.6.2 You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
4.7 Third-party marketing
4.7.1 We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
4.8 Opting out
4.8.1 You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
4.8.2 Where you opt into receiving these marketing messages this will not apply to personal data provided to us as a result of a product/service purchase or experience or other transactions.
4.10 Change of purpose
4.10.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
4.10.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
4.10.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
5.1 Normally, only our employees will be able to see and process your personal information. However, there may be times when we will share relevant information with third parties. When sharing personal information, this will be done on a strictly need to know basis and we will comply with all aspects of the Data Protection Act and the General Data Protection Regulation.
5.2 Sensitive information about health, sexual orientation, race, and religion is subject to particularly stringent security and confidentiality measures. Such information may be used for equality and monitoring purposes.
5.3 We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
5.3.1 Internal Third Parties as set out in the [Glossary].
5.3.2 External Third Parties as set out in the [Glossary].
5.3.3 Specific third parties as set out in the [Glossary].
5.4 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
6.1 We do not transfer your personal data outside the UK.
6.2 In the event that we do transfer your personal data out of the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
6.2.1 We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
6.2.2 Where we use certain service providers; we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
6.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
7.1 To ensure you have confidence that your data is protected, we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
7.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7.3 Where we are collecting data for equality and monitoring purposes, we will ensure that your data is anonymised.
8. Data Retention
8.1 How long will you use my personal data for?
8.1.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
8.1.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
8.1.3 By law we may have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for certain periods after they cease being customers.
8.1.4 In some circumstances you can ask us to delete your data: see your legal rights below for further information.
8.1.5 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
9.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
9.1.1 See 10.3.1 (a)
9.1.2 See 10.3.1 (b)
9.1.3 See 10.3.1 (c)
9.1.4 See 10.3.1 (d)
9.1.5 See 10.3.1 (e)
9.1.6 See 10.3.1 (f)
9.1.7 See 10.3.1 (g)
9.2 If you wish to exercise any of the rights set out above, please contact our DPO on the details given at the start of this policy.
9.3 No fee usually required
9.3.1 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
9.4 What we may need from you
9.4.1 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
9.5 Time limit to respond
9.5.1 We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10.1 LAWFUL BASIS
10.1.1 Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
10.1.2 Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
10.1.3 Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
10.1.4 Consent means processing your personal data where you have given your explicit consent to that processing. We do not typically rely on or require your consent to process personal data and will only ask for consent where we are unable to rely on an alternative lawful basis for processing.
10.2.2 External Third Parties
(a) Service providers acting as processors based United Kingdom who provide IT and system administration services.
(b) Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
(c) HM Revenue & Customs, local authorities, government departments as necessary, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
(d) With other registered providers, trusts and landlords in connection with tenancy references and associated enquiries.
(e) Utility companies and their representatives and Council Tax Offices to ensure billing details ae correct.
(f) Credit reference agencies and debt collection agencies in connection with any outstanding charges and housing sales.
10.3 YOUR LEGAL RIGHTS
10.3.1 You have the right to:
(a) Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
(f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
11. Legal & Regulatory Framework
|List of relevant legislation or regulation|
|Data Protection Act 2018|
12. Related HFL Policies
This policy links to the following HFL policies:
• Data Protection Policy
• Retention Policy
13. Related HFL Procedures
This policy links to the following HFL procedures:
14. Version Control
|Version Number||Revision Date||Summary of Changes||Author|
|1.0||New Policy||Head of IT and Devonshires Solicitors|