Supported Housing Privacy Notice

Privacy information – current customers and those applying for a home with us
How we use your information
This Privacy Notice is to let you know how we use your information and what we do with it. Stonewater is a landlord and committed to ensuring that your privacy is protected.
As part of its role Stonewater collects, uses and stores information about you for the purposes of assessing your housing application, managing your tenancy and support with us, and enhancing our communities. Provision of information requested by us may form part of a ‘Contractual Requirement’. Without this information, we may not be able to provide this service. We are responsible for the information we hold about you.

As a provider of support services, we process data about your health and social care to deliver our services and to safely meet your assessed needs. We also process this information because it is necessary in the performance of a contract, to fulfil our legal and regulatory obligations and because it is in our legitimate interests to do so.
Where we are providing care and support services as part of a local authority contract, we may share your information with the commissioning local authority.

Children
We do not usually gather information directly from children as part of our core landlord service. We may process information relating to children in our households where it has been provided to us during our relationship with you. In such cases, we process that information based on our legitimate interests and to fulfil our legal and regulatory obligations.

We also process some of your data because it is in our legitimate interests to do so. You can object to this processing if you think that your legitimate interests outweigh ours.

We consider that we have a legitimate interest to make sure that:
• Our services/properties meet the needs of our customers
• We can contact Customers in the event of emergencies and to carry out essential repairs
• We communicate with Customers to meet our business objectives, encourage social inclusion and help build communities
• We work with authorities, stakeholders and the police to support safer communities
• We have effective procedures for preventing, and managing, outstanding debt resulting from unpaid rents
• We make the most efficient use of our resources and we understand how we are performing
• We understand our Customers’ experiences and views so that we can effectively influence and contribute to debates on future housing strategies

We have split this document into sections so that you can easily find the information you need. The document covers:
• How we collect your information
• What Information we use about you
• What we do with that information
• How long we keep hold of your information
• Who we might share your information with and why
• Your rights
• Withdrawal and consent
• How to contact us

You can contact us at any stage with queries or concerns using the details in the 'Contact Us' section below.

How we collect your information
We collect most of our information directly from you, including when you apply for one of our properties or services, complete one of our forms, when you write, email or meet with us, or respond to a survey.

We also collect information from other third parties where is it relevant to our relationship with you. This includes customer survey providers or organisations that carry out maintenance and repair services on our behalf as well as:
• Local councils and central government departments such as the Department of Work and Pensions – for information about your benefits
• Local authorities, health and social care professionals, previous care providers – for information about your health, care and support needs, and those of your household (including your children)
• Previous landlords and credit agencies such as Experian – for your rental history, credit checks and information about your financial status/history
• Home Office, local authorities – for information about your immigration status, where relevant
• Police and other public authority fraud departments, local authorities – for information on criminal activity, but only where it is relevant to your tenancy or application
• Other Customers – we may receive information in relation to complaints

What information we use about you
As part of your application for housing, you provide us with information about you, any partner or joint applicant, and those living with you. When you provide information about household members, we assume that you do so with their full knowledge and consent. In particular, we collect the following information:
• Name (including previous names), address, contact details and date of birth
• National Insurance Numbers
• Proof of your eligibility to housing and if you have an interest or equity in other property
• Your household income
• Any relevant health conditions, disabilities or vulnerabilities
• Any third parties who you are involved with, including those offering support and services
• Immigration status
• Bank details, if you pay your rent by direct debit
• Property history including previous tenancies with Stonewater, rent arrears, legal action in relation to your tenancy
• Support history including any engagement with statutory agencies such as Social Services, Mental Health Teams
• Previous complaints about anti-social behaviour
• Criminal record or on-going criminal or civil proceedings
• Whether anyone acts on your behalf and whether you have capacity
• Details in relation to your health
• Relevant details of your personal life and your support requirements
• Any previous behaviours that we may consider risky such as drug and alcohol misuse
• Copy of identification documents
• Information provided by our credit checking agencies
• Information provided by your references, including probation officers, social workers, or local authorities

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.

When you become a customer of ours, we will also hold other information about you, your household or visitors, provided by either you or third parties. This will include:
• An image of you, your household or visitors, to enable us to provide effective support to you and all our customers
• Contact details of your next of kin, relevant relatives and other named contacts
• Details of your current support requirements, including progress against personalised outcomes
• Details about your emotional and physical well-being
• Details of your contacts and interactions with our staff/contractors and volunteers
• Information provided by previous landlords, agencies, such as Social Services, Mental Health Teams, and your referees
• Any correspondence with or about your support and housing needs, risk management
• Rent statements and rent payment records
• Details of any complaints made by or against you or your visitors
• Any correspondence we have at your request with third parties
• Where your safety and/or the safety of our staff, customers, contractors or members of the public is believed to be at risk, we will record this information on your record so that risks are minimised

In most of our services, we operate closed circuit television (CCTV), sound recording and/or use photography to ensure your safety, capture evidence of breach of tenancy, alleged anti-social behaviour or crime.

The calls to our Customer Contact Centre are recorded for training and monitoring purposes. These recordings can also be used as evidence in disputes or investigations of our customers or colleagues and are usually held for a period of 6 months.

We may also take photographs at our events, our properties and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for these purposes with your consent.

Where we have photographs of your visitors due to anti-social behaviour or complaints, these will be kept on file for as long as you are a customer of ours.

If you do not provide the information we have asked for, we may be unable to provide you with certain services or benefits. If this arises, we will discuss with you the implications of that decision.

What we do with the information we hold
We will only use your personal data in accordance with the law.

We may need to use your information to ensure compliance with the terms of your tenancy agreement, to discharge our legal obligations, to fulfil contractual obligations or to undertake activities that are within Stonewater's legitimate interests, or in the public interest.

There are various ways we use your information, for example:
• The information provided in the application for housing is required to progress and consider your application at your request, to tackle fraud and to comply with the obligations and rights in your tenancy agreement
• We use relevant health and disability information for the purposes of ensuring that you receive the most appropriate form of housing for your needs
• We use relevant previous and current support information to ensure you receive effective support from us and other support services, including statutory agencies
• We use previous and current personal information about you to effectively manage your safety and that of our staff, contractors and other clients
• We share information with authorised contractors and commissioners to provide Landlord services, for example repairs, and temporary / supported accommodation services. Where we need to share personal data with our contractors and commissioners, the relationship is governed by a contract, which will include strict data sharing and confidentiality protocols. We only share personal information that is necessary to deliver the service and meet our contractual obligations
• We work closely with third parties such as Local Authorities and other government agencies to ensure that you are acting within the law, and for them to provide you with relevant assistance where appropriate
• We also use relevant information to ensure the safety of those within our neighbourhoods and communities and to tackle crime and anti-social behaviour
• We will use your information and record of your housing and support to respond to any queries or complaints made by you or members of your household and to deal with requests such as repairs and maintenance of your property
• We will keep some information about you for Equality and Diversity monitoring purposes, although we will never use this information to make decisions about you
• We pass data about your rent payment record to credit reference agencies to enable them to assist other organisations to assess your financial standing if you apply for products and services
• We conduct research and statistical analysis to help improve the services offered to customers and our internal business processes, as well as to evaluate our performance. Where possible, statistical information is anonymised or pseudonymised
• We conduct surveys relating to our services in order to assess satisfaction and make improvements based on customer feedback

If in the future we need to process your personal data for a new purpose, we will provide you with further information about the nature and purpose of such proposed processing.

How long will we keep your information?
We will only keep your information for as long as necessary to fulfil the purpose we collected it for. Including for the purposes of satisfying any legal, accounting, or reporting requirements and in accordance with our disposal and retention guidelines.

There may be personal information that we are required to hold for longer in accordance with our obligations under legislation, for example information in relation to safeguarding or care issues, or under legislation such as the Right to Buy, or Health & Safety.

Who will we share your information with?
We will not share your personal information with third parties unless we are permitted or required to by law. Information about you and your household may be shared, only in appropriate circumstances with the following third parties:
• Local Authorities and government agencies to ensure you have access to appropriate benefits and services, and to protect the interests of you, your household and your neighbourhood
• Credit reference agencies for the purposes of carrying out credit reference checks
• Our IT providers for the purposes of maintaining secure and up to date tenancy records and filing systems
• External repairs, maintenance providers, and health & safety consultants, in order to carry out our obligations under the tenancy and relevant legislation
• Debt collection agencies and legal advisers for the purpose of collecting rent and any other payments due under the tenancy agreement, and any other enforcement issues
• Where necessary, to utility companies, local authorities, probation services, support workers, doctors, drugs and/or alcohol services, MPs, police and our professional advisors such as auditors and solicitors

Where we share your information, we always ensure that we provide only what is necessary and that appropriate arrangements are in place to protect the security and confidentiality of your information.

Your rights
You have the right to:
• Object to us using your information in certain ways
• Have your information deleted from our systems in certain circumstances
• Request details of personal information, which we hold about you under the Data Protection Act 2018, including information about how we use that information
• Rsk us to correct or update your information if you believe that any information we are holding is incorrect or incomplete
• Request that we transfer your information directly to a new landlord or other third party in certain circumstances

If you would like us to look into any of these rights, please contact, us and we will consider your request carefully. There may be circumstances where we still need to use your information in certain ways or keep hold of it, despite your request. If that is the case, we will explain this to you.

You also have the right to lodge a complaint with the Information Commissioners' Office if you believe that we have not used your information properly, or if you have any other concerns about the way in which we deal with your information.

Further information about your data protection rights appears on the Information Commissioner’s website at the ico website

Withdrawal of consent

We may need to collect certain personal information by law, or under the terms of a contract we have with you.

If you choose not to give us this personal information, it may in certain limited circumstances delay or prevent us from meeting our obligations to you. It may also mean that we cannot perform the services you have asked for. In some circumstances, it could mean that we will need to terminate our relationship with you.

We will always tell you at the time we try to collect such personal data, if your refusal to provide that data may impact on our ability to provide services to you.

If you change your mind, or you are unhappy with our use of your personal data, please contact us.

Contact us
If you have any queries or questions about the way we use your information or you would like to talk to us about any of your rights as set out above, please contact us:

By email:
data.protection@stonewater.org

By post:
Stonewater Ltd,
Suite C, Lancaster House,
Grange Business Park,
Enderby Road,
Whetstone,
Leicester, LE8 6EP

By telephone:
01202 319119

Last updated
This notice is regularly reviewed and updated to ensure that it is accurate. This notice was last updated in December 2019.
Where there are substantial changes to this notice, which might affect you, we will let you know.