Data Controller:
Golding Homes, County Gate One, Staceys St, Maidstone, Kent ME14 1ST
Introduction
Golding Homes is a ‘Data Controller’ under Data Protection Laws. This means we make decisions about how we process your personal information in the course of managing your relationship with us, how we use your information for our legitimate business needs, who we may share it with and why, how long we need it for and the technical and organisational measures we need to implement to safeguard your information and to protect your right to privacy, confidentiality and security of personal information.
We take your privacy seriously and are committed to protecting your information and using it fairly, lawfully and transparently. The purpose of this policy is to outline our approach to data protection, information security and how we protect your information under our control. The aim of the policy is to provide you with assurance that we will only use and share your information lawfully and within the requirements of Data Protection Laws.
The information we hold about you may vary depending on what services we are providing to you. Personal information will only be collected, created or otherwise obtained for specific, explicit and legitimate purposes and will not be used for any other incompatible purpose.
This Privacy Policy will provide you with information about how your personal data will be processed by Golding Homes.
Our Privacy Promise
Golding Homes promises:
- Never to sell your personal data.
- To be transparent about what we do with your personal data and to keep you informed when this changes
- To respond to any of your requests regarding your information in a timely and effective manner.
- To respect your rights as a data subject and to process your information lawfully, ethically and to maintain security of the information provided.
What information do we collect?
We collect information about you when you make an application with us for a tenancy, home purchase or shared ownership or a referral is made by you for one of our services. We may also collect information when you voluntarily complete customer surveys, provide feedback or where there is general correspondence. Further information may be collected during your tenancy or relationship with us.
The table below sets out what personal data we may process, our purpose for doing so, our lawful justification and how long we keep it for:
| What personal data we process | Our purpose for doing so | Our lawful justification | How long we keep it for |
|---|---|---|---|
| Details about you and your children, including name, date of birth, address, contact details, identification (including National Insurance number), documents provided to us, employment details | Allocating homes, managing our services, managing your tenancy and relationship with us, identifying you are who you say you are, meeting our obligations as a registered provider | Performance of a contract, Legitimate interest Legal obligation |
6 years from the end of your tenancy with us |
| Details about your home, household and your housing needs and tenancy agreement | Allocating homes, managing our services, managing your tenancy and relationship with us, providing repairs, meeting our obligations as a registered provider | Performance of a contract Legitimate interest | 6 years from the end of your tenancy with us |
| Your rent account and payment history | Managing your tenancy commitments | Performance of a contract | 6 years after the end of your tenancy |
| Welfare benefit referrals, Housing Benefit notifications, Universal Credit verifications, rent statements | Managing your tenancy commitments and relationship with us, meeting our obligations as a registered provider | Performance of a contract, Legal obligation Legitimate interest | 2 years |
| Details about your home when you apply to shared ownership | Allocating shared ownership homes, managing your relationship with us | Performance of a contract, Legitimate interest, Legal obligation | 6 years following the end of your tenancy |
| Right to Buy / Acquire information | To administer Right to Buy / Acquire applications | Legal obligation, legitimate interest | 10 years |
| Rent and service charge information | Allocating homes, managing our services, informing relevant local authority departments, managing your tenancy with us | Performance of a contract, legitimate interest | 6 years following the end of your tenancy |
| Financial information, including any credit checks, income details, bank details, housing benefit information | 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 departments 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 help with improving your credit score | Performance of a contract, Legal obligation, Legitimate interest Consent | At least 3 months |
| References received about you (e.g. from your employer or previous landlord) | Allocating homes, managing our services, administration | Legitimate interest | 3 months |
| Medical information, emergency contact details, next of kin or any advocate, Information about any accidents or incidents which involve you or your home. | To provide information to our staff to enable them to provide services to you to 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 such as any religious or cultural wishes To act in someone’s best interests such as 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 support you in your tenancy and meet our obligations as a registered provider | Consent, Social Protection Law Protecting Vital Interests in extreme circumstances. | 6 years following the end of the tenancy |
| Information about any complaints made by you or which relate to you | To handle any complaints, manage your tenancy | Legitimate Interest, Contract | 6 years following the end of your tenancy |
| The way in which you conduct your tenancy if you are in breach of your tenancy conditions | To respond to breach of your tenancy conditions | Contract, Legitimate interest | 6 years following the end of the tenancy |
| Information regarding your marketing preferences | To deliver marketing materials such as our newsletter or make note of your preferences | Consent Legitimate interest Legal obligation | Refreshed every two years |
| Any photographs taken of you or your property | Monitoring defects, assessing any health & safety risks, administering tenancies and security. | Consent Legitimate Interest | 6 years following the end of your tenancy |
| Any marketing materials/photos taken at events | To promote our services | Consent Legitimate interest | Refreshed after 2 years, otherwise deleted |
| Equality information | To ensure fair and equal access for all to our services; To help us put together statistics to give to our regulator or other government organisations | Legitimate interest Consent | 6 years following the end of your tenancy |
| Convictions, proceedings and criminal acts | To deliver our services, safeguarding, employee safety | Legal obligation, Employment law, Prevention and detection of crime | 6 years following the end of your tenancy |
| Call Recordings | To improve our services | Legitimate Interest | 60 days following recording |
| CCTV footage | For the prevention and detection of crime | Legitimate Interest | 28 days following recording Until it is no longer required to use in evidence for criminal or civil proceedings |
If we deem there to be a risk to our staff, we may place a flag over your tenancy. When we do so, we will inform you and ensure that these flags are regularly reviewed.
We may keep some of your information longer than the periods listed above. This will be to satisfy our legal obligations and maintain certain records where appropriate to do so under our legitimate interest.
We also maintain a Retention Schedule, detailing how long we keep all items of information at Golding Homes beyond those generally listed above. This is available to view on request.
Our Legitimate Interests
A legitimate interest means that we need to process information necessary for Golding’s business or commercial interests, to meet our obligations as a registered provider or to meet the lawful and legitimate interests of another organisation, for example the collection of unpaid debt or for crime prevention and detection purposes. When we rely on any legitimate interest, we will conduct a legitimate interest assessment to ensure that we take a balanced approach and have appropriate safeguards in line with your expectations. If we rely on any legitimate interest, we will tell you what that is.
Our legitimate interests include:
- Having appropriate security, for our offices and on our sites. This includes CCTV and identification photographs.
- Handling and investigating complaints.
- Keeping, maintaining and producing our records.
- Collecting and servicing unpaid debt.
- Recording threatening and unacceptable behaviour.
- Obtaining information from third parties.
- Official Communications.
- Keeping our records up to date, working out which of our products and services may interest you and telling you about them.
- Engaging with you to seek your feedback on improvements and changes to our products and services.
- Contacting you with matters regarding your tenancy with us
- Sharing your information with local utilities providers in the event of unpaid debts.
- Processing for business efficiency purposes and enabling services to be provided.
- Analyses for business insight, planning and future organisational service or development requirements.
- Working collaboratively with other associations to take a multi-agency approach to managing aggression, violence, crime prevention and detection.
How will we collect this information?
Information will be collected from you personally when you enter into an agreement / contract with us. This will be in the form of applications and any other forms which may be completed electronically or written to apply for one of our properties, to become a tenant, to manage your tenancy and relationship with us, in receiving or responding to communications from you or when requesting a repairs or support service from us.
It is possible that we will receive referrals containing your information from public bodies such as local councils where we have properties, but this should be done with your knowledge of why they are making the referral to our services. This information should be made available to you from the public body at the point of data collection and through their privacy notice.
We may generate further personal data regarding our tenants during the tenancy. This could be in the form of general correspondence, or this may need to be generated to satisfy our statutory obligations. An example of Golding Homes fulfilling its statutory obligations and potentially collecting personal data would be where photographs of properties are required for the purposes of monitoring defects or for assessing any health & safety risks.
Who will we share it 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, with other organisations for lawful and legitimate reasons. This include:
| Who we share your information with | The purpose for sharing it | Our justification for sharing |
|---|---|---|
| Companies which provide services or utilities to your home (such as gas, electricity or water suppliers) and the relevant Council Tax Department | Payment for these services Debt recovery Fraud investigations | Legitimate interest, Legal obligation. |
| People who provide services on our behalf, such as a managing agent, contractors carrying out repairs | Fulfilling the tenancy agreement, Repairs, Defect rectification | Legitimate interest, Contract, Health and Safety, Legislation |
| A credit checking agency, your bank and mortgage company or other financial institutions and (where necessary) a debt collection and/or tracing agency | Allocating and administering properties and tenancy agreements, Fraud investigations, Debt recovery | Performance of a contract, Legitimate interest. |
| Housing Benefit Department or Department for Work and Pensions | Legal obligation | Legal obligation |
| Board members involved in our complaints process | To scrutinise our services | Legitimate interest |
| A doctor, hospital, paramedic or health worker | Where you require medical attention and are unable to provide the information yourself | Consent, Social Protection, Laws, Vital interest |
| Our legal advisors, the courts and the police | Reducing ASB, fraud, prevention and detection of crime. | Legitimate interest Legal obligation |
| People or agencies who provide services to you or who work with us to provide services to you, such as your care/support provider | To deliver services | Legitimate interest Consent |
| The bodies involved with your care/support such as the relevant Local Authority or NHS departments and any alarm call centre | To deliver services | legal obligation Legitimate interest, Consent |
| 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 | Legal obligation | Legal obligation |
| Your next of kin, or nominated individual, in an emergency and a where you have requested this | When the information is requested to protect life | Consent |
| To another landlord or housing association where you are looking to move or exchange your property, where they request your details or a reference from us | When the information is requested | Consent, Legitimate Interest |
| 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 or where we have concerns about possible criminal activity or domestic violence | Safeguarding Prevention and detection of crime | Legal obligation, Legitimate interest |
| 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, providers of our information technology services or software | To enhance and deliver our services, maintaining records. | Legitimate interest |
| Companies who process your rent payment information | To enhance your credit score, To efficiently collect rental debt | Legitimate interest |
| Local authorities | To support their homelessness duty | Legal obligation, Legitimate interest |
International Transfers
Golding Homes will not transfer your information outside of the European Economic Area without adequate safeguards. Golding Homes does not transfer any personal data internationally, besides information transferred to SurveyMonkey and Mailchimp, which are both covered by the Privacy Shield.
If Golding Homes were to transfer any personal data internationally, this will be in line with our internal procedure and the terms in this privacy notice will be updated.
Keeping your information secure
We store personal information both electronically and in paper form.
We implement organisational and security policies, processes and technical security solutions to protect the personal information we hold from:
- Unauthorised access
- Improper use or disclosure
- Unauthorised modification
- Unlawful destruction or accidental loss
When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, support workers, solicitors) act on your behalf we will take steps to ensure that you have agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.
Employees and third parties who have access to, or are associated with, the processing of your personal information, must comply with our Policies and Procedures, to use and process your information ethically and lawfully, to maintain confidentiality and take all reasonable efforts to safeguard it.
Automated Decision Making and Profiling
We do not make any decisions about you using automated means. An automated decision is one that is made by a computer algorithm that has no human intervention, for example, an online credit card application is an automated decision made about you. If the situation does change, we will notify you in writing.
Golding Homes does carry out profiling with non-automated decisions being made. This involves the use of predictive analytics by an external company in order to help facilitate rent arrears collection and assist in the performance of the contract.
Marketing
We maintain a newsletter which we periodically send to tenants, containing useful news and information regarding social housing, Golding Homes and related services, to promote social, economic and environmental wellbeing under the Neighbourhood and Community Standard 2015, and for the effective communication of information for tenants under the Tenant Involvement and Empowerment Standard 2015 to all those who sign up to our services.
We also ask for your consent to market information using our standard consent forms for email communications that are of a direct marketing nature. Further direct marketing may be conducted by post or by telephone (provided you are not on the TPS) under our legitimate interests.
If you do not wish to receive marketing material, or you would like to edit your preferences, please contact us. Unsubscribe options will also be offered on all marketing emails.
Please note, opting out of marketing does not remove the ability for Golding Homes to contact you regarding general correspondence or delivering the tenancy management service.
Visiting our websites
When you visit one of our websites, we collect standard internet log information for statistical purposes.
- We use cookies to collect information in an anonymous way, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Please see our website’s Cookie Policy for further information.
- We do not make any attempt to identify visitors to our websites. We do not associate information gathered from our sites with personally identifying information from any source.
- When we collect personal information, for example via an online form, we will explain what we intend to do with it on the form
Our websites may contain links to various third-party websites. We are not responsible for the
content or privacy practices of any external websites that are linked from our sites.
Applying for a job
If you apply to work for Golding Homes, we will use your personal information to process your
application and to produce and monitor recruitment statistics. We will not take up references without
your prior permission. We will not share or disclose your information unless you have given us your
consent, or we are required to do so by law. Where we are required to carry out a Disclosure and
Barring Service (DBS) check we will comply with the law and your rights when carrying out these checks.
We retain personal information relating to unsuccessful applicants for no longer than 12 months,
for use in the event of an appeal. We produce statistical information to assist with recruitment
analysis.
If you are successful in your application for employment you will receive further information as
to what and how we process your information as an employee.
Leaseholders and Freeholders
Golding Homes also collects and processes information relating to leaseholders and freeholders
which relates to:
- Information about the sale/purchase/assignment of a lease or its extension or about the sale of a freehold;
- Information relevant to a lessee’s mortgage or re-mortgage application;
- Information relevant to service/repairs/other charges;
- Rent review information;
- Information in connection with managing your business lease/tenancy.
Further information is provided directly to Leaseholders and Freeholders relating to Privacy matters.
Contractors, suppliers and other third parties
Information collected and processed relates to basic contact details and any other information
they may share in routine correspondence with us.
General enquiries and other information received
Golding Homes may collect and retain information voluntarily sent by the Data Subject and not
caught by any other section within this policy.
This information will be processed, stored, retained and shared where relevant and appropriate to
do so for responding to or managing any general enquiries or other information received, volunteered
or sent to us by the data subject that is or may be connected to any of our activities.
This information will be processed in accordance with your rights and our obligations as detailed
under Data Protection law and the general principles contained within this policy as well as our
Data Protection Statements and Privacy Notices.
Changes
We will notify you of any material changes to this Privacy Policy via Golding Homes’ website.
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 to be informed | Individuals have the right to be informed about the collection and use of their personal data. | We will provide privacy notices (such as this privacy policy) where we collect your personal data. You can request a copy of this privacy policy if you wish. |
| Right of access | You have the right to obtain confirmation from Golding Homes as to whether personal data concerning you is being processed, and, where that is the case, access to that personal data. | Golding Homes 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 how we operate. We may redact information where exemptions apply and as permitted by Data Protection Laws. We will tell you what information has been redacted unless this jeopardises a criminal or other lawful investigation. |
| Right to rectification | You have the right to request Golding Homes to rectify inaccurate personal data concerning you. Considering 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 personal data which you disagree with being rectified. |
| Right to erasure (right to be forgotten) | You have the right (under certain circumstances, but not all) to request Golding Homes 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 must follow a legal obligation to delete. |
| Right to restriction of processing | You have the right (under certain circumstances, but not all) to request Golding Homes 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 request Golding Homes 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 request Golding Homes to transmit those data to another controller. | This right only applies to data collected by automated means. As Golding Homes does not currently undertake processing which is wholly automated, we do not see any circumstances in which we would have to comply with this right. For a copy of your personal data, please carry out a subject access request instead. |
| 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. | Withdrawing consent will not affect the legality of any processing carried where consent is given i.e. 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. If you would still like to receive marketing in one medium, please let us know. Golding Homes still reserves the right to contact you regarding important matters unrelated to marketing i.e. chasing rent arrears. |
| Rights in relation to automated decision making and profiling | Golding Homes does not perform any automated decision-making based on personal data that produces legal effects or similarly significantly affects you. | Golding Homes does not carry out any automated decision making based on profiling. Where profiling is carried out without automated decision making, we will update our privacy notices where necessary. |
If you wish to exercise any of these rights, please put your request in writing to the Customer
First Team at Golding Homes or contact us by email or telephone using the details at the bottom
of this page under the ‘Contacting Us section’. For more information about any of your rights,
please visit:
Legislative and regulatory requirements:
Golding Homes is a charitable, not-for-profit housing association registered under the Co-operative and
Community Benefits Societies Act 2014 and regulated by the Regulator of Social Housing.
Homes and Communities Agency No: LH4402
Registered Community Benefit Society 7628
Legislative
- General Data Protection Regulations 2016;
- Data Protection Act 2018;
- Privacy and Electronic Communication Regulations 2003; and not
- Golding Homes is not a scheduled body under the Freedom of Information Act and therefore does not have to respond to any requests under the Act.
Regulatory
Regulator of Social Housing Governance and Viability Standard (para 1.1): "Registered providers shall
ensure effective governance arrangements that… comply with all relevant law."
Contacting Us
Please contact us if you have any questions in relation with this notice or the information we hold about you:
by email: help@goldinghomes.org.uk
by phone: 0300 777 2600
by post: County Gate One, Staceys Road, Maidstone ME14 1ST
Right to Complain
If you feel that our handling of your personal data under this policy and/or your right to privacy
has been compromised, you should contact our Privacy Officer at our address above.
If you are not satisfied with our response you have the right to lodge a complaint with the
Supervisory Authority and the right to a judicial remedy. In the United Kingdom this is:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
Data Controller:
Golding Homes, County Gate One, Staceys St, Maidstone, Kent ME14 1ST
Introduction
Golding Homes is a ‘Data Controller’ under Data Protection Laws. This means we make decisions about how we process your personal information in the course of managing your relationship with us, how we use your information for our legitimate business needs, who we may share it with and why, how long we need it for and the technical and organisational measures we need to implement to safeguard your information and to protect your right to privacy, confidentiality and security of personal information.
We take your privacy seriously and are committed to protecting your information and using it fairly, lawfully and transparently. The purpose of this policy is to outline our approach to data protection, information security and how we protect your information under our control. The aim of the policy is to provide you with assurance that we will only use and share your information lawfully and within the requirements of Data Protection Laws.
The information we hold about you may vary depending on what services we are providing to you. Personal information will only be collected, created or otherwise obtained for specific, explicit and legitimate purposes and will not be used for any other incompatible purpose.
This Privacy Policy will provide you with information about how your personal data will be processed by Golding Homes.
Our Privacy Promise
Golding Homes promises:
- Never to sell your personal data.
- To be transparent about what we do with your personal data and to keep you informed when this changes
- To respond to any of your requests regarding your information in a timely and effective manner.
- To respect your rights as a data subject and to process your information lawfully, ethically and to maintain security of the information provided.
What information do we collect?
We collect information about you when you make an application with us for a tenancy, home purchase or shared ownership or a referral is made by you for one of our services. We may also collect information when you voluntarily complete customer surveys, provide feedback or where there is general correspondence. Further information may be collected during your tenancy or relationship with us.
The table below sets out what personal data we may process, our purpose for doing so, our lawful justification and how long we keep it for:
| What personal data we process | Our purpose for doing so | Our lawful justification | How long we keep it for |
|---|---|---|---|
| Details about you and your children, including name, date of birth, address, contact details, identification (including National Insurance number), documents provided to us, employment details | Allocating homes, managing our services, managing your tenancy and relationship with us, identifying you are who you say you are, meeting our obligations as a registered provider | Performance of a contract, Legitimate interest Legal obligation |
6 years from the end of your tenancy with us |
| Details about your home, household and your housing needs and tenancy agreement | Allocating homes, managing our services, managing your tenancy and relationship with us, providing repairs, meeting our obligations as a registered provider | Performance of a contract Legitimate interest | 6 years from the end of your tenancy with us |
| Your rent account and payment history | Managing your tenancy commitments | Performance of a contract | 6 years after the end of your tenancy |
| Welfare benefit referrals, Housing Benefit notifications, Universal Credit verifications, rent statements | Managing your tenancy commitments and relationship with us, meeting our obligations as a registered provider | Performance of a contract, Legal obligation Legitimate interest | 2 years |
| Details about your home when you apply to shared ownership | Allocating shared ownership homes, managing your relationship with us | Performance of a contract, Legitimate interest, Legal obligation | 6 years following the end of your tenancy |
| Right to Buy / Acquire information | To administer Right to Buy / Acquire applications | Legal obligation, legitimate interest | 10 years |
| Rent and service charge information | Allocating homes, managing our services, informing relevant local authority departments, managing your tenancy with us | Performance of a contract, legitimate interest | 6 years following the end of your tenancy |
| Financial information, including any credit checks, income details, bank details, housing benefit information | 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 departments 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 help with improving your credit score | Performance of a contract, Legal obligation, Legitimate interest Consent | At least 3 months |
| References received about you (e.g. from your employer or previous landlord) | Allocating homes, managing our services, administration | Legitimate interest | 3 months |
| Medical information, emergency contact details, next of kin or any advocate, Information about any accidents or incidents which involve you or your home. | To provide information to our staff to enable them to provide services to you to 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 such as any religious or cultural wishes To act in someone’s best interests such as 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 support you in your tenancy and meet our obligations as a registered provider | Consent, Social Protection Law Protecting Vital Interests in extreme circumstances. | 6 years following the end of the tenancy |
| Information about any complaints made by you or which relate to you | To handle any complaints, manage your tenancy | Legitimate Interest, Contract | 6 years following the end of your tenancy |
| The way in which you conduct your tenancy if you are in breach of your tenancy conditions | To respond to breach of your tenancy conditions | Contract, Legitimate interest | 6 years following the end of the tenancy |
| Information regarding your marketing preferences | To deliver marketing materials such as our newsletter or make note of your preferences | Consent Legitimate interest Legal obligation | Refreshed every two years |
| Any photographs taken of you or your property | Monitoring defects, assessing any health & safety risks, administering tenancies and security. | Consent Legitimate Interest | 6 years following the end of your tenancy |
| Any marketing materials/photos taken at events | To promote our services | Consent Legitimate interest | Refreshed after 2 years, otherwise deleted |
| Equality information | To ensure fair and equal access for all to our services; To help us put together statistics to give to our regulator or other government organisations | Legitimate interest Consent | 6 years following the end of your tenancy |
| Convictions, proceedings and criminal acts | To deliver our services, safeguarding, employee safety | Legal obligation, Employment law, Prevention and detection of crime | 6 years following the end of your tenancy |
| Call Recordings | To improve our services | Legitimate Interest | 60 days following recording |
| CCTV footage | For the prevention and detection of crime | Legitimate Interest | 28 days following recording Until it is no longer required to use in evidence for criminal or civil proceedings |
If we deem there to be a risk to our staff, we may place a flag over your tenancy. When we do so, we will inform you and ensure that these flags are regularly reviewed.
We may keep some of your information longer than the periods listed above. This will be to satisfy our legal obligations and maintain certain records where appropriate to do so under our legitimate interest.
We also maintain a Retention Schedule, detailing how long we keep all items of information at Golding Homes beyond those generally listed above. This is available to view on request.
Our Legitimate Interests
A legitimate interest means that we need to process information necessary for Golding’s business or commercial interests, to meet our obligations as a registered provider or to meet the lawful and legitimate interests of another organisation, for example the collection of unpaid debt or for crime prevention and detection purposes. When we rely on any legitimate interest, we will conduct a legitimate interest assessment to ensure that we take a balanced approach and have appropriate safeguards in line with your expectations. If we rely on any legitimate interest, we will tell you what that is.
Our legitimate interests include:
- Having appropriate security, for our offices and on our sites. This includes CCTV and identification photographs.
- Handling and investigating complaints.
- Keeping, maintaining and producing our records.
- Collecting and servicing unpaid debt.
- Recording threatening and unacceptable behaviour.
- Obtaining information from third parties.
- Official Communications.
- Keeping our records up to date, working out which of our products and services may interest you and telling you about them.
- Engaging with you to seek your feedback on improvements and changes to our products and services.
- Contacting you with matters regarding your tenancy with us
- Sharing your information with local utilities providers in the event of unpaid debts.
- Processing for business efficiency purposes and enabling services to be provided.
- Analyses for business insight, planning and future organisational service or development requirements.
- Working collaboratively with other associations to take a multi-agency approach to managing aggression, violence, crime prevention and detection.
How will we collect this information?
Information will be collected from you personally when you enter into an agreement / contract with us. This will be in the form of applications and any other forms which may be completed electronically or written to apply for one of our properties, to become a tenant, to manage your tenancy and relationship with us, in receiving or responding to communications from you or when requesting a repairs or support service from us.
It is possible that we will receive referrals containing your information from public bodies such as local councils where we have properties, but this should be done with your knowledge of why they are making the referral to our services. This information should be made available to you from the public body at the point of data collection and through their privacy notice.
We may generate further personal data regarding our tenants during the tenancy. This could be in the form of general correspondence, or this may need to be generated to satisfy our statutory obligations. An example of Golding Homes fulfilling its statutory obligations and potentially collecting personal data would be where photographs of properties are required for the purposes of monitoring defects or for assessing any health & safety risks.
Who will we share it 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, with other organisations for lawful and legitimate reasons. This include:
| Who we share your information with | The purpose for sharing it | Our justification for sharing |
|---|---|---|
| Companies which provide services or utilities to your home (such as gas, electricity or water suppliers) and the relevant Council Tax Department | Payment for these services Debt recovery Fraud investigations | Legitimate interest, Legal obligation. |
| People who provide services on our behalf, such as a managing agent, contractors carrying out repairs | Fulfilling the tenancy agreement, Repairs, Defect rectification | Legitimate interest, Contract, Health and Safety, Legislation |
| A credit checking agency, your bank and mortgage company or other financial institutions and (where necessary) a debt collection and/or tracing agency | Allocating and administering properties and tenancy agreements, Fraud investigations, Debt recovery | Performance of a contract, Legitimate interest. |
| Housing Benefit Department or Department for Work and Pensions | Legal obligation | Legal obligation |
| Board members involved in our complaints process | To scrutinise our services | Legitimate interest |
| A doctor, hospital, paramedic or health worker | Where you require medical attention and are unable to provide the information yourself | Consent, Social Protection, Laws, Vital interest |
| Our legal advisors, the courts and the police | Reducing ASB, fraud, prevention and detection of crime. | Legitimate interest Legal obligation |
| People or agencies who provide services to you or who work with us to provide services to you, such as your care/support provider | To deliver services | Legitimate interest Consent |
| The bodies involved with your care/support such as the relevant Local Authority or NHS departments and any alarm call centre | To deliver services | legal obligation Legitimate interest, Consent |
| 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 | Legal obligation | Legal obligation |
| Your next of kin, or nominated individual, in an emergency and a where you have requested this | When the information is requested to protect life | Consent |
| To another landlord or housing association where you are looking to move or exchange your property, where they request your details or a reference from us | When the information is requested | Consent, Legitimate Interest |
| 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 or where we have concerns about possible criminal activity or domestic violence | Safeguarding Prevention and detection of crime | Legal obligation, Legitimate interest |
| 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, providers of our information technology services or software | To enhance and deliver our services, maintaining records. | Legitimate interest |
| Companies who process your rent payment information | To enhance your credit score, To efficiently collect rental debt | Legitimate interest |
| Local authorities | To support their homelessness duty | Legal obligation, Legitimate interest |
International Transfers
Golding Homes will not transfer your information outside of the European Economic Area without adequate safeguards. Golding Homes does not transfer any personal data internationally, besides information transferred to SurveyMonkey and Mailchimp, which are both covered by the Privacy Shield.
If Golding Homes were to transfer any personal data internationally, this will be in line with our internal procedure and the terms in this privacy notice will be updated.
Keeping your information secure
We store personal information both electronically and in paper form.
We implement organisational and security policies, processes and technical security solutions to protect the personal information we hold from:
- Unauthorised access
- Improper use or disclosure
- Unauthorised modification
- Unlawful destruction or accidental loss
When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, support workers, solicitors) act on your behalf we will take steps to ensure that you have agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.
Employees and third parties who have access to, or are associated with, the processing of your personal information, must comply with our Policies and Procedures, to use and process your information ethically and lawfully, to maintain confidentiality and take all reasonable efforts to safeguard it.
Automated Decision Making and Profiling
We do not make any decisions about you using automated means. An automated decision is one that is made by a computer algorithm that has no human intervention, for example, an online credit card application is an automated decision made about you. If the situation does change, we will notify you in writing.
Golding Homes does carry out profiling with non-automated decisions being made. This involves the use of predictive analytics by an external company in order to help facilitate rent arrears collection and assist in the performance of the contract.
Marketing
We maintain a newsletter which we periodically send to tenants, containing useful news and information regarding social housing, Golding Homes and related services, to promote social, economic and environmental wellbeing under the Neighbourhood and Community Standard 2015, and for the effective communication of information for tenants under the Tenant Involvement and Empowerment Standard 2015 to all those who sign up to our services.
We also ask for your consent to market information using our standard consent forms for email communications that are of a direct marketing nature. Further direct marketing may be conducted by post or by telephone (provided you are not on the TPS) under our legitimate interests.
If you do not wish to receive marketing material, or you would like to edit your preferences, please contact us. Unsubscribe options will also be offered on all marketing emails.
Please note, opting out of marketing does not remove the ability for Golding Homes to contact you regarding general correspondence or delivering the tenancy management service.
Visiting our websites
When you visit one of our websites, we collect standard internet log information for statistical purposes.
- We use cookies to collect information in an anonymous way, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Please see our website’s Cookie Policy for further information.
- We do not make any attempt to identify visitors to our websites. We do not associate information gathered from our sites with personally identifying information from any source.
- When we collect personal information, for example via an online form, we will explain what we intend to do with it on the form
Our websites may contain links to various third-party websites. We are not responsible for the content or privacy practices of any external websites that are linked from our sites.
Applying for a job
If you apply to work for Golding Homes, we will use your personal information to process your application and to produce and monitor recruitment statistics. We will not take up references without your prior permission. We will not share or disclose your information unless you have given us your consent, or we are required to do so by law. Where we are required to carry out a Disclosure and Barring Service (DBS) check we will comply with the law and your rights when carrying out these checks.
We retain personal information relating to unsuccessful applicants for no longer than 12 months, for use in the event of an appeal. We produce statistical information to assist with recruitment analysis.
If you are successful in your application for employment you will receive further information as to what and how we process your information as an employee.
Leaseholders and Freeholders
Golding Homes also collects and processes information relating to leaseholders and freeholders which relates to:
- Information about the sale/purchase/assignment of a lease or its extension or about the sale of a freehold;
- Information relevant to a lessee’s mortgage or re-mortgage application;
- Information relevant to service/repairs/other charges;
- Rent review information;
- Information in connection with managing your business lease/tenancy.
Further information is provided directly to Leaseholders and Freeholders relating to Privacy matters.
Contractors, suppliers and other third parties
Information collected and processed relates to basic contact details and any other information they may share in routine correspondence with us.
General enquiries and other information received
Golding Homes may collect and retain information voluntarily sent by the Data Subject and not caught by any other section within this policy.
This information will be processed, stored, retained and shared where relevant and appropriate to do so for responding to or managing any general enquiries or other information received, volunteered or sent to us by the data subject that is or may be connected to any of our activities. This information will be processed in accordance with your rights and our obligations as detailed under Data Protection law and the general principles contained within this policy as well as our Data Protection Statements and Privacy Notices.
Changes
We will notify you of any material changes to this Privacy Policy via Golding Homes’ website.
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 to be informed | Individuals have the right to be informed about the collection and use of their personal data. | We will provide privacy notices (such as this privacy policy) where we collect your personal data. You can request a copy of this privacy policy if you wish. |
| Right of access | You have the right to obtain confirmation from Golding Homes as to whether personal data concerning you is being processed, and, where that is the case, access to that personal data. | Golding Homes 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 how we operate. We may redact information where exemptions apply and as permitted by Data Protection Laws. We will tell you what information has been redacted unless this jeopardises a criminal or other lawful investigation. |
| Right to rectification | You have the right to request Golding Homes to rectify inaccurate personal data concerning you. Considering 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 personal data which you disagree with being rectified. |
| Right to erasure (right to be forgotten) | You have the right (under certain circumstances, but not all) to request Golding Homes 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 must follow a legal obligation to delete. |
| Right to restriction of processing | You have the right (under certain circumstances, but not all) to request Golding Homes 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 request Golding Homes 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 request Golding Homes to transmit those data to another controller. | This right only applies to data collected by automated means. As Golding Homes does not currently undertake processing which is wholly automated, we do not see any circumstances in which we would have to comply with this right. For a copy of your personal data, please carry out a subject access request instead. |
| 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. | Withdrawing consent will not affect the legality of any processing carried where consent is given i.e. 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. If you would still like to receive marketing in one medium, please let us know. Golding Homes still reserves the right to contact you regarding important matters unrelated to marketing i.e. chasing rent arrears. |
| Rights in relation to automated decision making and profiling | Golding Homes does not perform any automated decision-making based on personal data that produces legal effects or similarly significantly affects you. | Golding Homes does not carry out any automated decision making based on profiling. Where profiling is carried out without automated decision making, we will update our privacy notices where necessary. |
If you wish to exercise any of these rights, please put your request in writing to the Customer First Team at Golding Homes or contact us by email or telephone using the details at the bottom of this page under the ‘Contacting Us section’. For more information about any of your rights, please visit:
Legislative and regulatory requirements:
Golding Homes is a charitable, not-for-profit housing association registered under the Co-operative and Community Benefits Societies Act 2014 and regulated by the Regulator of Social Housing.
Homes and Communities Agency No: LH4402
Registered Community Benefit Society 7628
Legislative
- General Data Protection Regulations 2016;
- Data Protection Act 2018;
- Privacy and Electronic Communication Regulations 2003; and not
- Golding Homes is not a scheduled body under the Freedom of Information Act and therefore does not have to respond to any requests under the Act.
Regulatory
Regulator of Social Housing Governance and Viability Standard (para 1.1): "Registered providers shall ensure effective governance arrangements that… comply with all relevant law."
Contacting Us
Please contact us if you have any questions in relation with this notice or the information we hold about you:
by email: help@goldinghomes.org.uk
by phone: 0300 777 2600
by post: County Gate One, Staceys Road, Maidstone ME14 1ST
Right to Complain
If you feel that our handling of your personal data under this policy and/or your right to privacy has been compromised, you should contact our Privacy Officer at our address above.
If you are not satisfied with our response you have the right to lodge a complaint with the Supervisory Authority and the right to a judicial remedy. In the United Kingdom this is:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire