Privacy Statement – Customers and Service Users
This privacy statement explains how we collect, use and share your personal information. It applies to information about housing applications, tenants, residents, occupiers of our serviced office spaces and any other customers including shareholders.
Keeping your personal information safe and secure is important to us and this statement should help you understand what kind of personal information we may hold about you, why we need and process this information and the legal basis for the processing (‘processing’ can include just keeping your data).
This statement applies to personal data held by Unity Housing Association Limited and Unity Property Services Limited, who are each known as Data Controllers.
How we collect your information
We collect most of our information directly from you. This happens when you first make an application for housing, request a service from us, complete one of our forms, contact us or respond to a survey. We may collect information when you use our social media facilities, access our website or when tenants use our self-service portal “MyUnity”.
We also receive information from other organisations where this is relevant to the management of our tenancies, the services that we provide as a social landlord and our serviced office spaces. This includes:
• Our contractors, agents or consultants – when they deliver services on our behalf
• Local councils and central government departments – for information about your benefits, immigration status and fraud prevention
• Previous landlords and credit referencing agencies – for information about your previous tenancies, rental history and credit status
• Police – for information on criminal activities
• Health and social care providers – for information about health, care and support needs
• Councillors, MPS or other representatives – when they are acting on your behalf
• Other residents or service users – when receiving information relating to a complaint
Information we may collect about you
• Name, photographic proof of your identity, age, date of birth
Detailed personal information
• Ethnicity, income, National Insurance number, private expenditure data, employment status, gender, gender identity, relationship status, any disabilities, religion, sexuality, nationality, caring responsibilities, access to financial services such as banks and credit unions, bank details, benefits and VAT registration numbers
• Your contact details, address, phone numbers, email contacts and details of those who you want us to communicate with on your behalf, how you prefer us to contact you, emergency contact details, whether you have any literacy problems, your ability to speak English and language preferences, requirements for different communication formats, your preferences for getting involved and the service areas that are of most interest to you
• Medical information so that we can better understand your requirements, preferences or supports needs
How we use your personal information and the legal basis for processing
In a nutshell we collect personal information because it is needed by us as a social landlord to deliver services to applicants, residents, customers of our service office spaces, service users and any other customers including shareholders. In most cases the legal basis for processing your personal data is that it is needed to comply with contractual or legal obligations. It could also be that processing your personal data is in our legitimate interests and necessary for us to be an effective social landlord who provides high quality services to our customers. The following are the main examples of how we use your personal information.
To assess your housing application and manage our contract with you
We process personal information we hold about you to assess your housing application or to manage your tenancy or other contract with us. We collect and process your information because you have asked us to assess your suitability and this is an essential step towards entering into a tenancy agreement. You can’t opt out of providing this information if you want us to process your housing application or request for a service.
We also consider that we have a legitimate interest to use your personal information to ensure that:
• Our services and properties meet the needs of our customers;
• We can contact applicants, residents, customers of our serviced office spaces in the event of emergencies or to carry out repairs or improvements;
• We prevent and manage outstanding debt resulting from unpaid rent and charges
• We guard against fraud and illegal subletting
• We are not held responsible for charges for which you are liable such as utility bills
• We remain commercially viable and make the most efficient use of our resources
To promote community safety and safeguard individuals
We process personal information relating to anti-social behaviour, criminal activity and convictions to ensure that we promote a safe and secure environment. This may include images included in CCTV recordings, photographs or audio recordings. We process personal information in these circumstances because it is in our legitimate interests to do so and to prevent and detect unlawful acts. We may also need to process information to meet our legal obligations, because there is a substantial public interest, or it is in the vital interests of a person.
To stay in touch with you
We use your contact details to communicate with customers about their property or serviced office space, other services, meet our business objectives, encourage social inclusion and help build communities. This includes:
• repairs and maintenance
• rent collection
• complaints and housing management issues
• responding to emergencies
• to enforce the terms of your tenancy or lease
• considering licence renewals for serviced office spaces
• inviting shareholders and other customers to our annual general meeting
We may pass on your details to contractors that provide services on our behalf, so that they can contact you to deliver these services. We do this because it is necessary in the performance of a contract. It is not possible to opt out of this type of data processing. Where we do not have the appropriate contact details for you, we may try and source these externally from other third parties or public sources of information.
We also use your contact details to keep you updated about Unity events or other services which do not form part of our contractual landlord service, but which may be of interest to you. This includes our newsletter and letting you know about services that we or our partners may provide. It is in our legitimate interests to use your contact details in this way.
To involve you
We want to understand our residents’ and service user’s experiences and views so that they can effectively influence and contribute to debates on future strategies.
We’re constantly working to improve our services. One of the ways we do this is by listening to our residents and service users and asking for feedback and undertaking surveys. These surveys may be carried out by contractors who specialise in customer feedback. In such cases, we pass on your contact details to them so you that they can contact you and ask about our performance. It is in our legitimate interest to use your contact details this way, however you do not have to take part in our surveys but if you don’t you are missing out on the opportunity to shape and influence our services.
To provide appropriate properties and services
We process personal information that may relate to your health and social care. We do this to:
• help us make any reasonable changes to our properties and services
• ensure our properties are fit for purpose and accessible
• protecting vulnerable individuals in our communities
We use this information to meet our legal and regulatory obligations, for example, the Equality Act 2010, and because there is a legitimate or substantial public interest for us to do so.
To ensure equality, diversity and inclusion in our services
We may ask you to provide us with your diversity data (ethnicity, religion, disability, sexual orientation). This information is not used to inform any decisions we make about you individually. It is gathered for statistical purposes to help us understand who is living in our communities and using our services. It helps us to ensure fairness and equality in the services we provide and allows us to fulfil our legal and regulatory obligations. You do not have to provide this information but it helps us to plan and design better services if you do.
We use some of your personal data to create a profile of you so that we can identify relevant services that might be of interest or helpful to you. For example, if information suggests that you might be having some difficulties with managing your finances, or we think you might encounter difficulties in the future, we can direct you to relevant agencies. Alternatively, if our information suggests that you might be vulnerable because of age, or ill health, we may tailor our services to your needs.
We sometimes use profiling information to contact you about our community programmes that we think you might be interested in. We rely on our legitimate interests to process information for these purposes.
To support research
We may use your personal data to carry out internal research and analysis. We do this to develop and improve our services and to help us understand trends within the social housing sector. We process information based on our legitimate interests for these purposes.
Sharing your information
We sometimes need to allow our contractors or agents to process personal information we hold about you. This includes repairs and maintenance, gas servicing and debt collection. We only share information which is necessary for them to carry out the service they have been contracted to provide. All our contractors operate under the terms and conditions of a legally enforceable contract and will not use your information for anything other than carrying out a service on behalf of Unity. We may also share information with partners because it is in our legitimate interests.
We share information about social housing lettings data with the government. It is a regulatory requirement for all registered providers to supply this data. The data we share includes information on lettings, type of tenancy, rents and charges, demographic information about tenants (including special category data and criminal convictions) and financial information. The data does not include names or addresses but does include a unique property reference and a full postcode.
This information is used for research and statistical purposes to allow the government to exercise their role in providing adequate social housing. The information cannot be used for any other purposes, such as making decisions in relation to specific individuals.
We share this information because it is necessary for the performance of a task carried out in the public interest and/or for reasons of substantial public interest. Individuals are not able to opt out of this process.
Other organisations we may share your information with include:
• Local councils and government departments (including the Ministry of Housing, Communities and Local Government)
• Health and care services
• Police and other law enforcement agencies
• Utility companies
• Social Housing Regulator
• MPs and Councillors acting on your behalf
In some cases, we may need to share your information with these or other organisations because the law requires us to, it is in our legitimate interests, it is in the public interest or to protect the vital interests of a person.
Consumer credit agencies
We may share some of your personal data with a consumer credit reporting agency. This is to help us assess your application for housing, manage your tenancy or contract with us, prevent and detect fraud and illegal subletting and to manage our collection of rent and recovery of rent arrears. We may also receive information about you from a consumer credit reporting agency for the same purposes. We collect and process your information in these circumstances because it is needed in the performance of a contract or our legitimate interests.
We do not usually gather information directly from children as part of our services. 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.
Recording telephone calls
We may record your telephone calls to Unity for training and monitoring purposes and to make sure we’re delivering a good service. We process data in this way because it is in our legitimate interests to do so.
If you visit our website, we collect your Internet Protocol address. Unity logs this information for internal review purposes. For example, this information helps us determine how well our services are working so we can continually improve the quality of our website. The log information is also important for security, audit and quality improvement.
Keeping your personal information
How long we keep your personal data for can depend on the type of data it is. We will never keep your information for any longer than is necessary. We will delete information as soon as we no longer have a valid reason to hold it. We will keep information on our tenancy files and other occupancy agreements for up to six years after the contract comes to an end. Retention periods for all personal data is set out in our Privacy and Data Protection Policy which is available by contacting us.
Transfers outside the UK
Very occasionally, we may need to transfer your personal data outside the European Economic Area (EEA) to our contractors or agents. This could happen if we use an IT service provider whose servers are situated outside of the European Union. If we do this we will ensure that we only contract with organisations that have appropriate measures in place to safeguard the security of your personal data and comply with the relevant national standards.
Your privacy rights
You have rights as an individual which you can exercise in relation to the information we hold about you. These rights are explained below.
Transparency – You have the right to be informed about how we are using your data. If you think we are doing something with your information that we have not told you about in this Privacy Statement, you can object to this.
Access – You have the right to ask us what personal information we hold about you, and to request a copy, free of charge. If we consider that the request is manifestly unfounded, excessive, or repetitive, we can charge a reasonable fee. This fee will be based on the administrative cost of providing the information.
Objection – You can object to the processing of your personal data. You should note that this right does not apply in all circumstances, for example, where we are processing information because it is necessary in the performance of a contract.
Withdrawal of consent – If we are processing your data based on your consent, you can withdraw this consent at any time. Where this is the case we may no longer be able to provide the relevant service to you.
Rectification – If you think that the personal data we hold about you is inaccurate or incomplete, you have a right to request that it be rectified.
Erasure – You can ask us to delete your personal data where it is no longer needed by us, where you have withdrawn consent (if we process based on consent), or where we have no lawful basis for keeping it.
Restriction – You can ask us to restrict the personal data we use about you where you have asked for it to be erased or where you have objected to our use of it.
Data portability – You can ask us to provide you, or a third party (if possible), with some of the personal data we hold about you in a structured, commonly used, electronic form, so that it can be easily transferred.
Further information and complaints
If you are not satisfied with the way that we have dealt with your personal data or require further information or want to request a copy of the data we hold about you, see the Contact Us section of our website for details of how to get in touch with us. Alternatively you can write to our Data Protection Officer at Unity Housing Association Limited, 113-117 Chapeltown Road, Leeds, LS7 3HY.
The Information Commissioner (ICO) is also a source of further information about your data protection rights. You have the right to complain to the ICO if you thank that we have not handled your data correctly. You can contact the ICO on-line at www.ico.org.uk or write to The Information Commissioners’ Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113.
Changes to this Privacy Statement
We keep our privacy statement under regular review and will place any updates on our website.
Updated 6 August 2020