Privacy Notice

Privacy notice

Sutton Housing Partnership needs to process personal data in order to deliver the following services to you

Managing your tenancy and the London Borough of Sutton property to which it relates
Monitoring compliance with the terms of your tenancy agreement
Delivering support for special needs to you or any member of your household within an agreed support plan
Conducting surveys in order to monitor and improve our services
Informing you of our services and / or performance

We are committed to treating your information securely, with respect and in line with data protection law.

This privacy notice tells you what to expect when Sutton Housing Partnership processes your personal information. It applies to information about housing applicants, residents and other service users. This is the main privacy notice for Sutton Housing Partnership and Sutton Connect. Please read this notice in full to understand what information we hold about you, how we may use it and your rights in relation to your personal data.

This privacy notice is kept under regular review and we will place any updates on our website. If you have any concerns or queries about this privacy policy or to receive a hard copy of our privacy notice, please email our Data Governance and Protection Officer or write to us at Sutton Gate, 1 Carshalton Road, Sutton, SM1 4LE.

Information Commissioner's Office

You can also contact the Information Commissioner for independent information and advice about data protection, privacy and data sharing issues.

Phone: 0303 123 1113

Email: casework@ico.org.uk

Website: www.ico.org.uk

Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Information we collect

We will only collect personal information when we need this. The type of information we need from you will vary depending on our relationship with you. When we ask you for information, we will make it clear why we need it. We will also make it clear when you do not have to provide us with information and any consequences of not providing this.

Most information we hold will be collected from you but we may also obtain this from third parties such as the local authority or a previous landlord.

We collect information from you (as applicable):

To complete tenancy sign-ups
- We will need your name and contact details (including telephone numbers, email addresses and details of anyone you may choose to represent you) for use across the organisation and by our contractors only so far as it is necessary for the provision of services to [the resident/you] OR [for the purposes identified in this policy or otherwise agreed with you].
- We will collect detailed personal information about you and other household members*, including age, sex, date of birth, ethnicity, income, National Insurance number, income and benefits details, employment status, gender identity, relationship status, any disabilities, any communication and accessibility requirements, religion, sexuality, nationality, caring responsibilities, access to financial services such as banks and credit unions, bank details, benefits, council tax, medical information, details of any unspent criminal convictions.

* When you provide information about household members we assume that you do so with their full knowledge and consent.

Provision of some of the information requested by us is part of a ‘contractual requirement’. Without this information, we will be unable to accept an application for services. For example, we cannot see if you are eligible for a tenancy without being able to verify your identity.

Where enquiries relate to household members, it is in our legitimate interests to know who will be living in our premises, to check that accommodation offered is adequate for current and near future needs of the household, to check that household members’ needs are being met and to ensure that the local community will have quiet enjoyment of their homes.

To manage your tenancy or lease:
- Up to date contact details (telephone number and email address) so we can reach you when we need to discuss issues pertaining to your tenancy or lease, e.g. income collection, essential servicing, access for maintenance and improvements, if we need to arrange a home visit or to contact you in the event of an emergency or to enforce the terms of your tenancy/lease.
- We will also use your contact information to tell you about changes to Sutton Housing Partnership, for example our organisational structure and governance arrangements, and to resolve or investigate complaints or housing management issues such as antisocial behaviour.
- Details of any change in circumstances (e.g. if you have a medical need that means your housing requirements need to be re-assessed we would ask you for supporting information about your change in health needs) or to effect any changes to your tenancy (e.g. if you want to change your name on our records we’ll ask you for a copy of your marriage or deed poll certificate).
- We will hold records of all our contact with you, your contact with us, and any contact from third parties representing you or about you. This may include call recordings.
- Financial records about the amount of money you have paid us, any amount(s) outstanding and associated recovery action. Depending on your method of payment, we may hold your bank account details.
- Details relating to the repair, maintenance and servicing requirements of your home (although this information will not necessarily constitute your personal data).

Provision of the information is a ‘contractual requirement’. Without this information, we may be unable to manage your services. For example, we cannot consult with you about changes to your service if we do not hold your contact details.

Where enquiries relate to household members, it is in our legitimate interests to know who is living in the premises, to check that accommodation remains adequate for current and near future needs of the household, to check that household members’ needs are being met and to ensure that the local community has quiet enjoyment of their homes.

To meet your needs in our service delivery
To ensure our services are accessible, that we take account of any support needs in our dealings with you and to improve our communications with you. For example, if you are involved with a carer, social worker or other advocate, if there are considerations we need to apply when we visit you at home, if you need large print or translated text.
When profiling you for services and to target our resources.

Where processing information about you or your household members, we may have a legal or contractual obligation to process this information for example to provide inclusive services.

It is also in our legitimate interests to ensure that service delivery meets the needs of our service user and their household.

To prevent fraud and illegal sub-letting and to confirm eligibility for housing - We will ask for proof of ID e.g. Tenancy Sign-ups or subsequent Tenancy Audits, when the housing composition changes or a reasonable period of time has passed (this applies to all household members over the age of 18).

Processing for the purpose of fraud prevention is required in order to meet our legal obligations. Therefore if we are unable to verify your identity we may not be able to provide services to you.

To manage the legal process if you apply to buy your home

Provision of information requested for this purpose is required in preparation for entering into ‘contractual relations’. Without this information, we will be unable to manage this legal process.

Where the processing of information concerns household members, it is in our legitimate interests to do this. e.g. to ensure we understand all legal effects that a process may have.

When you engage with our additional guidance, advice and support services - For example if we support you to improve your financial circumstances, we may hold detailed information about your household income and expenditure.
If you ask Sutton Connect to provide support requirements we may hold detailed information about your needs and where relevant, records of payments for the services provided to you.

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.

Where processing also concerns household members, it is in our legitimate interests to ensure that we are meeting the needs and expectations of all service users.

To understand how we’re performing - We undertake call recordings for training and quality monitoring purposes.
We may use your contact details to carry out market research and customer satisfaction surveys to help us to monitor our performance and to improve our services to our customers.
To segment customers to help target our resources and prioritise services.
In managing and analysing complaints.
For statistical analysis.

It is in our legitimate interests to understand how we are performing so we can meet our purpose, vision and responsibilities.

There may also be a legal obligation for us to process the information or to demonstrate that we are fulfilling our obligations, for example around anti-discrimination laws.

See our table of information we collect and legal basis

Special categories of personal data

As well as personal information (such as your name, address and date of birth) we may collect sensitive personal information (also known as special categories of data) of which may include:

Racial or ethnic origin.
Religious beliefs.
Sexual orientation.

We use this data to ensure services are delivered appropriately and to monitor equality, diversity and inclusion.

Where you provide explicit consent for us to process sensitive personal information, you have the right to withdraw this consent at any time.

How we protect your data

We will apply appropriate technical and organisational measures to ensure your personal information is secure.

When we need to share personal data with our contractors and third party suppliers, our relationships are governed by our contracts with them which include data processing and confidentiality protocols.

To help us ensure confidentiality of your personal information we will ask you (and any of your representatives) security questions to confirm your identity when you contact us. We will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so or where we have received a clear verbal instruction from you (as a one-off circumstance).

We use G Suite and Google Cloud Platform to provide our services. This means that your information may be stored and processed on servers outside of the European Economic Area. Google has achieved internally accepted independent security standards for Information Security Management, Cloud Security and Cloud Privacy and has certification under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. For more information, visit Google’s website.

Who we share your information with

Sometimes we need to share personal information we hold about you with other organisations that we work with or who provide services on our behalf. When sharing information we will comply with all aspects of data protection law. Where the information is of a sensitive nature, for example about your health, we will generally obtain explicit consent from you prior to sharing this information, unless we are required or permitted to share this by law.

Where ‘sharing’ is in our ‘legitimate business interests’ or yours or others ‘vital interests’, we may share your information without seeking your consent first. This may be with:

Our contractors to facilitate repairs, maintenance or improvement works.
Debt and money management advisors.
Local authority teams such as social services, environmental health and benefit agencies.
Utility companies (and their representatives) and Council Tax Departments to ensure billing details are correct.
Third parties providing services on our behalf. For example a research company carrying out a customer satisfaction survey, or a debt collection agency pursuing former tenant arrears.
Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative.
Police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime, the apprehension of offenders or the collection of tax or duty.
Other statutory organisations e.g. social services and health authorities as necessary for exercising statutory functions.

We may also share information when required by law for example where ordered by the Court or to protect an individual from immediate harm.

Third party companies we share information with

Contacting you and promoting our services

We will routinely use your contact details to send you information and communicate with you about your tenancy/lease/service. We will contact you based on your preferred method of contact. However, we will use all means of contact available should we need to contact you in the event of an emergency or to enforce the terms of your tenancy/lease.

We would also like to keep you updated with information about accessing training and employment, financial guidance, energy efficiency and digital support. It’s a legitimate business interest for us to send you postal communications (from time to time) which may comprise information about all these areas of our work.

You can object to receiving this type of content from us in the post or through electronic communications. You can change your mind at any time. Please just contact us or follow the ‘unsubscribe’ instructions that will be available on all of our promotional publications. Sutton Housing Partnership will never sell your personal data to 3rd party organisations for marketing purposes.

How long will you keep my data

Sutton Housing Partnership only holds records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us.

We have a document retention schedule which sets out how long we keep different types of information for. Please Contact us if you would like any more information

Your rights around your data

Sutton Housing Partnership is committed to upholding your rights in respect of your personal data. To discuss or exercise any of the following data rights please contact our Data Governance & Protection Officer on foi@suttonhousingpartnership.org.uk or write to us at Sutton Gate, 1 Carshalton Road, Sutton, SM1 4LE.

The right to be informed

Through our privacy notice, we will be open and transparent about how and why we use your personal information.

The right of access

You have a right to ask us what personal information we hold about you and to request a copy of your information. This is known as a ‘subject access request’. Find out more about subject access requests here or email foi@suttonhousingpartnership.org.uk

The right to rectification

You can ask us to rectify your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by keeping us informed if your details change.

The right to be forgotten

In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for its continued processing. This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data. Our response will also be guided by the provisions of our retention schedule.

The right to restrict processing

In some circumstances you can ask us to restrict processing, for example

If you disagree with the accuracy of personal data.
If we’re processing your data on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate grounds override those of yours.

The right to data portability

If the situation arises where it would be helpful for you to move, copy or transfer personal data we hold about you, across different services, you may be able to ask us to do this. Please contact us to discuss.

The right to object

You can tell us if you object to our processing of your personal data:

Based on legitimate interests.
For the purpose of promotional publications.

The right in relation to automated decision making and profiling

In some circumstances (e.g. if there is no contract) you can ask us not to subject you to a decision based solely on automated processing, including profiling, which produces legal effects concerning you.

The right to lodge a complaint with Information Commissioner’s Office (ICO)

You have the right to lodge a complaint to ICO if you consider the processing of your personal data infringes the EU General Data Protection Regulation (GDPR).