- What do we mean by personal information?
- What personal information do we collect about you, where from and why?
- Why are we allowed to use your personal information?
- What about our responsibility to protect your personal information?
- Who do we share your personal information with and why?
- How long do we keep hold of your information?
- What are your rights?
- What if you're unhappy with how we keep your information?
- How often do we change this policy?
- If you have a question or want to know more?
We are committed to respecting your privacy and protecting your personal information. We promise to respect all the personal information you share with us and keep it safe and secure, as well as any personal information we receive about you from other organisations.
We will not do anything with your personal information that you would not reasonably expect us to do.
This policy explains what we do with your personal information and what your rights are, that way you know what we do with it and you stay in control of it.
The law gives you the legal right to see personal information we hold about you and, where it is possible, to provide it to you in a way that suits you.
It says that we must:
- only use your personal information for lawful reasons
- explain to you how we will use your personal information and only use it for the reasons we have told you about
- only collect personal information that we need
- only hold your personal information as long it is necessary to do so
- make sure any personal information we keep is accurate, held safely and securely
If we need your consent to handle your personal information, you can contact us at any time to ask us to stop using it.
We receive personal information about you in two main ways:
1. you give us most of the personal information we hold when you fill in forms before you become a tenant and during your tenancy
2. other organisations that work with you, such as Manchester City Council or the Department of Work and Pensions, sometimes pass on personal information to us.
How do we use this personal information?
If you apply for a home, we use the personal information you give us about your rehousing needs to decide what kind of home you need and how quickly you need to move there. When you become a tenant, we use your personal information to help us manage your home and the surrounding neighbourhood, such as helping us to decide the kind of support and services you need.
If you want to know more about our policy you can read the sections below:
Personal information, also called personal data, is information about an identifiable individual (also called a ‘data subject’). For example:
a person's name, address, phone number or email address. It can include things like a photograph, a video or audio recording of a person, a national insurance number, bank account details, education or employment history or details about the conduct of a current or a previous tenancy.
It also includes all kinds of sensitive information (known as ‘special category’ data), for example, it might include personal information about:
- ethnic origin
- biometrics (where used for ID purposes)
- sex life
- sexual orientation
We’ll only collect and request personal information that is relevant for delivering our services and meeting our legal obligations as a landlord. You can refuse to give us personal information but if you do it might mean we’re unable to provide you with certain services.
We may ask for your personal details from organisations’ you’ve dealt with in the past, like previous landlords, support workers or other professionals who know you. This is one of the few occasions where we would need your consent to do so.
When you use our website we store and use your personal information to better communicate with you and to provide online services to you that are relevant to your needs and to understand how people interact with our website, such as how you use your online account, web forms or web chat service.
When you contact us, you might need to give us personal information about yourself so we can verify your identify, prevent fraud and provide you with a service best suited to your needs and preferences. This personal information is kept by Northwards Housing and if necessary only relevant details are shared with our suppliers or contractors when they deliver a service to you on our behalf.
When you make an application to us and we provide you with a rehousing service or a tenancy, we use the personal information you give to us to provide a service to you and to meet our responsibilities set out in the tenancy agreement. During the lifetime of your contact with us we might also use the following personal information:
- sensitive information; for example, about your ethnic origin, health or support needs to meet our legal obligations and ensure we provide you with a fair and equal service.
- financial information, such as your income and expenditure, so we can deal with your rent payments and, if necessary, provide you with money, energy or debt advice to help you maximise your income.
- survey responses to help us review how satisfied different people are with the range of services we provide and to help us to improve our performance.
- information to plan repairs and improvements to your home and minimise any inconvenience and disruption to you and your neighbours
- information about your current or previous conduct to prevent crime, anti-social behaviour, meet our legal responsibilities and protect the health and safety of our staff and the wider community.
- recordings of telephone conversations with our customer service centre to help us monitor and provide a consistent service to you.
- CCTV in our offices and specific locations (which are clearly signposted) to protect the safety and security of our staff and customers and to prevent, detect and investigate crime and anti-social behavior.
- details about other people living in your household, including children, so we can review your future needs and decide whether you are entitled to certain services
- details of any friends, relatives or carers you trust who contact us on your behalf and with your consent.
- images of you to highlight news stories or marketing campaigns, as long as we have your explicit consent
We have a public duty to deliver services to council tenants on behalf of Manchester City Council. These are set out in law and in a legal management agreement between Northwards Housing and the Council. To do this well and to meet the responsibilities set out in your tenancy agreement we need to collect your personal information and use it to provide services to you.
We also need to meet the council’s legal responsibilities to assess people who may have a need for housing.
To be able to provide a comprehensive rent and money advice service and where we have a valid and genuine reason for doing so (called ‘Legitimate interests’) we also access limited credit information of a small number of tenants via Experian and the Debt Prioritisation Service to support you to better manage your finances and rent arrears.
We will always consider whether or not it is necessary to obtain your consent to access personal information as well as the potential impact on you and balance Northwards Housing’s interests with your rights and interests.
We’re committed to keeping your personal information safe and storing it securely and access to it is strictly controlled and monitored. Only Northwards Housing staff, a small number of volunteers and our contractors can see your personal information and they only see the information that is relevant to help them do their job.
We regularly review who has access to personal information to ensure it is only seen by people who have been trained. Our staff receive data protection training and we have a data protection policy and procedures in place.
We store personal information on computers and we also hold paper records. Our computer systems are secure and protected and our computer network is checked regularly to prevent unauthorised access. Sometimes we also use computers which are owned or managed by our suppliers. Their computers will always be secure and protected too.
We may share your personal information with other companies, for example, repairs contractors or suppliers who provide services on our behalf, such as companies that send out mail shots or newsletters on our behalf or with Manchester Move. We will always provide the minimum of personal information necessary to complete the task and make sure that your information is treated with the same respect as if we were handling it. We have contracts or information sharing agreements with companies to make sure your information is kept confidential and secure.
We do not share personal information outside the European Economic Area (EEA).
We share your personal information with other agencies like Manchester City Council, or the police, but only when we need to - for example to prevent crime or provide extra support to you. We only share essential and relevant personal information and ask them to keep the information safe and remove it from their files when they no longer need it.
We use different products and computer software to store personal information and we make sure the information is held securely and access to it is controlled.
As part of the National Fraud Initiative, we may share personal information about our tenants with other public bodies to pinpoint any fraudulent activity and to stop fraud happening in the future. We are committed to making sure that no one is living in our homes who shouldn't be and we're working with Manchester City Council to make sure that public money is spent properly. This work helps us to reduce the number of frauds in housing benefit and in tenancy agreements to make the system fairer.
Families with Complex Needs
We will also provide the council with certain personal information about people who have been the involved in anti-social behaviour. This is to enable those people to be considered for help under Manchester City Council's 'Complex Families' Programme. Click the link for more details.
Our ‘Be Well’ service
We share personal information with the NHS for our customers who choose to use this service, but we will always ask for your consent first. All personal information is treated in the strictest confidence.
Credit Reference Agencies
If you are a tenant, we will share your personal information with Experian (a credit reference agency). A credit reference agency is an independent organisation that securely holds data about your financial behaviour, accounts and credit/loan applications. When you apply for a property with us via the Manchester Move website and before you enter into a tenancy agreement with us, we will check with Experian to ensure that you are able to afford the property you have been offered.
We are also a member of Rental Exchange which is a scheme run by Big Issue Invest and Experian. The scheme allows tenants with little or no credit history, to build a credit history and to create an online proof of identity which, together with being able to show a track record of paying your rent, will enable you to access services such as bank accounts, credit cards, online shopping, cheaper credit and better gas and electricity rates.
Important: Building a credit history also means that if you do not pay your rent, fail to make regular payments on time or accrue rent arrears, it will have a negative impact on your credit rating. This may mean you are less likely to benefit from the scheme and obtaining access to the services described above will be more difficult.
In addition, sharing your tenancy records through Rental Exchange allows us to work more closely with you to manage your existing tenancy, like providing money advice, and also enables Experian to use the information to assist other landlords and organisations to:
- Assess and manage any new tenancy agreements you may enter into;
- Assess how strong your financial standing is for suitable products and services;
- Manage any accounts that you may already hold, for example, reviewing suitable products or adjusting your current product in light of your current circumstances;
- Contact you in relation to any accounts you may have and recovering debts that you may owe;
- Verify your identity and address to help them make decisions about services they offer;
- Help prevent crime, fraud and money laundering.
We will therefore share your tenancy details and rent payment history with the Rental Exchange throughout your tenancy.
However, to allow you to remain in control of your personal information, you are able to opt-out of the Rental Exchange scheme. You can do this through our website or by writing to us at Northwards Housing, Freepost, Manchester M9 8GQ or by emailing firstname.lastname@example.org. We will need your contact details so that we can speak to you and verify your identity.
Other legal reasons
There may be other reasons we will be expected to share information, for example, if there are safeguarding concerns involving children or vulnerable adults.
We will only keep hold of your personal information for as long as it is needed and for the purposes it was collected.
How long personal information is kept depends on the type of information it is and what it is being used for. For example, we will stop sending you emails if you unsubscribe to our email service and delete your records if they’re no longer needed.
We have a list called a ‘data retention policy’ which sets out how long we keep different type of information before it is deleted and destroyed confidentially. This is to comply with our legal obligations, or to protect our or your interests.
You have the right to see any of the information we hold about you. To ask for the information, complete our information request form.
We will acknowledge your request and send what you have asked for within a month. In exceptional circumstances, if it takes us longer, we will explain why and provide you with a realistic due date which will be no later than a further 2 months.
Under certain circumstances, by law you also have the right to:
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to use it. You also have the right to ask us to delete or remove your personal information where you have decided to use your right to object to us using it.
- Object to processing of your personal information in certain circumstances.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend using your personal information, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
You can find more information about your rights by visiting the Information Commissioner’s Office website.
If you have any concerns about the way we use or keep your personal information, we would encourage you to contact us
If you have any questions about the personal information we hold, you can also ask to speak to our Data Protection Officer by emailing them directly at DPO@wearehy.com or completing our information request form.
We review this policy regularly, at least annually, and take into account any changes in the law, feedback from customers or changes in guidance issued by the regulator, the Information Commissioner. The date the policy was last reviewed was February 2019.
You can contact us by emailing email@example.com
We’re always keen to receive feedback about our policy and if you have any suggestions for how we could improve it we’d be happy to hear from you.
If you have any questions about how we use your personal information or want to let us know your personal information has changed, please email us.
If you want to make a complaint about the use of your information you can contact the Data Protection Officer by emailing DPO@wearehy.com.
Northwards Housing is registered with the Information Commissioner’s office registration number Z9400719.
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