Keep Homes Privacy Notice
This privacy notice explains what happens to the personal information you give us. It also explains the choices you have about the data we hold about you.
We are committed to handling your information securely, respectfully and in line with data protection laws. At Keep Homes (KH) we take the privacy of your information very seriously.
Our privacy notice tells you what to expect when KH processes your personal information (‘personal data’) which we collect when you become one of our customers or each time you contact us.
‘Personal data’ is any information which relates to an individual who can be identified from that information. ‘Processing' includes the collection, recording, storage, use, disclosure or destruction of personal data. We are a “data controller”. A data controller determines the purposes and means of processing personal data.
Who we are and our contact details
We are Keep Homes of 39 Etchingham Park Road, London N3 2DU. You can find out more about us at http://www.keephomes.co.uk.
For further information, please contact our Data Protection Officer by emailing firstname.lastname@example.org.
Our Data Protection Officer is responsible for data protection compliance at Keep Homes.
How we collect your information
We will make every effort only to collect the personal information we need from and about you. The type of information we collect will vary depending on the service we offer to you.
The information will be collected directly from you, but we may also obtain information from another person or organisation if you have given permission for them to share it with us, or the law allows them to. This could include a local authority, your previous landlord, your doctor or other health professional. In addition, we may also obtain your information from available public sources.
The types of data that we collect
Personal data such as your name, address, date of birth, email address, phone number, gender, marital status, disability, race, religion, employment status, National Insurance Number and next of kin details for you and your family. We also hold data about your credit risk, rent account, rent payments, benefit status, bank account details, credit reports, contact with us about rent arrears and agreements you have made to repay arrears.
Special category personal data. This is sensitive personal information, for example your racial, or ethnic origin, religious beliefs, other beliefs, sexual orientation, health information, political opinions and so on. KH would only collect your sensitive personal information where there is a clear need for us to do so, such as to assess what services are relevant to you or to offer appropriate support to you. Before collecting any sensitive personal information about you we will always try to make it clear to you what information we are collecting, the reason for collecting it, and explain your choices in respect of providing this information. If you have any questions please ask us.
Criminal offence data. This is data that relates to criminal convictions and offences or related security measures. KH collects this data to ensure appropriate services can be provided. Before collecting any criminal offence data about you we will always try to make it clear to you what information we are collecting and the reason for collecting it. If you have any questions please ask us.
How we use your personal information and the legal basis for processing
We use the information we hold about you to manage your tenancy or leasehold. We need this to deliver our services to you. We collect most of this information because it is necessary in the performance of a contract. You will not be able to opt-out of providing this type of information.
We also process some of your data because it is in our legitimate interests to do so. You can object to this processing if you think that your legitimate interests outweigh ours.
We consider that we have a legitimate interest to make sure that:
- Our services/properties meet the needs of our customers;
- We can contact residents in the event of emergencies and to carry out essential repairs;
- We communicate with residents to meet our business objectives, encourage social inclusion and help build communities;
- We work with authorities and the police to support safer communities;
- KH remains commercially viable and protects its commercial and social assets;
- We have effective procedures for preventing, and managing, outstanding debt for example from unpaid rents, service charges etc;
- We make the most efficient use of our resources and we understand how we are performing;
- We understand our residents’ experiences and views so that we can effectively influence and contribute to debates on future housing strategies
Special category personal data and criminal offence data
We can only process special category personal data and criminal offence data in certain circumstances
- With your consent;
- Where we need to protect the vital interests (i.e. the health and safety) of you or another person;
- Where you have already made your personal information public;
- Where we or another person needs to bring or defend legal claims;
- Substantial public interest grounds (eg safeguarding, protecting the public, preventing unlawful acts)
We are not permitted to keep a comprehensive register of criminal convictions.
What sorts of personal information do we hold?
We use the information we collect from or about you (as applicable) in various areas of work, including:
Assessing and processing housing applications, sales of shared ownership properties, service eligibility and completing tenancy sign-ups
- To process your application, we require 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, suppliers and partners.
- 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, council tax, medical information, details of any unspent criminal convictions.
This information is required as we will be unable to accept an application for services without it. Information on household members is required as it is also in our legitimate interests to know who will be living in our premises and to ensure the property offered is adequate for the needs of the household. We assume any information you provide about household members is provided with their full knowledge and you should direct your household members to this policy.
Managing your tenancy or lease
- Your 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. 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 may need to provide your contact details and relevant associated information to our contractors who may be undertaking work on your property on our behalf.
- We will ask you for supporting documents to effect changes to your tenancy, such as a copy of your marriage certificate or deed poll certificate to change your name on our records, or supporting medical evidence to reassess any change to housing requirements as a result of a medical need.
- 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.
- Financial records about the amount of money you have paid us, any amount(s) outstanding and associated recovery action.
- We may hold information about your history, for example regarding credit status or criminal convictions, if we decide this is required.
- We also record information about repairs, maintenance, and servicing requirements of your home. We may need to provide this information in particular to our contractors
- We will also use your contact information to tell you about changes to Keep Homes, for example changes to our organisational structure and governance arrangements, and to resolve or investigate complaints.
The provision of this information is a ‘contractual requirement’. Without this information, we may be unable to manage or provide your services. For example, we would not be able to discuss changes to your service if we do not hold your contact details. Please speak to us if you have any concerns.
Confirming your eligibility for housing and prevent fraud and illegal sub-letting
- We will ask for proof of ID e.g. for tenancy audits or when the housing composition changes or a reasonable period of time has passed (this applies to all household members over the age of 18).
We need to be able to verify your identity to provide services to you. Processing for the purpose of fraud prevention is required in order to meet our legal obligations.
Meeting your needs in our service delivery
- We record your support needs in our dealings with you and to improve our communications with you.
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.
Managing the legal process if you apply to buy your home or want to access another home ownership route
This information is required to manage the legal process needed in preparation for entering into contractual relations.
Assisting with personal security and prevention and detection of crime
- We may capture your image on our CCTV systems if you visit one of our properties which is covered by this facility.
This information may be required to meet legal obligations and our legitimate business interests around health and safety and crime prevention.
Understanding how we’re performing
- Our managing agents may undertake call recordings for training and quality monitoring purposes.
- We will carry out customer satisfaction surveys to help us monitor our performance and improve our services.
It is in our legitimate interests to understand how we are performing so we can meet our objectives.
Keeping in touch with you
We may wish to communicate with you and keep you up to date with events and news about the organisation which we think will be of interest or use to you.
Prevention and detection of crime, and regulatory purposes
We do this to meet our legal obligations and to further our legitimate interests.
How do we collect data about you?
The information we hold about you comes from you or your household members, for example when you filled in your original application and signed up to your tenancy. We will also have any letters or emails you have sent to us, records of calls to the office and any feedback or permission forms you have completed.
Who might we share your information with and why?
KH operates through contracting with managing agents that are responsible for managing relationships with tenants on a day-to-day basis. This means that we will share information with the particular agent that is responsible for managing the home in which a tenant lives.
We sell our properties through partner agents who work on our behalf. We will share your information with the particular agent to enable you to buy a property from us.
We will not disclose personal information about you to other parties except where we have a legitimate interest or other legal basis for doing so or where you have given us your consent to disclose (if required).
Your data may be shared within KH where it is necessary for staff to carry out their duties or to provide services to you. We may share your data with our contractors and suppliers so that we can carry out repairs and maintenance to your home or provide other services.
There may be situations in which we have or choose to share some of your information with other third parties including (but not limited to):
- Local councils and government departments (including the Ministry of Housing, Communities and Local Government)
- Health and care services
- Police and other law enforcement agencies
- Electricity, water and gas companies
- Social Housing Regulator
- MPs and Councillors acting on your behalf
Where we share data with a third party organisation or statutory agency we will ensure that the organisation or agency understands how the data is to be used, what information is to be shared and when it will be destroyed. We may provide more detailed information to you about any data sharing that takes place, or you can ask us for more information about it.
In some cases we may be legally required to provide information to one of these other organisations – for instance, in certain circumstances we may be required to provide information about housing benefits to a local authority or central government department.
Our staff are trained in data protection and know the importance of keeping your data safe and secure.
We don’t normally send data overseas
Our business is based solely in the United Kingdom, and so we do not ordinarily send data overseas. We may sometimes make use of cloud-based systems located outside of the EU to support the management of our business. Where this happens, we will ensure that there are appropriate safeguards in place to protect your data.
KH is required by law to comply with UK Anti Money Laundering Regulations (AML Regulations).
Whether you are a new or existing customer, we may therefore need to verify your identify and your source of funds.
We may do this by:
- Requesting that you provide original or certified copies of identity evidence
- Requesting that you provide necessary documentation to support proposed source of funds
- Undertaking an electronic identity check using a credit reference agency to search information relating to you
We primarily use our partners, Coreco, Just Mortgages, Orchard & Shipman, Pinnacle and SpicerHaart to undertake these checks.
With your consent (or because you have used or been interested in similar services from us previously) we may use your personal data in order to send you information about our services, promotions and events that we believe may interest you.
With your consent we may share your personal information with our partner agents (including but not limited to Sales Agents, Financial Advisers and Mortgage brokers) and may use the information you give to us to provide you or permit selected partner agents to provide you with information about the developments and other products that are of interest to you.
If you are or represent a business, you may also receive an email from KH because we obtained your contact information from a reputable third party agency.
We collect your basic identification and contact details. This may include for example your name, company, telephone number, and email address.
If you decide to opt-out of our marketing, we will no longer use your personal data for this purpose. You may opt out (or opt back in) at a later date. You have a right at any time to stop us from contacting you for marketing purposes.
You can easily change or withdraw consent or stop receiving direct marketing messages or communications by clicking the 'unsubscribe' link at the bottom of each marketing email or emailing email@example.com.
How long we keep your data for
We will only keep your data during our relationship with you and for a set period afterwards to allow us to meet our legal obligations, including resolving any follow-up issues between us (for example, if you are a tenant, we will hold information about you for the duration of your tenancy. If you move, and are no longer a resident we will usually keep records about you for no more than 6 years).
Please contact us if you would like any more information.
Protecting your data
We take the protection of your data very seriously. We have procedures in place to protect your data from loss, misuse, disclosure, abuse or destruction.
Where we share your data with third parties, such as contractors, we provide written instructions to them to ensure that your data is held securely and in line with data protection legislation. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not normally undertake automated decision making
We do not normally undertake automated decision making – that is decisions made about individuals without any human involvement.
The law on data protection gives you certain rights in relation to the personal data we hold about you. These are:
- The right to be informed. This means that we must tell you how we collect and use your data (i.e. the details provided in this privacy notice).
- The right of access. You can ask to see the data we hold about you which we will provide free of charge (in most circumstances). A request to see this information is known as a ‘subject access request’ (“SAR”).
SARs do not need to be made in writing but we encourage you to put the request in writing so there is no confusion about what you are asking for. We also ask that your written request be accompanied by proof of your address and identity. If you require specific information it is helpful if this is clear in your request, for example, information from a particular time period or about a specific piece of correspondence. If someone is requesting information on your behalf, they will need written confirmation from you to show you consent for us to release this and proof of ID (both yours and theirs).
We will provide a copy of the information requested free of charge. However, we can charge a ‘reasonable fee’ when a request is manifestly unfounded or excessive, particularly if it is repetitive. We may also charge a reasonable fee to comply with requests for further copies of the same information.
We will seek to provide you with the information you have requested within one month although in certain circumstances it may take longer to provide you with some or all of the information you have asked for and we will try to keep you updated about this as promptly as we can.
- The right to rectification. You can ask for any inaccuracies to be corrected. If any of the data we hold about you is wrong you are able to ask us to correct it.
- The right to ask for erasure: to ask to have your information deleted. If you want us remove any of your data you can ask us to delete it from our systems where it is no longer necessary for us to keep it. Please be aware, however, that we may not need or be able to comply with such requests, depending on the circumstances.
- The right to restrict processing of your data. You can ask us to stop using your data while we check that it is correct.
- The right to object to the inclusion of any information if we are processing it based on a legitimate interest. You can tell us that you think the way that we use your data is wrong.
- The right to withdraw consent at any time. If we are relying on consent to use your personal information, then we must stop using the information. We can refuse if we can rely on another reason to process the information such as our legitimate interest
- The right to data portability allows you to copy or transfer personal data easily from one IT environment to another in a safe and secure way. The right only applies to personal data you have provided to us where we are relying on your consent or for the performance of a contract to use your information. It also only applies when processing is carried out by us using automated means.
Changes to our Privacy Notice
We keep our privacy notice under regular review and will place any updates on our website; you will be notified of any major changes to this policy.
Making a complaint
If you are concerned about the data we hold, how we are processing it or if you would like to see the data we hold about you please contact us at firstname.lastname@example.org.
If you remain dissatisfied, you have the right to refer the matter to the Information Commissioner. The Information Commissioner can be contacted at:
Helpline: 0303 123 1113