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The data controller for the purposes of the Data Protection Act and the General Data Protection Regulation is GHH (POC) Limited of 70 Grosvenor Street, London, W1K 3JP.
GHH (POC) Limited strongly believes in protecting your privacy and the confidentiality of your personal information. To explain how GHH (POC) Limited collects, uses and protects personal information in connection with tenant management we have developed the following privacy notice. In this privacy notice, ‘We’ and ‘Us’ means GHH (POC) Limited.
This privacy notice applies to tenancy applicants, tenants, former tenants, and owners of 'enfranchised' properties.
You can contact us with any questions you may have about privacy and/or data protection. Our contact details are: firstname.lastname@example.org
We collect personal information as part of the tenant application process, and if you become a tenant, during your tenancy. We explain in detail below the types of information that we collect, how and why we use that information, and what rights you have in connection with your personal information.
We must have a lawful basis to process your personal information, and this notice explains what our lawful basis is in respect of each purpose for which we keep and use personal information about you. Generally, we are allowed to process your personal information where it is necessary in connection with a contract between us (such as a lease or maintenance agreement), where it is necessary for us to comply with our legal obligations as your landlord, or where we have a legitimate interest to do so (but we will always consider whether your right to privacy overrides our interest).
We will require you to provide certain personal information to us where it is necessary, both as part of your tenancy application and if you are a tenant, in connection with your tenancy contract. If you fail to provide certain personal information when requested, we may not be able to offer you a tenancy contract, perform the contract if we have entered one with you, or comply with our legal obligations.
We may collect personal information through the application process, either directly from applicants or a background check provider. We also may collect additional personal information from third parties including councils, employers, credit reference agencies and/or other background check agencies.
We may collect additional personal information as required.
We may collect and use the following personal information about you:
We may collect and use the following personal information about you, so that we can understand you and your needs to help tailor our service to you:
If appropriate we will collect sensitive information about you such as ethnicity, religion, sexual orientation, physical and mental health, and criminal offences. For further information about this, please see information on ‘Sensitive personal information’ and ‘Information about criminal convictions’ under the section on ‘How we use your personal information’.
We may also collect personal information of other people associated with you, such as other members of your household, dependants, your next of kin, and emergency contacts.
We are committed to improving your experience with us and from time to time we will process yourinformation to carry out tenant feedback exercises, newsletters, and service information.
You can provide details of friends, relatives, or neighbours who you trust to contact us on your behalf.
With your consent we may use your name, photo, video, and experience with us for brochures, advertising, or press releases.
We will process your personal information if you contact us with compliments and/or complaints about our services
If you attend our events, we may contact you for feedback on how they have helped you.
We pride ourselves on being active in the communities we work in. Your personal information may be used for our services within localities.
We may collect and use the following personal information about you:
We may collect personal information about you from other sources. This may include the following:
This list is not exhaustive. In specific instances, we may need to collect additional personal information for the purposes set out in this notice.
We may collect personal information about you from third parties, including the police, the council, organisations who let and manage our properties and organisations who provide professional advice and support regarding social housing management, to identify if you are a suitable prospective tenant and/or ensure your support needs are appropriately met.
We have set out in the table below how and why we use your personal information, and what our legal basis is to be able to use your personal information in each way. The principal legal bases on which we use your personal information are as: (a) to Allow us to enter into and perform a contract, (b) to enable us to comply with legal obligations, and (c) to pursue legitimate interests of our own or those of third parties (provided your interests and fundamental rights do not override those interests).
Basis for processing personal information
Allow us to enter into and perform a contract
Enable us to comply with legal obligations
In order to pursue legitimate interests of our own or those of third parties (provided your interests and fundamental rights do not override those interests)
Administering a tenancy if we have entered into one with you
Checking you are legally entitled to reside in the UK
Complying with our health and safety obligations
Dealing with any complaints you may have
Dealing with legal disputes involving you, or other tenants or other residences, including accidents
Determining the terms on which you will be granted tenancy
Management and planning, including accounting and auditing
Making a decision about your application for a tenancy
Making decisions about rent reviews
Making decisions about your continued residency
Making arrangements for the termination of your tenancy or residency
Making repairs, alterations, and improvements to your property
To detect and prevent fraud, money-laundering and other crimes
To interact and respond to any communications you send us, including social media posts that you tag us in
To let you know about any important changes to our business or policies
We may use your personal information to identify and tell you about events and activities that we think may be of interest to you. We will only do this by email where you have informed us that you would like to receive these communications via email. Whether you choose to receive this information via email is entirely up to you. Your choice will not affect your tenancy. You can update your preferences by responding to our emails to you, or by contacting us (see contact details above).
We may also use your information to invite you to participate in market-research. If we do contact you about market-research, you do not have to participate. If you tell us that you do not want to.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Sensitive Personal information, such as ethnicity, religion, sexual orientation, and physical and mental health requires higher levels of protection. We need to have further justification for collecting, storing, and using this type of personal information. We may process this personal information in the following circumstances:
Less commonly, we may process this type of personal information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the personal information public.
We may only use personal information, relating to criminal convictions where the law allows us to do so. We may use this information:
Where we process such information, it shall be in accordance with this privacy notice and subject to appropriate safeguards.
If you are violent or abusive to our employees and/or other tenants, we may decide to place a violent warning marker on your record. If we do this, we will tell you and explain why. We will also share this information with any of our partners such as contractors.
We may share your personal information with our employees where this is necessary, such as for internal administration purposes. Your personal information will only be shared with such employees as are reasonably necessary for these purposes.
Please note that our employees are employed by a separate data controller, The 4th Duke of Westminster’s 1964 Settlement Trust, of Eaton Estate Office, Eccleston, Cheshire, Cheshire, CH4 9ET.
We may need to share your personal information with certain third parties, including third-party service providers, and we require third parties to respect the security of your personal information and to treat it in accordance with the law.
We will share your personal information with third parties where required by law, where it is necessary to administer your tenancy, support our relationship with you or where we have another legitimate interest in doing so. The following activities are carried out by third-party service providers:
There are also certain exceptional circumstances in which we may disclose your personal information to third parties. This would be where we believe that the disclosure is:
We may share personal information about you with other third parties, including the police, the council, organisations who let and manage our properties and organisations who provide professional advice and support regarding social housing management, to identify if you are a suitable prospective tenant and/or ensure your support needs are appropriately met.
If you do not become a tenant or decide you no longer want to take up a tenancy, then we will not retain your personal information.
Once you have ceased being a tenant, we will retain very limited personal information indefinitely, for the purposes of keeping and maintaining our historical records. Please note that these records will remain confidential for a period of 100 years.
All other personal information will only be kept for 6 calendar years after a tenant has vacated.
There are several exemptions to the 6-calendar year retention period after the tenant has vacated:
Social care support and safeguarding, including multi-agency meeting notes and referrals and care leavers personal development, will only be kept for the duration of the tenancy.
Any information that we require, to determine your income and welfare benefit, will only be retained for 2 years after it has been provided.
We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this notice.
All personal information you provide to us is stored securely, including in a physically secure environment, on our secure servers.
Access to your personal information will be restricted to such employees and other individuals as are necessary for the purposes for which the information was collected.
Due diligence has been carried out to ensure that those who are letting and managing our properties are complaint with data protection and information security requirements.
We have a legal obligation to provide you with concise, transparent, intelligible, and easily accessible information about your personal information and our use of it. We have written this notice to do just that, but if you have any questions or require more specific personal information, you can contact us (see contact details above).
You have the right to ask us to confirm whether or not we hold any of your personal information. If we do, you have the right to have a copy of your information and to be informed of the following:
To maintain the security of your personal information, we will have to verify your identity before we provide you with a copy of the information we hold.
You have the right to amend any inaccurate personal information about you which we hold. If you need any support, please contact us (see contact details above).
There may be times where it is no longer necessary for us to hold personal information about you. This only relates to the following:
In these situations, you have the right to have your personal information deleted. If you believe one of these situations applies to you, please contact us (see contact details above).
Also known as Data Portability, you have the right to obtain a copy of your personal information for your own purposes. This right allows you to move, copy or transfer your personal information more easily from one IT system to another, in a safe and secure way. This right shall only apply where:
If you would like us to transfer a copy of your personal information to you or another organisation in a structured, commonly used, and machine-readable format, please contact us (see contact details above).
You can tell us at any time that you would prefer that we do not use your email address to be contacted about events and activities. If you would like to stop receiving emails about events and activities, please contact us (see contact details above) or respond to the emails that we send, and we will stop sending these immediately.
Sometimes, we use your personal information to pursue our own legitimate interests, or those of third parties (please see ‘How do we use your personal information?’ above for more information about such interests).
We aim to always ensure that your rights and personal information are properly protected. If you believe that the way we are using your personal information is not justified due to its impact on you or your rights, you have the right to object. Unless we have a compelling reason to continue, we must stop using your personal information for these purposes.
To exercise your right to object to our use of your personal information for the purposes above, please contact us (see contact details above).
You have the right to ask us to stop using your personal information in any way other than simply keeping a copy of it. This right is available where:
If you believe any of these situations apply, please contact us (see contact details above).
If you wish to make a complaint about our collection or use of your personal information, please contact us (see contact details above) in the first instance so that we may seek to resolve your complaint.
If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the statutory body which oversees data protection law in the UK. This is the link to the ICO website if you wish to lodge a complaint with the ICO.