Customer Privacy Policy

Customer Privacy Notice

This privacy notice sets out how North Devon Homes uses and protects your information in accordance with the data protection legislation in force in England. North Devon Homes includes:

  • North Devon Homes
  • Anchorwood Ltd

We are obliged by law to give you this Privacy Notice. It is part of our procedures for data protection. Its purpose is to tell you:

  • What information we will collect about you (your personal data)
  • Why we are able to process your information
  • What purpose we are processing it for
  • Whether you have to provide it to us
  • How long we store it for
  • Whether there are other recipients of your personal information
  • Whether we intend to transfer it to another country

It also tells you of your rights in relation to the information we have about you. The term “Customer” includes tenants (in our owned or managed properties), occupants, shared owners, leaseholders, freehold purchasers of market sale properties, garage renters and Alarm customers.

What sort of information is involved? What is ‘personal data’?

Broadly, it means any information relating to you personally.

From the time of your first application for accommodation and throughout your tenancy with us, we come into possession of a range of information about you, but we are principally concerned with information that enables us to manage your tenancy and / or provide services to you effectively and therefore in which we have a legitimate interest including:

  • Personal details e.g. date of birth, national insurance number, marital status
  • Family detail e.g. the names and dates of births of those living with you
  • Lifestyle and social circumstances
  • Financial information and employment details, which with your consent may help us to solve arrears payments, and to provide welfare, benefits and debt advice
  • Property details to help us solve repair issues
  • Satisfaction survey details that will enable us to shape our services and fulfil regulatory requirements. It is optional as to who replies to these and they are anonymised

Sometimes we may also process sensitive classes of information that could include:

  • Physical or mental health details to help us support your needs
  • Relevant criminal convictions and other misconduct or allegations of misconduct
  • Warnings against you or your occupants that ensure your safety and that of our staff and contractors
  • Details of complaints by or about residents
  • Recordings of incidents involving our staff as part of our lone working protection system
  • Ethnicity data

We do minimise our holding of sensitive classes of data, but given the services we provide, there are times when we use it to understand our customers and their needs better and to protect our staff.

Any payment details are processed outside of North Devon Homes, through recognised providers and are not stored within our own IT systems.

Any recordings of incidents made by staff when they feel threatened are processed outside of North Devon Homes, through a recognised provider with appropriate safeguards in place, and are not stored within our own IT systems.

There may well be other items of information that we record from time to time for the purposes of ensuring the smooth running of the business.

Every effort will be taken to keep all information up to date and accurate.

What information do we hold on under 13’s and children and how is it collected/processed?

NDH will only collect limited information about children living within a property, such as name, address, and date of birth. This is so a record of who is living at the property can be kept. We may also collect information about relevant health conditions if it is needed for us to provide help or support.

NDH will collect information for children and young people in some settings, such as in relation to safeguarding.

The data that is collected for children and young people will depend on the services and support needs of that individual. It is likely to include:

  • Name
  • Date of birth
  • Health and support needs
  • Details of parent or guardian
  • Support plans
  • Case notes
  • CCTV Images

NDH may legally collect information beyond this list if it is required.

NDH may share a child’s personal data if there are welfare concerns through our safeguarding procedure or as part of a multi-agency welfare case.

Children aged 13 or over have the same data protection rights as adults. Therefore, children of 13 or above, can exercise their rights under the data protection act 2018 and UK GDPR. This includes making a subject access request.

For children under the age of 13, those with parental responsibility can make an individual rights request on behalf of the child. Please speak to an NDH colleague if you have any questions regarding data protection rights.

Information regarding housing will be retained for six years after you have moved out of the property. Support plans will be retained in accordance with our Document Retention Policy. After this time, your information will be deleted or securely destroyed.

How do we collect information?

We collect information in a variety of ways including forms, contracts (e.g. tenancy agreement), email, in writing, over the phone, face to face, online, CCTV, photos, Drone footage etc. The information may be supplied by you or by another source such as family, neighbours police, credit agencies or the local council.

We keep a record of when you contact us or use our services (such as when you request a repair or make a complaint) and note the outcome.

We record calls to and from our offices to assist with training and monitoring. When taking rent payments the recording is paused when the card details are read out.

At our offices and some housing and support schemes we have CCTV cameras in public areas for crime prevention and safety purposes. We also provide our staff with a voice recording facility on their identity badge in case they get involved in a heated exchange or incident that puts their safety at risk.

We may photograph or film events to use for our websites, publicity material (such as newsletters); these may be provided to the media for publication in local and national newspapers and on Social Media. We ask customers for their consent to be included in a photograph or film when they are the main subject of an image.

Who is collecting the information?

North Devon Homes – a registered charity

You can contact us at Westacott Road, Barnstaple EX32 8TA

Tel 01271 312500

Email: [email protected]

We are the ‘Controller’ for the purposes of data protection law and decide how and why the information is collected and processed.

What is meant by ‘processing’ information?

‘Processing’ is broadly defined as any operation which is performed on your personal information.

The ‘operations’ in question include collecting it, recording it, storing it , consulting or using it, disclosing it, combining it, limiting its future processing, and even erasing it or destroying it.

Why is the information collected/processed?

In order to ensure the smooth and efficient running of the company and to provide the right services to you, and so ultimately for your benefit.

What legal basis is there for collecting/processing the information?

We collect and process your information because you have entered into, or wish to enter into a contract (tenancy agreement) with us. This is generally the legal basis for processing your information and carrying out our activities. We need the information to help us assess and manage your tenancy and to provide the services that are expected from us. There are also times when processing personal information is necessary for a legitimate interest pursued by NDH or a third party.

We are allowed to collect and process information as we have a legitimate interest in doing so.

We are entitled by law to collect and process such information where it is necessary:

  • In order for us to consider your application to become a tenant,
  • For meeting the terms of the tenancy agreement with you
  • Information to confirm your identity
  • In order to enable us to comply with a legal obligation
  • In order to protect your vital interests or those of another person, or
  • For the purposes of legitimate interests pursued by us or by a third party property management e.g. debt recovery services
  • Associated welfare services and support research
  • Preventing crime, prosecuting offenders and tackling anti-social behaviour
  • North Devon Homes colleague and customer security and health and safety
  • To provide services to you such as repairs and planned improvements where we will share your contact details with our contractors
  • To credit scoring agencies to support you in getting loans and access a range of goods and services online.

Our legitimate interest is in running the business of letting; managing; repairing and collecting income smoothly and efficiently in accordance with the terms of the Tenancy Agreement for the benefit of the residents; and in protecting their interests as tenants of North Devon Homes property.

No data is transferred outside of the EU.

What are the legitimate interests just referred to?

We have an interest in making sure our services and products are of a high quality, efficient and suitable for you and your home, so we may process your information to ensure that they are tailored to your needs. It can also apply to processing that is in your interests as well. For example, we may process your personal information to help ensure that our websites and systems are secure and so protect you from fraudulent use of your personal data.

The legitimate interests of third parties include for instance the interests of health, social welfare, safeguarding or police authorities and other public bodies in pursuing their normal functions.

Do we share the information with anyone?

We may share your information with third parties from time to time, such as:

  • Police
  • HMRC
  • NHS
  • Utility and telephone companies
  • Local Authorities, government regulators and agencies (such as the Department of Work and Pensions, Regulator of Social Housing or Homes England)
  • Credit checking agencies, rental exchange and debt recovery agents
  • Charities and voluntary organisations and our support partners
  • Contractors acting on our behalf
  • Partner organisations who carry out Satisfaction Surveys on our behalf (including Tenant Satisfaction Measures) It is optional as to who replies to these and they are anonymised

We will share specific and relevant information with law enforcement and government agencies or public bodies where we are legally required to do so. Examples may include:

  • The prevention or detection of crime and fraud
  • The apprehension or prosecution of offenders
  • The assessment or collection of tax or duty owed to customs and excise
  • Sharing in connection with legal proceedings
  • Sharing in relation to the physical or mental health of an individual, where disclosure is required to protect them or others from serious harm
  • Research and statistical purpose

We may also share your information with emergency services and local authorities, where this is necessary to help them respond to an emergency situation that affects you.

How long will the information be stored?

Your personal data will be securely stored in accordance with North Devon Homes Data Retention Policy.

What rights do applicants/residents have?

You have the following rights in connection with the information that we have collected/processed:

  • The right to request access to the information or to have it rectified or erased or restricted.
  • The right to object to the processing of information
  • The right to have a copy of the information (‘data portability’)
  • The right to withdraw consent at any time (but please note what is said above about the circumstances in which we may collect and process information even without your consent)
  • The right to lodge a complaint with the supervising authority, which is the Information Commissioner’s Office

You have the right to access any information that we hold relating to you. Should you wish to receive details that we hold about you please send your request in writing, including proof of your identity, to our Data Protection Officer at Westacott Road, Barnstaple, Devon EX32 8TA or email Philippa Butler at [email protected].

Information provided by sources other than the applicant/resident

We may come into possession of information about you from sources other than yourself. For instance, from neighbours, other agencies, the internet or from others in the course of their dealings with the company.

Such information will usually fall into the categories outlined above.

All such information will be safeguarded in the same way as if you had given it yourselves.

How will the information be safeguarded?

Information in digital form will be stored on encrypted computers. Such computers are safeguarded by passwords and anti-virus and anti-malware software. The computers are kept in secure conditions inside our offices.

Information kept in paper form will also be kept in secure conditions inside our offices.

Any portable devices provided by the company to staff are protected by passwords and are encrypted. If these devices are mislaid or stolen we can deactivate them remotely.

All reasonable steps will be taken to ensure that information in whatever form is not lost or damaged or destroyed or allowed to fall into the hands of those not authorised to receive it.

Right to object

You have the right to object to North Devon Homes processing your data, even if it is based on our legitimate interests and necessary for us to provide services to you and maintain our relationship with you. If you wish to object please contact our Data Protection Officer at Westacott Road, Barnstaple, Devon EX32 8TA, email [email protected] or call 01271 312500.

Issued 09/04/2024