Your privacy is important to us. This information notice explains what personal data we collect from you and how we use it. Please read the summaries below and if you then would like more information please contact us.
This notice relates to the Pobl Homes and Communities who are part of the Pobl Group, including Pobl Letting Agency
Pobl Group Ltd
Tel: 01633 679911
Our Data protection Office is Gillian Owen and you can contact her at Gillian.email@example.com.
How we collect personal information
We collect information in a variety of ways including; on various forms, tenancy agreements, in CCTV images at some locations, through ongoing contact with you via personal meetings, letters, texts, social media messaging, e-mails and phone calls, some of which are recorded.
When you apply for a property with us or you are referred to us for a home by the Local Authority, we request and store references about you from, for example, your former landlord or mortgage lender, the police, social workers, health professionals, support workers and credit reference agencies.
If you are a landlord using our letting agency services we collect and store personal identification, proof of address, proof of property ownership and mortgage consent; along with bank details to enable us to make rental payments to you.
We may also take photographs of people at events or in our communities to use for general marketing and publicity. We will only use these images where we have your consent to do so.
If we collect information from you about your family or other people who live with you we assume that you have obtained their consent to give us this information for processing.
Who we collect personal information about
We collect personal information about:
- Our Customers: This includes current and former customers and potential customers who live in the properties we own or manage or communities we work in, or who access the support and other services we provide. This could include people such as tenants, home owners and leaseholders and also their family, partners or associates.
- Anyone who makes a complaint or enquiry, including other professionals and members of the community.
What personal information do we collect?
Most of the personal information that we process is about you and the people who live with you. This includes information such as your name, address, contact details, gender, date of birth, proof of identity such as photo ID, national insurance number and financial information including income and bank account details. Sometimes we process personal information about you that we have been given by other organisations such as the Local Authority, the Police, support agencies, Councillors or MPs acting on your behalf. This could include, for example, information relating to a housing application, universal credit or housing benefit claim, support package or criminal activity.
We need this information for you to enter into contract with us. We have a legitimate interest to collect and use this data fairly and lawfully.
Special category or ‘sensitive’ personal information
Some of the personal information we process is a bit more sensitive and needs extra protection. The new law calls it “special category data”. This data is about for example:
- Ethnic origin
- Sexual orientation
We only use this type of data where it is necessary, lawful and fair to do so, for example to allocate appropriately, resolve anti-social behaviour, provide help and protection to you and to sustain tenancies.
When we collect sensitive data we will let you know how we will use it, including who it may be shared with.
Some of our properties, communities and offices have CCTV to deter crime and anti-social behaviour and to promote public safety. Footage from Pobl CCTV cameras is only retained for a maximum of 40 days, except where the law allows us to keep them for longer, for example, to support legal action to stop crime or anti-social behaviour.
Why do we process personal information?
We process personal information to allow us to carry out a range of functions that are within our legitimate interests as a social landlord and letting agency, including to:
- Make allocations
- Manage tenancies or leases
- Receive rent and service charges
- Ensure bills and benefits, including welfare benefits and housing benefit/Universal Credit are accurate and paid accordingly
- Provide a repairs and maintenance service, including upgrading and adapting properties
- Offer help with debt and benefits
- Provide support services and initiatives which help people achieve their goals and ambitions
- Provide intervention services to help people retain their tenancies or keep them safe
- Prevent and detect crime and resolve anti-social behaviour
- Engage with customers to make improvements to our services
- Promote equal opportunities and fair treatment of customers
- Deal with complaints and queries
- Provide information (e.g. about opportunities and services) that you request from us and that we offer
- To safeguard our staff
- Property Management
In some circumstances we require your consent to process your personal information. For example, when using your photograph in publications or when you want to engage with an optional service such as receiving debt advice. Where we require your consent we will make this clear to you and will not process your information unless you give us your consent. You will then be given the opportunity to withdraw your consent at any time.
Who do we share your information with?
Your personal information will be kept secure and confidential. Usually we will not disclose personal information without your consent, unless where the law requires us to do so, or where it is necessary for us to do so, for example, to manage your tenancy, provide support or deliver a service. We may share information within the Pobl Group, with contractors, utility companies, third parties or other agencies we work with, for example, Local Authorities, support agencies, Police, the Courts, other landlords and Health bodies but only where it is fair & lawful to do so.
We share some of your personal data with Experian, a consumer credit reporting agency. This is to help us prevent and detect fraud and illegal subletting and to manage our rental arrears. We also receive information about you from Experian for the same purposes. We process this information to fulfil our legal obligations and to prevent and detect unlawful acts.
As part of the Rental Exchange Programme, we share your rental payment history with Experian. This programme allows tenants with a history of little or no credit, who are paying their rent on a regular basis, to build up their credit history. You can opt out of the Rental Exchange Programme at any time by contacting us.
We exchange information as part of the Rental Exchange Programme because it is in our legitimate interests to do so. This data is held on Pobl’s and Experian’s secure systems.
Not only will we be able to work with you more closely to manage your tenancy agreement, your track record as a tenant will enable Experian to use the information supplied to them to assist other landlords and organisations to:
- assess and manage any new tenancy agreements you may enter into;
- assess your financial standing to provide you with suitable products and services;
- manage any accounts that you may already hold, for example reviewing suitable products or adjusting your product in light of your current circumstances;
- contact you in relation to any accounts you may have and recovering debts that you may owe;
- verifying your identity, age and address, to help other organisations make decisions about the services they offer;
- help to prevent crime, fraud and money laundering;
- screen marketing offers to make sure they are appropriate to your circumstances;
- for Experian to undertake statistical analysis, analytics and profiling,
- and for Experian to conduct system and product testing and database processing activities, such as data loading, data matching and data linkage.
If you would like to see more information on these, and to understand how the credit reference agencies each use and share rental data as bureau data (including the legitimate interests each pursues) this information is provided in this link: www.experian.co.uk/crain (Credit Reference Agency Information Notice (CRAIN)). (For a paper copy, please get in touch with us or with Experian using the contact details in this letter).
If you would like more information about your data protection rights, please contact us or the Information Commissioner’s Office (ICO) at www.ico.org.uk
How long do we hold your information for?
We hold personal information about tenants and their household members for the length of their tenancy and for a maximum of 6 years after the end of the tenancy. At the end of this time we will securely dispose of your personal information
How do we store your information?
We store your personal information in electronic and paper filing systems at our offices and in secure off-site storage facilities. We do not transfer or store your data outside of the Europe Economic Area.
Accessing your information
You have the right to request copies of the information we hold about you. If you would like copies of specific information, please contact us and we will respond to you.
Please contact Gillian Owen Gillian.firstname.lastname@example.org. if you need more details about the Subject Access Request process. We do not charge for this request and the information will be provided within a calendar month.
What rights do you have?
You have a number of rights under the General Data Protection Regulation (GDPR).
- The right (in some circumstances) to ask us to correct or complete the personal data we hold about you.
- In some circumstances to have your personal data deleted.
- In some circumstances to stop or block our processing of your data.
- To lodge a complaint to a supervisory authority – the Information Commissioner’s Office (UK). For more information on individuals rights you may wish to visit the ICO website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ )