Resident Privacy Notice

HYELM – RESIDENT PRIVACY NOTICE

How we use your personal information

The privacy and security of your personal information is important to us
Through your relationship with us, we hold and process personal information about you. This
is subject to data protection legislation.

This privacy notice explains how and why we use your personal data and summarises your
rights. Our aim is that you stay informed and can be confident about giving us your
information. We’ll never sell your personal data and will only share it with organisations we
work with when it is appropriate and necessary to our duties as landlord and provider of
housing and the privacy and security of your data is assured.

We’ll keep this privacy notice updated to show you all the things we do with your personal data
and we’ll let you know about any key changes that affect you.

This privacy notice applies to you if you are a current or former resident or if you are applying
to us or contact us about becoming a resident.

The type of information we collect depends on the context and our needs. As a resident, we
will collect and process information about you to ensure that we provide you with appropriate
housing and, if relevant, support and to comply with the terms of your tenancy agreement with
us.

Information may include matters such as your contact details, financial information (including
the receipt of benefits), or mental or physical health information (including whether you have
any disabilities we should be aware of). We may also need to collect certain information to
meet our statutory and regulatory obligations.

We ensure that the information we hold about you is only used for the purposes it was
obtained for, and only kept for as long as is necessary for those purposes. We may need to
share some information with third parties, such as Local Authorities, benefits departments, our
repairs and maintenance contractors, government departments as required and the
emergency services.

You have various rights in relation to your personal data, including the right of subject access
or to make a complaint to the regulator, the Information Commissioner’s Office (ICO).
This is a brief overview which is explained in more detail below. The rest of this notice is split
into sections to make it easier to understand.

If you have any queries about this notice, please contact us.

Who are ‘we’?

In this notice, whenever you see the words ‘we’, ‘us’, ‘our’ or ‘HYELM’, it refers to HYELM.
HYELM is a Company registered in England at Companies House (Number 00244598), a
Charity registered by the Charity Commission (Number 215575) and a Registered Social
Landlord regulated by the Regulator of Social Housing (Number HO312).

Our ICO registration number is Z7873038.

As a housing provider, our normal activities for our residents can be summarised as:

• Providing affordable rented housing.
• Property, grounds maintenance and upkeep at our properties.
• Managing housing tenancies as a landlord

We also provide additional services, including:

• Organising and assisting community events.
• Offering opportunities to be involved.
• Providing advice.

Contacting us

If you have any questions in relation to this document or how we use your personal data they
should be sent to HYELM’s Data Protection Officer, who is the Company Secretary:

By email:
[email protected] – mark the subject line for the attention of the Data Protection Officer

By post:
Company Secretary
HYELM – Old Street
43-51 New North Road
London
N1 6JB

Who the personal information relates to

We collect and process personal information about residents. This includes current and former
residents (and those who apply to us or contact us about becoming residents) of our
properties or access our services. They may include members of their family and people
associated with them

How we collect personal information

We collect information in a variety of ways.
As a resident, you will give us personal data when you apply for a tenancy or sign-up and in
the ordinary course of your tenancy. You may also use our website or other social media
functions, correspond with us or take part in research.

We also collect information through our ongoing contact and correspondence with you, from
people associated with you such as family, friends and neighbours and, if relevant, from third
parties such as a Local Authority.

At our properties we have Closed Circuit Television (CCTV) surveillance cameras in in public
areas, external entrances and courtyards / terraces.

If you provide us with personal information relating to members of your family or your
associates, we will assume that you do so with their knowledge and consent.

It is important that you notify us of any changes to your or other’s personal information as soon
as possible so that we can contact you easily and keep our records up to date.

We may record, monitor, use and store CCTV recordings, email or other communication you
provide, or we collect for legitimate purpose. This includes checking any instructions or
requests given to us, training purposes such as learning from complaints and to improve the
quality of our customer service.

What information we hold about you

When you apply to become a resident, we obtain information to determine your housing
needs.

You will provide us with information through your application form. We will also use information
from your employer or referral agent to help us to assess your application.

We will generally hold the following information from residents:

• Full name including proof of your identity / photo ID.
• Date of birth.
• National Insurance number.
• Contact details, including address of property at which you live and telephone, email and
  other contact address.
• Names, contact details and other relevant personal details of any permitted occupiers.
• Banking details if you make payments to us.
• Benefit and Council tax information.
• Proof of housing eligibility which will include current and former employment details such
  as name of your employer, your job title and description, annual salary, bonuses and
  contract type.

Other personal information may be collected in order to help us manage your tenancy
including dealing with any alleged breaches, anti-social behaviour or suspected fraud.

We may also hold additional information from you concerning:

• Disabilities or vulnerabilities – We use this information to provide you with an appropriate
  service and, if relevant, to tailor that service to better meet your needs. We may also use
  this information for safeguarding of staff.
• Financial information – Financial data including payment and non-payment of rent and
  other sums due. It is important that in order to ensure that any arrears payments are
  settled quickly, therefore we may collect information to help us to work out a plan with
  you. In addition, to provide welfare, benefits and debt advice as a free service to help you
  budget, pay your bills, or to support an application for funding.
• Identification – Photo ID, bank statements, payslips or income details. We will record
  information when you contact us or use our services (or if we contact you). We note any
  action taken, for example logging repairs, and feedback from our contractors about
  appointments with you, so that we have a record of what happened and of our contact
  with you.

CCTV and photographs

Our properties have CCTV surveillance cameras in the public areas, external entrances and
courtyards / terraces. You will be recorded when you move through our communal spaces.

CCTV is used to provide security and to protect users of our properties (including residents,
their families and friends, staff, contractors and visitors. CCTV will be only be viewed when
necessary (e.g. to detect or prevent crime). Video is stored for 30 days after which it is
deleted. If an incident has been captured this footage may be retained for a longer period.

HYELM complies with the Information Commissioner’s Office CCTV Code of Practice and we
put up notices so you know that CCTV is used within our properties.

We may take photographs at our events, at our properties and in our communities to use for
general marketing and publicity. However, photographs focused on specific individuals will
only be used for those purposes with your consent.

Purposes for which we use your personal information

We use your personal information for the following purposes:

• To assess and deciding on your application for housing.
• To enter a tenancy contract (and to renew it).
• To manage the contract and, more generally, your tenancy. This is likely to include:
  • Collecting rent and other charges and dealing with and recovering any arrears.
  • Carrying out and scheduling repairs and liaising with contractors.
  • Making contact if there is an emergency.
  • Handling any complaints.
  • Dealing with contractors.
  • Dealing with allegations of criminal offences including fraud.
• Communicating with a view to meeting your needs and our business objectives.
• Encouraging social inclusion and building communities.
• Working with the local authorities and other agencies such as the policy to support a safer
  community and environment free from anti-social behaviour and criminal activity.
• Considering and making service adjustments to support persons with disabilities.
• Seeking to monitor services we provide and, if relevant, improve them by obtaining and
  analysing feedback on services.
• Updating you on additional services that we may offer and if you wish providing those
  services.
• Providing a newsletter and similar communications.
• Monitoring equality, diversity and inclusion. Any such information will not inform a
  decision made about you individually but will be aggregated and used for statistical
  purposes to assess our services with a view to achieving fairness.

Legal bases for processing

The processing set out above is necessary for the purposes of our legitimate interests or
those of third parties. These interests include:

• Managing our properties efficiently and effectively in the interests of all residents and
  potential residents.
• Administering our business and operation and communicating with residents and others.
• Meeting the needs of residents and other in the community including avoiding and dealing
  with anti-social or illegal behaviour.
• Contacting residents in the event of emergencies and to carry out repairs.

Information used in connection with creating and managing your tenancy is processed
because it is necessary for the purposes of your tenancy contract (or to enter into that
contract).

In some circumstances processing may be necessary to comply with legal obligations such as
duties under the Equality Act 2010 and under health and safety legislation.

In general, we do not rely on your consent as a ground for processing. In specific
circumstances and with your agreement we may do so.

Special category data

Under data protection legislation certain personal information is classified as “sensitive” or
“special category” personal data. This includes information relating to racial or ethnic origin,
physical or mental health, sex life or sexual orientation, religious or philosophical beliefs,
political opinions, membership of a Trade Union, allegations of criminal offences and criminal
convictions and offences, along with biometric data such as fingerprints.

We minimise our holding and use of sensitive categories of personal information but, given the
services we provide, there are times when we use it to understand our residents and their
needs better, for example when providing accommodation for disabled persons or when
resolving neighbourhood disputes involving alleged criminal activity.

We will usually be processing this information to allow us to comply with our legal obligations,
act in the substantial public interest in relation to the services we provide or to deal with any
legal action.

There may be times where we need to ask you for your consent to use this type of personal
information, in which case we will always notify you and make this clear.

Sharing your information

Your personal information will be kept secure. Our staff have restricted access to personal
information on a “need to know” basis.

We may share information with third parties, including contractors we work with such as our
repairs and maintenance contractors, agencies and authorities we work with, such as Local
Authorities and the Police.

Our third party cloud hosting and IT infrastructure providers are data processors who process
information on our behalf.

We will share certain information in appropriate circumstances with our regulators and funders.
We will also share relevant information with others when HYELM believes it is in your, or the
public’s, interest to do so, such as to keep residents, staff or safe, or members of the public as
required by law.

In particular, please be aware:

• Current or forwarding addresses may be shared with utility companies and Council Tax
  offices to ensure that any contractual relationships are managed.
• If you default on any tenancy conditions, information about you may be provided to
  authorised debt recovery agencies, to enable them to recover the debt. This may affect
  future applications for tenancies, credit and insurance. Information may also be provided
  to our legal advisors in connection with claims and recovery.
• We may discuss your financial situation, rent payments (including any arrears) and any
  claims made for welfare benefits with an external debt advice agency, welfare rights
  advisor, the housing benefit department or the Local Authorities’ housing advice and
  homeless prevention team to make sure that benefits are paid correctly.
• We may pass data about your rent payment record to credit reference agencies. This will
  enable them to assist other organisations to assess your financial standing if you apply for
  products and services.
• We may pass your contact information to a third party to conduct surveys and research on
  our behalf which allow us to gather feedback and improve the services we offer you. The
  third party will be bound to strict terms and conditions outlined by us and will not share
  your data with other organisations. Should you choose not to participate in the surveys the
  third party will securely destroy your data.
• We may share your National Insurance number to verify your Universal Credit application
  and manage these payments and to prevent and investigate tenancy fraud.

When we allow third parties acting on behalf of HYELM to access to your information, we will
always have complete control of what they see, how long they see it for and what they are
allowed to do with it.

We do not sell or share your personal information for other organisations to use.

How we secure your data

Information system and data security is imperative to us to ensure that we are keeping your
data safe.

We operate a robust and thorough process for assessing, managing and protecting new and
existing systems which ensures that they are up to date and secure against the ever-changing
threat landscape.

Personal information is stored and managed within IT software systems using hardware which
are maintained to achieve a high level of security. We hold information in IT systems which
may be copied for testing, backup, archiving and disaster recovery purposes.

Our employees complete mandatory data protection training on a regular basis to reinforce
responsibilities and requirements set out in our policies. Only those staff members and third
parties who require access to your information will be able to access it.

When you trust us with your data, we will keep your information secure. By utilising strong
encryption when your information is stored or in transit, we minimise the risk of unauthorised
access or disclosure; when entering information on our website, you can check this is secure
by right clicking on the padlock icon in the address bar.

HYELM are based in the UK and we store most of our data within the European Union (EU).
Some organisations which provide services to us may transfer data outside the European
Economic Area, but we will only allow this if your data is adequately protected.

How long do we keep your information?

We will only use and store your information for as long as it is required for the purposes it was
collected for. How long information will be stored for depends on what it is being used for.

Sometimes we may also need to keep information for statutory or regulatory purposes or to
deal with any legal claims.

Data collected will be stored in line with the guidelines issued by the National Housing
Federation. In exceptional cases other timescales will be used and the reasons recorded.

Your rights

You have various rights in your personal data including the right:

• to ask us for access to information about you that we hold.
• to have your personal data rectified, if it is inaccurate or incomplete.
• to request the deletion or removal of personal data in certain circumstances – for example
  where processing is no longer necessary in relation to the purposes for which they are
  processed.
• to restrict our use of your personal data (i.e. permitting its storage but nothing further) in
  certain circumstances – for example where processing is unlawful, but you oppose its deletion.
• to request that we transfer your information directly to a new landlord or other third party.

These rights are subject to statutory conditions. Further information appears on the Information
Commissioner’s website at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individualrights/

If you would like further information or to exercise any of these rights, please contact us.

Consent

We may sometimes process your data for specific purposes which require your consent. If we do
this, we will always ask for your specific consent.

Where we are processing your personal data based on your consent, you have the right to
withdraw that consent at any time. This may affect the services that we can make available to you,
but this will be explained to you.

Please contact us if this is the case.

Complaints or concerns

If you are unhappy with our use of your personal data, or anything in this notice, please talk to us
directly so we can help to resolve any problem or query.

You also have the right to raise any concerns with the Information Commissioner’s Office (ICO).
They can be contacted by post:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

By calling 0303 123 1113 or by email [email protected]
Their website is www.ico.org.uk