Privacy notice

Privacy Notice

This privacy notice sets out how Westward Housing Group collects, uses and protects your information. Westward includes:

• Westward Housing Group Ltd
• New Horizon Homes Ltd (trading as Horizon Homes)

We are committed to ensuring your privacy is protected and:

• data is kept safe and secure
• data is handled legally, responsibly and ethically
• we are open and transparent about what data we are using and why
• we only collect what we need

We may change this privacy notice by updating it on our website – this current notice is effective from 25 April 2023 (previous versions are available on request); you should check from time to time to ensure you are happy with any changes.

The information provided in this notice gives an overview and examples of data processing, it does not necessarily include every scenario.  If there is anything you don’t understand or you have any feedback on this notice, please contact the Data Protection Officer dataprotection@westwardhousing.org.uk or see our Data Protection Policy. 

Shortcuts to the contents:

• What information we hold
• How we collect information
• How we use information
• What we do with customer information
• What we do with the staff and volunteer information
• What we do with board member information
• How we store your information
• Sharing your information
• How long we keep your information
• On our website
• Your rights
• Queries and complaints

What information we hold

As a social housing provider, employer and provider of support services and home ownership products, we collect information about:

• customers (including current, former and potential customers who live in our properties or access our support and other services; this includes members of their family and people associated with them)
• employees and volunteers
• board members
• other stakeholders and business partners, such as contractors, suppliers, visitors and members of the public (including MPs and councillors)

The types of information we collect may include:

• name and contact details (including email, telephone numbers and your current, previous and forwarding addresses)
• identification information (including your age and gender)
• family details (including next of kin and marital status)
• financial information (including your income, welfare benefit entitlements and bank account details)
• national identifiers (including National Insurance or social security number)
• education and employment details
• online identifiers (including IP address or cookies)
• device identifiers (for example identifiers for a smartphone)
• photographs, CCTV images, films and telephone recordings
• whistleblowing (confidential reporting) information
• vehicle telematics

We may also collect ‘sensitive’ personal data such as:

• ethnicity
• religious beliefs or other beliefs
• physical or mental health or condition
• sexual life or orientation
• risks to children or other people
• criminal convictions or offences
• trade union membership (in relation to our staff)
• biometric and genetic data (in relation to our staff who need to access electronic devices)

We minimise collection and use of sensitive information, however, given the services we provide, there are times when we use it to understand our customers and their needs better (such as providing accommodation for customers with disabilities or when dealing with neighbourhood disputes involving alleged criminal activity).

How we collect information

We collect information in a variety of ways including forms, contracts, email, in writing, over the phone, face to face, online, CCTV, photos, etc.  The information may be supplied by you or by another source such as family, neighbours, police 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 (such as ‘complaint resolved’).

Calls to and from our Customer Enabling Hub and some calls with Westward Property Services might be recorded 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 and communal areas for crime prevention and safety purposes.  We may also collect data from fobs used to access our office and residential buildings.

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 or national newspapers.  We ask customers for their consent to be included in a photograph or film.  Staff/volunteers and board members can request to opt out.

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

How we use information

We are legally allowed to collect information for a number of different reasons:

• legal contract
• compliance with law
• consent (such as customer consent for photos or films)
• vital interests (in other words, a life or death situation)
• legitimate interest (where we believe our reasons for using your data outweigh your rights and freedoms; such as when we record phone calls to monitor and improve our performance)
• work carried out in the public interest (such as homeless support contracts)

In general, the information we hold helps us to:

• provide a service you request or to perform a contract to which you are party (such as a tenancy agreement, sales contract, support contract, employment or board member contract)
• understand your needs and provide you with an appropriate service
• effectively manage our internal records
• provide you with information about services
• provide you with the marketing information you have requested
• keep up to date and accurate information
• improve our products and services
• occasionally contact you (by email, phone or mail) for market research purposes
• customise the website according to your interests
• comply with our legal and regulatory obligations
• support government initiatives (such as the National Fraud Initiative)
• promote our business
• promote equality, diversity and fair treatment
• protect people and our assets (such as ensuring the health, safety and wellbeing of you and others)

We do not currently use your information for profiling with legal or similarly significant effects and/or automated decision-making.

No data is transferred outside of the EU unless it is covered by the safeguards set out by the Information Commissioners Office (for example the organisation signs up to ‘Privacy Shield’).

In the sections below we have more details about the information we collect from specific groups of people, such as customers, employees, board members, etc.

CUSTOMER INFORMATION

What we do with customer information

Keeping customer records allows us to:

• determine your housing needs and make allocations of accommodation
• manage tenancies (including collecting rent and service charges)
• provide a repairs and maintenance service
• provide home ownership products
• offer help with debts and benefits
• provide support services (often in conjunction with other agencies such as social services)
• keep in touch, understand your needs and preferences, and invite you to events
• prevent and detect crime and resolve disputes
• prevent and detect fraud and money laundering
• promote safety and the ‘quiet enjoyment’ of neighbourhoods and communities
• engage with you and make improvements to our products and services
• develop new products and services to meet the needs of communities
• provide a customer incentive scheme
• promote our services and business
• highlight health and safety or wellbeing issues

STAFF AND VOLUNTEERS

What we do with the staff and volunteer information

Keeping staff and volunteer records allow us to:

• assess job applications
• consider appropriate skills, experience, learning and development required
• manage the employment or volunteer contract
• provide you with access to our IT systems
• pay remuneration and expenses
• fulfil our legal and regulatory obligations (including funders requirements, company law, social housing and charity regulations, etc.)
• verify your identity
• ensure your health and safety, and wellbeing
• promote our services and business
• verify remote access to our systems to keep them secure
• monitor Westward lease vehicle driver behaviour

As a customer facing employee, we need to know that our staff are vaccinated against COVID-19 in order to protect our vulnerable customers and fulfil our health and safety requirements.

We are collecting the date of your first and second vaccination; this information will be collected by your manager and held by HR securely. It will be kept for a period of two years, then we will review the pandemic situation and only continue to keep it if it is required to protect our vulnerable customers and fulfil our health and safety requirements – we will update you at this point.

BOARD MEMBER INFORMATION

What we do with board member information

Keeping board member (non-executive director) records allow us to:

• assess applications for board membership
• consider appropriate skills, experience, learning and development required for the board to operate
• fulfil our legal and regulatory obligations (including funders requirements, company law, social housing and charity regulations, etc.)
• manage the ‘agreement for services’ (which is a legal contract)
• provide access to our paperless board system
• pay remuneration and expenses
• verify your identity

OTHER STAKEHOLDER INFORMATION

What we do with other stakeholder information

Keeping other stakeholder information (including business partners, such as contractors, suppliers, visitors, members of the public, MPs and councillors) allow us to:

• engage with the wider community about our homes and services
• ensure health and safety  
• monitor feedback on our services
• keep up to date records on power of attorney and next of kin
• respond to correspondence and complaints
• set up and manage contracts

HOME OWNERSHIP CUSTOMER INFORMATION (including open market purchases, etc.)

Horizon Homes builds high quality homes for sale on the open market.

What we do with the information we gather

We may use the information you give us:

• to provide a service that you request or to perform a contract to which you are party (for example, buying a home from us)
• to understand your needs and provide you with a better service
• for internal record keeping
• to improve our products and services
• we will only send you marketing information where you have requested it; you can opt out at any time
• to occasionally contact you (by email, phone, or mail) for market research purposes
• to customise the website according to your interests
• to comply with our legal and government contract obligations

How we store your information

Some information is stored on paper, but mostly it is stored electronically.  In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information.

Sharing your information

We only share your information where we are legally entitled to do so, such as:

• to provide you with the services you require (such as repairs and maintenance contractors)
• to comply with the law
• to seek legal advice or in connection with court proceedings or statutory action to enforce compliance with tenancy conditions
• child protection and safeguarding issues
• where there is a health and safety risk or other risk to yourself, staff and others
• where you have provided consent (such as customer consent for photos or films)

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

• Police
• HMRC
• NHS and Primary Care trusts
• Partner landlords
• Legal advisors, the courts, our insurers and auditors
• Health professionals
• Contractors providing maintenance and other housing related services
• Consultants providing services to us
• Utility and telephone companies
• Supporting People administrative authorities
• Local Authorities, government regulators and agencies (such as the Department of Work and Pensions, Regulator of Social Housing or Homes England)
• Credit checking agencies and debt recovery agents
• Charities and voluntary organisations and our support partners

In particular, customers need to be aware:

• current or forwarding addresses may be shared with utility companies and local authority council tax departments to ensure billing details are correct
• if you default on tenancy/licence conditions, information about you may be provided to authorised debt recovery agencies to enable them to recover the debt and/or may be shared with other landlords as part of a reference; this may affect your future applications for tenancies, credit and insurance
• 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, government welfare and benefits agencies, or local authority housing advice and homeless prevention teams to make sure benefits are paid correctly
• we may pass your contact information to a third party to conduct surveys and research on our behalf to improve the services we offer and to comply with the Regulator of Social Housing’s Tenant Satisfaction Measure Standard, which requires us to process information from Tenant Perception Surveys to ensure effective scrutiny by tenants of their landlord’s performance in managing their homes and neighbourhoods. The third party would be bound to strict terms and conditions outlined by us and in accordance with the Market Research Society’s code of conduct, and they would not share your data with other organisations. You can opt out by contacting us.
• we may pass your email to third parties providing our customer incentive scheme. The third party would be bound to strict terms and conditions outlined by us and would not share your data with other organisations. You can opt out by contacting us.
• we may share your information as part of a safeguarding report where we have concerns about your wellbeing, safety and/or security (this is permitted within safeguarding laws)
• we may share your National Insurance number to verify your Universal Credit application and manage these payments
• we may also share your National Insurance number in order to prevent and investigate tenancy and Right to Buy applications fraud
• in the event of a situation where a member of staff feels vulnerable or in danger, we may activate emergency recording and GPS tracking to ensure the safety and wellbeing of our staff
• we participate in the government’s CORE data gathering scheme that gathers information about new lettings and sales; here is their Privacy Notice that explains more: https://www.cambridge.gov.uk/media/5627/core-privacy-notice.pdf
• we have a partnership with Energy Angels to ensure Energy Suppliers are provided with up to date accurate information on your tenancy; here is their Privacy Notice that explains more: http://energyangels.co.uk/tenant-privacy-notice/  

We do not provide your personal information to other organisations for their marketing purposes. 

We might in some instances anonymise data and share this. For example, feedback obtained in surveys regarding our contractors.  Where personal data has been anonymised, we are not legally required to obtain consent.

Direct marketing

We would like to provide you with information about events, services and other information which we think you may find interesting.  We may send you such information by post, email or contact you by telephone.  You can let us know at any time how you prefer to be contacted or if you do not want us to contact you with this information.

How long we keep your information

We only store your information for as long as is reasonably necessary for us to fulfil the purposes set out in this notice; usually a maximum of six years after you cease to have a relationship with us or if we are in dispute with you until legal proceedings have ended, whichever is longer.

If you have provided information to us in relation to a potential tenancy, or a job or board member vacancy or other contract that turns out to be unsuccessful, we delete the information within 6 months.

Telephone calls are kept for up to 6 months and calls that are deemed abusive or threatening are kept until any investigation action is completed.

CCTV images are retained for up to two months or, where applicable, until any investigative action is completed.

Some basic tenancy information is kept for longer as evidence to support the level of discount available should a former tenant apply for the Right to Buy or Right to Acquire.

We review the information we hold every year and dispose of information securely.

Use of cookies on our website

In using the Westward website, you consent to the collection and use of information, and cookies by both us and our business partners as detailed in our privacy notice.

Cookies are small text files that are placed on your computer by websites you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the website owners.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

Google Analytics

These cookies are used to collect anonymous information about how visitors use our websites. Like many organisations, we use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Click here for an overview of privacy at Google.

To opt out of being tracked by Google Analytics across all websites visit: http://tools.google.com/dlpage/gaoptout

Links to other websites

Our website contains links to other websites that are not controlled by us. Any external links are not Westward’s responsibility and once you click on a link to an external site you will be subject to another organisation’s privacy policy. You should exercise caution and look at the privacy notice applicable to the website in question.

Third-party content within our website

From time to time, we may embed external content from third-party websites, for example Twitter or YouTube, within our websites. These external websites may utilise cookies and the privacy policy that will apply to such third-party content will be that published on the website of that third party content provider.

Your rights

You may request details of the personal information we hold about you, this is known as a subject access request.  We need to verify your identification and have a month to respond.

If you believe information we are holding about you is incorrect or incomplete, contact us and we will investigate and update our information. Tenants can access and update some of their information via a ‘My Account’ on our website: www.westwardhousing.org.uk/myaccount

Under some circumstances, you may have a right to have information erased, restricted and/or prevent us processing your information; please contact us.

You may opt-out of receiving our newsletters and surveys at any time.

If you wish to take a copy of your data across to a new data controller, please contact us.

Please be aware that if you do not provide relevant information, we may be unable to provide you with the services you have requested.

Queries and complaints

If you believe we have not handled your information correctly please let us know first so we can put it right:

Data Protection Officer (DPO) dataprotection@westwardhousing.org.uk or

Westward Housing Group

Templar House

Collett Way

Newton Abbot

Devon

TQ12 4PH

You have the right to contact the Information Commissioner’s Office (ICO):

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

www.ico.org.uk

Tel: 0303 123 1113

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Westward’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests should be sent to the DPO.

If you or someone you know would like this information on CD, in large print, braille, or translated into another language, please contact our Communications Team on 0300 303 8530 or email info@westwardhousing.org.uk

Westward Housing Group information

Westward Housing Group incorporates:

Westward Housing Group Ltd (an exempt charity and Community Benefit Society 7350).  Registered office: Templar House, Collett Way, Newton Abbot TQ12 4PH.  Also at Tarka House, Clovelly Road Industrial Estate, Bideford EX39 3HN. Website: www.westwardhousing.org.uk Email: info@westwardhousing.org.uk. Tel: 0300 100 1010 and fax: 01626 355137.

New Horizon Homes Ltd (trading as Horizon Homes) (Company registered in England and Wales No. 7625039). Registered office: Templar House, Collett Way, Newton Abbot TQ12 4PH. Tel: 01803 219090. Website www.horizonhomes.co.uk Email: info@horizonhomes.co.uk

Legal information

These terms shall be governed by and construed in accordance with English law. By using this website you hereby agree to submit to the exclusive jurisdiction of the English courts.