Updated November 2024
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1. Introduction and scope
Westward Housing Group is committed to protecting the privacy and personal data of all those whose data we are handling and to working within the guidelines set out by data protection law.
This privacy notice sets out why we collect personal information from you, how we use it and who we may share it with. It also explains how you can exercise the rights you have set out in the law and how you can contact us if you have any concerns or questions about data protection.
We may change this notice by updating it on our website. You should check the notice from time to time to ensure that you are happy with any changes.
2. Data Controller and Data Protection Officer
The legal data controller is Westward Housing Group. We are a Housing Association regulated by the Regulator of Social Housing.
Westward Housing Group includes Westward Housing Group Ltd and New Horizon Homes Limited (trading as Horizon Homes).
We have appointed a Data Protection Officer who is responsible for ensuring we comply with our legal obligations set out in the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. The Data Protection Officer monitors our data protection compliance and provides advice and guidance as to how we can improve our data handling practices.
Our contact details for data protection purposes are:
Westward Housing Group, Templar House, Collett Way, Newton Abbot TQ12 4PH
Email: dataprotection@westwardhousing.org.uk Telephone: 0300 100 1010
Westward Housing Group is registered with the Information Commissioners Office as a Data Controller. Our registration number is: ZA190046.
3. Your rights
The UK GDPR grants you certain rights (‘information rights’) which we summarise below:
Your rights
| Right of access and of data portability |
You have the right of access to information we hold about or concerning you and/or to have it transferred to another data controller in some circumstances. If you would like to exercise this right, you should contact our Data Protection Officer. |
| Right of rectification or erasure |
If you feel that any data that we hold about you is inaccurate you have the right to ask us to correct or rectify it. You also have a right to ask us to erase information about you where you can demonstrate that the data, we hold is no longer needed by us, or if you withdraw the consent upon which our processing is based, or if you feel that we are unlawfully processing your data. Your right of rectification and erasure extends to anyone we have disclosed your personal information to, and we will/shall take all reasonable steps to inform those with whom we have shared your data about your request for erasure. |
| Right to restriction of processing |
You have a right to request that we refrain from processing your data where you contest its accuracy, or the processing is unlawful and you have opposed its erasure, or where we don’t need to hold your data anymore but you need us to in order to establish, exercise or defend any legal claims, or we are in dispute about the legality of our processing your personal data. |
| Right to object |
You have a right to object to our processing of your personal data where the basis of the processing is our legitimate interests including but not limited to direct marketing and profiling. |
| Right to withdraw consent |
You have the right to withdraw your consent for the processing of your personal data where the processing is based on consent. To withdraw consent please email us or reply to the most recent electronic marketing communication you have received. |
| Right of complaint |
You also have a right to lodge a complaint about any aspect of how we are handling your data with the UK’s Information Commissioner’s Office who can be contacted at www.ico.org.uk |
If you would like to exercise any of your above rights, please make your request in writing to: Data Protection Officer at dataprotection@westwardhousing.org.uk or alternatively by post to Westward Housing, Templar House, Collett Way, Newton Abbot, TQ12 4PH.
4. Information we may collect about you
The personal information we collect will depend on our relationship with you and the services we are providing. We will only collect the information necessary to fulfil our obligations to you and in accordance with the legal bases set out below.
As a social housing provider, employer and provider of support services and home ownership products, we collect information about:
a) 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)
b) employees and volunteers
c) board members
d) other stakeholders and business partners, such as contractors, suppliers, visitors and members of the public (including MPs and councillors)
We collect, create and otherwise obtain and process the following types of personal data:
a) personal identifiers such as name and contact details (including email, telephone numbers and your current, previous and forwarding addresses)
b) identification information (including your age and gender)
c) family details (including next of kin and marital status)
d) financial information (including your income, welfare benefit entitlements and bank account details)
e) national identifiers (including National Insurance or social security number)
f) education and employment details
g) online identifiers (including IP address or cookies)
h) device identifiers (for example identifiers for a smartphone)
i) photographs, CCTV images, films and telephone recordings
j) whistleblowing (confidential reporting) information
k) vehicle telematics
We may also collect ‘sensitive’ personal data such as:
a) ethnicity
b) religious beliefs or other beliefs
c) physical or mental health or condition
d) sexual life or orientation
e) risks to children or other people
f) criminal convictions or offences
g) trade union membership (in relation to our staff)
h) 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).
5. How we collect information
We collect information in a variety of ways.
You can give us personal data by filling in forms provided by us, for example at tenancy sign-up, by registering to use our customer portal, by subscribing to take part in research on our website or other social media functions, or by corresponding with us (by phone, email, video triage, text message, web forms, chat bot and web chat or by joining us as a customer).
We also collect information through our ongoing contact and correspondence with you, and with other support agencies which relate to you, and from people associated with you such as family, friends and neighbours.
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, you will not be required to read your bank card details to us. You will instead be prompted to enter the details using a phone keypad in order to keep the information private and protected.
Use of Westward’s email system may be recorded by Westward on its communications systems. Any records made shall, at all times, remain the property of Westward.
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.
Westward uses software to allow our staff to send a secure one time use SMS or email to enable live video or images to be streamed from a customer’s mobile device back to the staff member. The current purpose is to aid property maintenance and repairs diagnostics and to accelerate the appropriate response, although it may be used for additional purposes in future. Terms and conditions will be provided to the customer, and their consent obtained to proceed, before filming is commenced.
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.
To help investigate complaints of anti-social behaviour such as noise nuisance, customers can download the Noise App onto their personal mobile devices. Westward can access recordings that have been uploaded to the secure Noise App website by a customer, and these recordings may be used in the investigation of anti-social behaviour. For more information, please visit https://sso.rheglobal.com/services/1/licences/tos
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.
6. How we use your information
We collect and process your information because you have entered or wish to enter into a contract (occupancy 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 you have requested from us.
There will also be times when processing personal information is necessary for a legitimate interest pursued by Westward Housing Group or a third party. Where processing is being carried out because of a legitimate interest, this will be set out in the privacy notice. Some of the information that we hold will be with your consent – we will always make it clear when this is the case, and also explain how you can withdraw your consent.
We are legally allowed to collect information for a number of different reasons:
a) performance of a contract (such as tenancy agreement or contract of employment)
b) compliance with law (such as providing evidence or information to the courts, or our regulators)
c) consent (such as customer consent for photos or films)
d) vital interests (in other words, a life-or-death situation)
e) 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)
f) work carried out in the public interest (such as homeless support contracts)
In general, the information we hold helps us to:
a) 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)
b) understand your needs and provide you with an appropriate service
c) effectively manage our internal records
d) provide you with information about services
e) provide you with the marketing information you have requested
f) keep information that is up to date and accurate
g) improve our products and services
h) occasionally contact you (by email, phone or mail) for market research purposes
i) customise the website according to your interests
j) comply with our legal and regulatory obligations
k) support government initiatives (such as the National Fraud Initiative)
l) promote our business
m) promote equality, diversity and fair treatment
n) protect people and our assets (such as ensuring the health, safety and wellbeing of you and others)
We record telephone calls for training and monitoring purposes. Callers to our customer facing group telephone numbers are informed about this via an automated message at the beginning of each incoming telephone call. Recordings of calls may be used by us:
- for staff training to develop confidence and potential of staff
- to check and measure whether we meet standards agreed with residents
- for use in appraisals with staff to develop customer service
- as evidence where there are disputes
- as evidence in investigations concerning either our customers or staff
- to resolve complaints regarding abusive telephone calls involving either our customers or staff
- to ensure staff compliance with procedures and best practice, or where misconduct is suspected
Any recordings made shall at all times remain the property of Westward.
We do not currently use your information for profiling with legal, or similarly significant, effects and/or automated decision-making.
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:
a) determine your housing needs and make allocations of accommodation
b) manage tenancies (including collecting rent and service charges)
c) provide a repairs and maintenance service
d) provide home ownership products
e) offer help with debts and benefits
f) provide support services (often in conjunction with other agencies such as social services)
g) keep in touch, understand your needs and preferences, and invite you to events
h) prevent and detect crime and resolve disputes
i) prevent and detect fraud and money laundering
j) promote safety and the ‘quiet enjoyment’ of neighbourhoods and communities
k) engage with you and make improvements to our products and services
l) develop new products and services to meet the needs of communities
m) provide a customer incentive scheme
n) promote our services and business
o) highlight health and safety or wellbeing issues
HOME OWNERSHIP CUSTOMER INFORMATION
What we do with the information we gather
This includes open market purchases, etc.
Horizon Homes builds high quality homes for sale on the open market.
We may use the information you give us:
a) to provide a service that you request or to perform a contract to which you are party (for example, buying a home from us)
b) to understand your needs and provide you with a better service
c) for internal record keeping
d) to improve our products and services
e) we will only send you marketing information where you have requested it; you can opt out at any time
f) to occasionally contact you (by email, phone, or mail) for market research purposes
g) to customise the website according to your interests
h) to comply with our legal and government contract obligations
STAFF AND VOLUNTEERS
What we do with staff and volunteer information
Keeping staff and volunteer records allow us to:
a) assess job applications
b) consider appropriate skills, experience, learning and development required
c) manage the employment or volunteer contract
d) provide you with access to our IT systems
e) pay remuneration and expenses
f) fulfil our legal and regulatory obligations (including funders requirements, company law, social housing and charity regulations, etc.)
g) verify your identity
h) ensure your health and safety, and wellbeing
i) promote our services and business
j) verify remote access to our systems to keep them secure
k) monitor Westward lease vehicle driver behaviour
l) ensure compliance with procedures and best practice
m) investigate any suspicions of misconduct
BOARD MEMBER INFORMATION
What we do with board member information
Keeping board member (non-executive director) records allow us to:
a) assess applications for board membership
b) consider appropriate skills, experience, learning and development required for the board to operate
c) fulfil our legal and regulatory obligations (including funders requirements, company law, social housing and charity regulations, etc.)
d) manage the ‘agreement for services’ (which is a legal contract)
e) provide access to our paperless board system
f) pay remuneration and expenses
g) 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:
a) engage with the wider community about our homes and services
b) ensure health and safety
c) monitor feedback on our services
d) keep up to date records on power of attorney and next of kin
e) respond to correspondence and complaints
f) set up and manage contracts
7. How we store and safeguard your information
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. In addition to this, we follow a defence in-depth security model, which means that your data is protected by multiple layers of security.
Personal information is stored and managed within a variety of IT software systems which are maintained to achieve a high level of security and confidentiality. We hold information in IT systems which may be copied for testing, backup, archiving and disaster recovery purposes.
Our employees complete mandatory information security and data protection training at the start of their employment, and annually thereafter to reinforce responsibilities and requirements set out in our information security 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 always keep your information secure to maintain your confidentiality. 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.
Westward Housing Group is 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’ll only allow this if your data is adequately protected in compliance with relevant data protection laws.
8. Sharing your information
Your personal information will be kept secure and confidential. 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, third party cloud hosting and IT infrastructure providers, agencies and authorities we work with, such as Local Authorities, Social Services, Police, and other social landlords.
We will share certain information in appropriate circumstances with our regulators or funders. We will also share relevant information with others when Westward Housing Group believes it is in your, or the public’s, interest to do so, e.g. to keep customers, staff or visitors safe, or as required by law.
In particular, please be aware:
a) Current or forwarding addresses may be shared with utility companies and Council Tax offices to ensure billing details are correct.
b) If you default on any tenancy/licence 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.
c) 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.
d) 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.
e) 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.
f) We may share your National Insurance number to verify your Universal Credit application and manage these payments and to prevent and investigate tenancy fraud and right to buy applications fraud.
When we allow third parties acting on behalf of Westward Housing Group 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.
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.
9. Data retention
We will hold information about you in our data systems only for as long as we need to hold it which is generally as follows:
a) 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.
b) Unsuccessful applications will be deleted within six months.
c) Telephone calls are kept for up to six months, any that are deemed abusive or threatening are kept until any investigation action is completed.
d) CCTV images are retained for up to two months or, where applicable, until any investigative action is completed.
e) 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 annually and dispose of information securely.
10. 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
11. 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
12. Direct marketing
We would like to provide you with information about events, services and other information which we think you may find useful and/or interesting. We may send you such information by post, or email or we may 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.
13. 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.
14. Third-party content within our website
From time to time, we may embed external content from third-party websites, for example X (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.
You can view our Privacy Notice - Easy Read format here — Easy read privacy notice | Westward
