Who we are
We are Christian Action (Enfield) Housing Association, a Data Controller & processor whose registered address is Benedict House, 61 Island Centre Way, Enfield EN3 6GS. Tel no: 01992 765900.
This is our main privacy notice; we have separate privacy notices for our young people’s services, employees, and people applying to work for us.
Why do we process personal data?
We collect and process personal information in order to deliver services to our customers and we are committed to being transparent about how we collect and use that information and to make sure we meet our data protection obligations.
When we collect personal information about you we will always make sure we:
- process it fairly and transparently and have a valid reason for doing so
- only use your information for the reason it was collected
- only collect the amount of personal information that we need to provide our services
- do our best to make sure your information is accurate and kept up to date
- only keep your personal data for as long as we need it
- keep your information secure and protect it against unauthorised access or accidental loss
What information do we collect about you?
We collect and process a range of information and this will vary according to the type of service we are providing you with. Most of the information we hold will be collected from you directly but we may also receive information about you from third parties such as a local authority, GP or health professional, or another community partner.
Information we may collect:
- your name, address and contact details, including email address and telephone number
- your date of birth and gender
- the names and date of birth of members of your household
- next of kin contact details
- relationship status
- photographic ID
- national insurance number
- income and benefits details
- employment status
- bank details and records of payments that you make to us
- housing history
- details of any disability or health condition that we need to be aware of to provide you with an appropriate service
- communication or accessibility requirements
- records of all our contact with you, and any contact from third parties representing you or about you, this may include call recordings.
- your image on our CCTV systems if you visit a property, office or communal facility which is covered by this facility
Some of the personal information, we collect is sensitive personal information (also known as special category data) which may include:
- Race or ethnic origin
- Religious or philosophical beliefs
- Sexual orientation
- Health information
We use this type of data to ensure services are delivered appropriately and to monitor equality, diversity and inclusion. We will make sure we have appropriate security and confidentiality measures when processing your sensitive personal information.
Why do we need the information?
There are a number of different reasons why we need to collect and process your information.
Some of the information we require is part of a contractual agreement, and without it we will be unable to process applications for housing or other services. For example documents verifying your identity to make sure that an application is not fraudulent.
Much of the information we collect and process is for our legitimate business interests, which means it is needed for us to deliver our services effectively. This could include things like your housing history, details of your income and any communications needs that you have.
Where we rely on legitimate interests as a reason for processing data, we have considered whether or not those interests are overridden by your rights and freedoms as individuals and have concluded that they are not.
Who has access to your data?
Usually only Christian Action staff will be able to see and process your personal information however sometimes we need to share personal information we hold about you with other organisations that we work with or who provide services on our behalf. We also sometimes share information when you ask us to, for instance in support of a transfer to another housing association. When sharing information we will comply with all aspects of data protection law.
Where it is in our ‘legitimate business interests’ to share your information, we may do so without seeking your consent first. This may be with:
- The Ministry of Housing, Communities and Local Government for research and statistical purposes (CORE reporting) – see separate information on our website
- Our contractors to carry out repairs, maintenance or improvement works.
- Debt and money management advisors.
- Local authority teams such as social services, environmental health and benefit agencies.
- Utility companies (and their representatives) and Council Tax Departments to ensure billing details are correct.
- Third parties providing services on our behalf. For example a mailing company distributing our letters, our tenant portal provider or a debt collection agency pursuing former tenant arrears.
- Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative.
- Police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime, the apprehension of offenders or the collection of tax or duty.
- Other statutory organisations e.g. social services and health authorities as necessary for exercising statutory functions.
- A third party out of hours contact centre if you live in one of our retirement housing schemes.
We may also share information when required by law for example where ordered by the Court. We may also share information when it is in an individual’s vital interests, such as needing protecting from immediate harm.
Where the information is special category data, for example about your health, we may need consent from you prior to sharing this information unless we are required or permitted to do so by law. We will be clear about what you are consenting to, will keep a record of your consent and you will have the right to withdraw your consent at any time.
Christian Action Housing will never sell your personal data to 3rd party organisations for marketing purposes.
How do we protect your data?
We take the security of your data seriously. We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees or other authorised individuals.
Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of your data.
To help us to ensure confidentiality of your personal information we may ask you security questions to confirm your identity when you call us. We will not discuss your personal information with anyone other than you unless we have a valid reason to do so or you have given us prior written authorisation.
How long will you keep my data?
Christian Action only holds records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues there may be between us.
We have a document retention schedule which sets out how long we keep different types of information. This is based on National Housing Federation guidance, legal requirements and best practice.
Please contact us if you would like any more information.
What if you do not provide personal data?
When we ask you for information, we will make it clear why we need it and also the consequences of not providing it. We will also make it clear when you do not have to provide us with information.
There may be some circumstances where decisions about whether to offer you a service or not is automated. Examples include where we use credit reference agencies during affordability checks for market rental and home ownership. Please contact us if you have any further questions.
Keeping you informed about our services
We will use your contact details to send you information and communicate with you about your tenancy or other services that we offer such as our quarterly newsletter.
When you visit our website, or register to the tenant portal we collect standard internet log information for statistical and value for money purposes and we ensure we respect your privacy in the following ways:
- We do not make any attempt to identify visitors to our website. We do not associate information gathered from our site with personally identifying information from any source.
- When we collect personal information, for example via an online form, we will explain what we intend to do with it.
Our website may contain links to various third party websites. We are not responsible for the content or privacy practices of any external websites that are linked from our sites.
Your data protection rights
Under data protection law, you have rights including:
- Your right of access - You have the right to ask us for copies of your personal information.
- Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we will comply with the data protection requirements. .Please contact us at firstname.lastname@example.org if you wish to make a request.
How to contact us or make a complaint
If you have any concerns about our use of your personal information, or have any questions, require further information, or would like to make a complaint you may contact us at:
The Data Protection Officer
Christian Action Housing
61 Island Centre Way
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Keeping this privacy notice updated
We regularly review and update our privacy notices. This privacy notice was last updated on the 19th June 2020.