Our Data Protection Officer is Sonia Hawley.

If you have any questions about the administration of your personal information, please contact the Data Protection Officer

• on 0300 790 1325
• by sending an email
• or at the postal address:

Data Protection Officer (DPO)
Housing 21
Tricorn House
51-53 Hagley Road
Birmingham
B16 8TP

Personal data may be contained within documents uploaded onto AI Tools used by Housing 21. Where this is the case, we are the data controller, and our approved AI supplier/contractor is the data processor. We have carried out the appropriate due diligence with each supplier/contractor (‘Processor’) to ensure that your personal data is protected, when processed with the use of the AI Tools, in accordance with the UK GDPR and our various information governance data protection and IT security policies.

None of your personal data will be used solely by the AI technology provider to improve their AI products.

In most cases, we process your personal data using the AI Tools to improve the efficiency, quality, and speed of our business processes.  A lot of these processes are already happening manually. Using AI to automate these processes allows Housing 21 resources to be used where they are needed most.

Any supplier who has access to your data is assessed for compliance with Data Protection legislation before any information is shared or processed by them.

The lawful basis we rely on to process your personal data is either Article 6(1)(a) of the UK GDPR, for example when we require your consent or Article 6(1)(f) which allows us to process personal data when it is necessary for our legitimate interests

Where Housing 21 processes customer personal data with the use of AI Tools, this is to fulfil our legal and statutory duties under the legislation, e.g. to consider a complaint, provide you with guidance, or investigate a breach. In other circumstances, your personal data will be processed under the lawful basis of “legitimate interest” e.g. in recruitment. For more information, please refer to the relevant sections in our full privacy notice.  

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• You have been through the application and/or recruitment process. 
• You have signed up to a tenancy agreement.
• You have signed a contract of employment.
• You have made a complaint or enquiry to us.
• You have made an information request to us.
• You wish to attend, or have attended, an event.
• You visit our website and consent to our use of cookies.
• You have agreed to a DBS check.
• You have applied for support funds such as the Helping Hands Fund
• You have sought guidance / supporting applications for additional benefits for non-means tested benefits
• You have provided your bank details for direct debit purposes (e.g. rent payment)

We may also receive personal information indirectly, in the following scenarios:

• Your personal information is contained in reports of breaches of data protection law (‘breach reports’) given to us by individuals or organisations.
• A complainant refers to you in their complaint correspondence.
• From an individual submitting a data subject access request.
• Whistleblowers include information about you in their reporting to us.
• We have collated evidence which contains personal information as part of an investigation.
• From public authorities, regulators, or law enforcement bodies.
• Where you have made your contact information available on our website, intranet or social media accounts.
• An employee of ours gives your contact details as an emergency contact or a referee.
• A resident of ours gives your contact details as Next of Kin.
• You are confirmed as a Power of Attorney for one of our residents. 

If it is not disproportionate or prejudicial, we’ll contact you to let you know we are processing your personal information. 

We will not share your information with any third parties for the purposes of direct marketing.

We use data processors who are third parties who provide elements of services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it, this includes processing by AI. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct. When it is necessary for us to transfer your personal information outside of the UK this will only be done in accordance with the UK GDPR. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.  We do not allow our third-party providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions as part of a contractual obligation. 

In some circumstances we may need to share information without your consent to comply with any legal obligation or to fulfil the purposes for which it was submitted.  For example, to process Housing Benefit payments and to liaise with your respective local authority to manage your rent service charges.    

Housing 21 do not use AI to make automated decisions. Human intervention will always be engaged to review and approve any outputs from the use of AI tools. Decisions are not made solely by automated means. For more information on your Individual Rights, contact the Data Protection Officer (DPO) 

Your personal information may be converted ('anonymised') into statistical or aggregated data in such a way that ensures that you cannot be identified from it. Anonymised data cannot, by definition, be linked back to you as an individual and may be used to conduct research and analysis, including the preparation of statistics for use in our reports.

We have a Document Retention Policy and Procedure and Retention Schedule in place, which outlines how long we keep different types of information for and includes data processed through the use of AI Tools. This is underpinned by legislative and regulatory compliance requirements.  This policy is formally reviewed every two years and is based around good practice guidance issued by the National Housing Federation, the ICO, and any regulatory or legislative updates.

You have the following rights under the Data Protection Legislation and Regulation:

• to access your personal data
• to be provided with information about how your personal data is processed
• to have your personal data corrected
• to have your personal data erased in certain circumstances
• to object to or restrict how your personal data is processed*
• to have your personal data transferred to yourself or to another business in certain circumstances
• to be told if Housing 21 have made a mistake whilst processing your data and in certain circumstances, Housing 21 may self-report breaches to the Information Commissioners’ Office (ICO).

*As we are processing your personal data for our legitimate interests as stated above, you have the right to object to our processing of your personal data. There are legitimate reasons why we may refuse your objection, which depend on why we are processing it.

The Data Protection law gives you the right to apply for a copy of information about yourself. This is called a ‘Data Subject Access Request'.

If you wish to see a copy of your records you should contact the Data Protection Officer. You are entitled to receive a copy of your records free of charge, within a month.

The accuracy of your information is important to us to be able to provide relevant services more quickly. We are working to make our record keeping more efficient. In the meantime, if you change contact information, or if any of your circumstances change, or any of the other information we hold is inaccurate or out of date please contact the Data Protection Officer by email or at the postal address:
Data Protection Officer (DPO)
Housing 21
Tricorn House
51-53 Hagley Road
Birmingham
B16 8TP

We keep our privacy notice under regular annual review and will place any updates on our website; you will be notified of any major changes to this notice.