Housing 21 is a registered data controller with the Information Commissioners Office (ICO), our registration number is Z5515259.  

In accordance with the Data Protection Act 2018 we collect and process PII about our residents. We do this to provide social housing, support and domiciliary care services related to housing or as permitted by law. We are an exempt charitable housing association.

Housing 21 is incorporated under the Industrial and Provident Societies Act 1965 (Registration number IP16791R) and under the Housing and Regeneration Act 2008 (Number L0055). Housing 21 is also a registered society under the Co-operative and Community Benefit Societies Act 2014.

For further information or queries email our Data Protection Officer, Sonia Hawley or telephone: 0370 192 4000 or write to:

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

Full details are set out in the relevant sections of this notice below, but in summary:

• We receive PII relating to you from you directly, but it may occasionally be provided to us by third parties with whom you have a separate relationship with (such as a local authority).
• We use your data to provide housing and other services to you, correspond with you, meet our legal obligations, and improve our products and services.
• We provide your PII to third parties as part of our role to provide housing and services or as permitted by law or regulation e.g. Resident Surveys for the Regulator of Social Housing
• We do not share your data with third-party advertisers.
• We store data for specified periods for our limited business purposes.
• You have certain rights, prescribed by law, in relation to the processing of your data, such as rights to request access, restriction, portability, rectification, to be informed, and the deletion of your PII, in certain circumstances.
• We do have CCTV in operation at some of our sites.

PII is data related to a living individual who can be identified from that data, either directly or indirectly. This can also include special categories of personal data (SPD) (revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, and genetic data, biometric data, health data and data concerning a person’s sex life or sexual orientation) as well as information relating to criminal convictions and offences.

PII will be processed in accordance with the Data Protection Act 2018.

This notice sets out how we use your information in the following circumstances:

1. Your Tenancy or Lease
2. CCTV
3. Resident Involvement
4. Communications (e.g. Newsletters, Resident Survey)

Where required we will disclose your PII with others, in these instances we will ensure we have appropriate information sharing protocols in place.

• All Housing 21 employees, contractors and suppliers who provide services to you, or who provide services on our behalf, e.g. contractors who undertake repairs/improvements or research companies who conduct surveys for us.
• Anyone who you have provided permission to speak with us on your behalf.
• Banks, to conduct payments through a secure system.
• Local authorities, other housing and support organisations and statutory agencies
• Mediation partner organisations.
• Our solicitors and other advocacy partner organisations.
• Housing 21 insurers in the event of public liability claims.
• Credit reference agencies.
• External assistance where you have agreed to the referral.
• Utilities companies.
• Tracing/debt collection agencies for unresolved debts after termination of tenancy by either party or unpaid service charges / major works owed by a resident.

In some cases, we will have a duty to disclose your information by law to:

• Other housing associations
• Local authorities, regulators, and government departments
• Police, fire services, health authorities or medical staff
• Others who may need information from us for their own purposes, for example detecting and preventing crime, prosecuting offenders and for the prevention and detection of fraud.

We do not provide organisations with access to your information in return for payment for their marketing or commercial purposes. However, on an annual basis we are obliged to disclose your information by law to the government, as required of all housing associations.  

We may also instruct an approved third party to administer our resident survey. We are required by law, under the Regulator of Social Housing to gather Tenant Satisfaction Measures (TSMs), and part of this process stipulates that these satisfaction measures must be gathered through a perception survey.

From time to time, we may need to provide third parties with PII relating to you or members of your household or obtain PII relating to you or members of your household from third parties. However, this will only be so we can accomplish our responsibilities as a housing provider.

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. For full details please refer to our Artificial Intelligence (AI) Privacy Notice.

We will collect the following PII about our residents:

• Name
• Address
• Phone number
•  Email address
• Marital status
• Whether you have any dependants
• National Insurance Number
• Benefits
• Date of birth
•  Family details
• Reference information
•  Relationship status
• Care needs
• Communication preferences
• Financial details such as direct debits, online and phone payments
• Homesearch application number (if applicable)
• Documentation such as: one photographic document e.g. passport, national identity card, provisional/full driving license, or a UK birth certificate where none of these are available. Home office ID card for nationals outside EEA and freedom pass. Two passport photos, legal documents if name changed and home office documents.

We will only ask for personal information that is appropriate to enable us to deliver services to you.

In some cases, you can refuse to provide your details if you deem a request to be inappropriate. However, it is important to note that where you refuse to provide information, in the performance of your tenancy agreement with us, it may impact upon our ability to provide certain services to you and may result in us being unable to process your application for a tenancy or provide you with a property that meets your needs.

During the life of your tenancy Housing 21 will collect and process information about you and members of your household for the following purposes:

• managing your tenancy or lease
• providing safe and sustainable properties
• monitoring compliance with the terms of your tenancy or lease agreement
• delivering support or care to you or members of your household
• conducting surveys and research to monitor and improve our services
• providing associated welfare services, advice, and support
• maintaining our accounts and records
• recruiting, supporting and managing our board and employees
• recruiting, supporting, and managing our agents and contractors that we use to help maintain properties and services
• promoting the services we provide
• Local Fraud Initiatives, including working in partnership with Local Authorities and Council Anti-Fraud & Corruption Teams to tackle tenancy fraud. Local Authorities may share the PII you have provided with fraud prevention agencies who will use it to prevent and detect fraud and money laundering and to verify your identity. If fraud is detected you could be refused certain services, finance, or employment 
• corporate administration and all activities we are required to conduct as a data controller
• ensuring we meet our legal obligations as a housing provider
• insurers and/or professional advisers in relation to maintaining insurance coverage
• where you are identified as an alleged victim, witness or perpetrator of anti-social behaviour or are the reporting party in relation to queries, complaints, or reports.
• to allow the statistical analysis of data so we can plan the provision of services
• to prevent and detect fraud or crime

Unless we specifically advise you otherwise, we will only collect and process PII that we need to carry out these functions.

The collection and processing of PII allows us to provide a service that meets your needs, and the information will be processed for social care purposes and as part of emergency response situations.

This PII will be stored on our data systems and/or a paper resident file. It is held securely, and we have security measures in place to prevent it from being accessed by any unauthorised personnel.

CCTV is installed on some of our estates to monitor building security, crime prevention and detection. Housing 21 does use mobile CCTV, in the form of body worn cameras at limited sites, however the main estate-based CCTV is operated and stored locally on Housing 21 properties.

We operate our CCTV in accordance with the guidance issued by the ICO. The Data Protection Act 2018 and UK General Data Protection Regulation (UKGDPR) covers images of people and information about people derived from CCTV, for example a vehicle registration plate.

Housing 21 collects this data as part of its public function as a housing provider to ensure the health and safety of residents and its employees.

We will not hold images for longer than necessary and will dispose of them securely. Our CCTV is operated locally and is auto wiped between 30-90 days after the image is captured. This footage will only ever be retained for longer, for the prevention and detection of crime, apprehension, and prosecution of offenders, and/or investigating cases of antisocial behaviour. 

Housing 21 encourages residents to become involved in helping us to improve the services that we provide. Should you decide to be informed about community projects and ways to get involved you will be added to the resident involvement database.

To be added to this database, the following PII will be collected from you:

• Name
• Address
• Phone Number
• Email Address

Information on that database will be kept separate from the main database and your PII will be used specifically for this purpose.

Housing 21 may use this information to contact you and for consultation exercises. This information is processed as part of our role as a housing provider, as resident involvement helps us to improve our services.

We store PII including Sensitive Personal Data (SPD) both electronically and in paper format. We use a range of controls to keep your PII is secure from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. These include delivering data protection training to all Housing 21 employees and implementation of security policies, processes, and technical physical security solutions.

Information kept in a paper format is placed in secure storage, e.g. lockable filing cabinets if onsite in a Housing 21 office and in a secure data storage site, if held externally. Security checks are conducted if you call our front-line teams to ensure the call handler can identify you before disclosing any account-related information. We do this to protect you, your data and ensure that other people are not privy to your PII.

If you would like another person to speak to us on your behalf, e.g. relative, carer, partner, friend, etc. you will need to provide them with your permission and make us aware of this. 

We cannot discuss your personal situation or disclose information about you to another person without your permission, permission can be granted verbally every time you call us alternatively you can confirm in writing and a note will be retained on our system and we can then speak with your chosen contact.

Our business is based solely in the United Kingdom, and so we do not send data overseas. We may sometimes make use of cloud-based systems to support the management of our business. Where this occurs, we will ensure that there are appropriate safeguards in place to protect your rights.

If you have agreed to receive communications, we will contact you from time to time by phone, email, and text. Residents may also have opted in via the privacy options at tenancy sign up.

To provide you with the updates we process the following types of information:

• Name
• Address
• Phone Number
• Email address

Housing 21 processes your information in these circumstances because we have your consent to do so, and you may withdraw your consent to communications at any time.

Please note that whilst we will discontinue contacting you for direct communications purposes, we will continue to process your PII for other purposes as set out above, to continue to provide you with social housing.

You can view your communication preferences and update your settings at any time by contacting us by e-mail or write to us at:

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

All PII is retained in line with the Housing 21’s Retention and Disposal Policy. The following applies:

• Current residents’ Tenancy Files, including rent payment records, and details of any complaints and harassment cases, are retained for the length of the tenancy plus seven years thereafter.
• Former residents’ Tenancy Agreements, and details of their leaving are retained for seven years.

The data we collect and retain for the necessary period of time is sourced through all types of communication, this includes telephone calls, e-mail, and paper-based correspondence.

If you wish to see a copy of the PII we hold about you then you can ask us at any time, and we must respond within one calendar month of the request. This is a data subject access request under the Data Protection Act 2018.

You will not have to pay a fee to access your PII. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

You have a legal right to access information we hold about you, including the right to:

1. 1.    Be informed about how we process your PII – this is why we have developed this privacy notice.
2. Have access to a copy of the PII we collect and keep on you – known as a data subject access request.
3. Have incomplete or inaccurate information rectified.
4. Restrict the processing of your PII in certain circumstances, for example, if you have challenged the accuracy or if you have objected to the processing of your PII.
5. Have PII erased in certain circumstances.
6. Obtain and have your data ported across different service providers, from one IT environment to another.
7. Object to the processing of your PII in certain circumstances including to stop your details from being used for communication purposes.
8. Request human intervention when decisions are made solely by automated means, you have the right to ask for details of the logic leading to the decision.
   You may exercise any of your rights in relation to your PII by written notice to us.

www.ico.org.ukYou can exercise any of the above rights by emailing the Data Protection Officer or write to us at:

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

If you wish to make a complaint about how we are processing your PII you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). You can find out how to contact the ICO on their website 

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Acceptance of cookies may be necessary to complete some actions such as submitting applications. See the Housing 21 website for our Cookie policy.

Housing 21 reserve the right to update this privacy notice at any time, and we will notify you when we make any fundamental changes. We may also notify you in other ways from time to time about the processing of your PII.
Further information on how your data may be processed can be found on our website Privacy Notice:  Housing 21 - Privacy policy.