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Our contact details for data protection purposes are:
Data Protection Officer
Twenty11 Homes Limited
Windsor Court
Kingsmead Business Park
High Wycombe
HP11 1JU
dataprotection@twenty11.co.uk
This Privacy Notice applies to all the personal data we collect and use. Twenty11 Homes Limited (Twenty11) and its parent company Red Kite Community Housing Limited (Red Kite) are the 'Data Controllers' for the purposes of the General Data Protection Regulations (UK GDPR) and UK Data Protection Act (2018).
In order to help provide you with the best and most appropriate service, we need you to help us by providing us with your detailed information.
Because the information you provide us is very personal we take your privacy and confidentiality very seriously.
We aim to keep your information as up-to-date as possible so that when your needs change over time, the services we provide to you can change to reflect these different needs. We will also ensure we make every possible effort to fulfil our obligations under the General Data Protection Regulation (UK GDPR), which took effect on 25th May 2018, and the UK Data Protection Act 2018.
We will keep your personal information secure and only keep it for as long as we need to, although please bear in mind we are legally obliged to keep some records for an extended period of time, such as housing benefit payments, before they are safely destroyed.
When using the term “personal data” in this Privacy Notice, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold.
We collect some personal data from you, for example when you first apply for a property, use our website or contact us. We may also receive your personal data from our commercial partners who provide services to you on our behalf, and our partners’ agencies.
In accordance with data protections laws, we need a “legal basis” for collecting and using information about you. There are a variety of different legal bases for processing personal data which are set out in the data protection laws.
The lawful basis on which we rely in order to use non-sensitive information which we collect about you will be that it is necessary for us to assess your housing application prior to entering into an agreement with you.
The lawful basis on which we rely in order to use your special categories of personal data which we collect about you will be that it is necessary for us to assess your particular housing needs, so that we can comply with our obligations as a social landlord.
The lawful basis on which we rely in order to use information and financial circumstances will be that you have provided explicit consent to use that information for that purpose, so that we can provide tailored rent management services to you to help you to manage your rent account.
Detailed personal information we collect may be some or all of the following:
We may sometimes collect additional information about you from third parties. If we do we will seek to ensure that the information is accurate and up to date.
We will only use your personal information when the law allows us to. These reasons for processing are known as "processing conditions" and we will always ensure that we have a lawful processing condition whenever we process your personal data. Most commonly, we will use your personal information in the following circumstances:
We may also use your personal information in the following situations, which are likely to be rare:
We may also process some of your data because it is in our legitimate interest to make sure that:
We need all the categories of information in the list above primarily to allow us to perform our contract with you to provide you with housing and other services and to enable us to comply with our legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
In the course of providing services to you, we may collect information that details your gender and gender identity, racial or ethnic origin, physical or mental health, sexuality, religious beliefs or alleged commission or conviction of criminal offences.
Such information is included within the “Special Categories of Personal Data” under the UK GDPR. We only collect this information where you have given your explicit consent, it is necessary under laws relating to social security and social protection law, or it is necessary in connection with legal proceedings or you have chosen to make it public.
If we are collecting special category data which we can only process with your explicit consent, we will make this clear at the time. You will have the right to withdraw that consent and we will explain to you how you can do that when you provide the consent but this may mean we are unable to provide all or parts of the services you have requested from us.
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of social protection or social security. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your tenancy with us that you agree to any request for consent from us.
We may use your personal data for the following purposes:
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a tenant or service user we will retain and securely destroy your personal information in accordance with our data retention policy or applicable laws and regulations.
The introduction of UK GDPR provides all UK citizens with new and enhanced privacy rights, which we are committed to upholding, and we take our responsibilities regarding our tenants' privacy rights very seriously.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Under certain circumstances, by law you have the right to:
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact dataprotection@twenty11.co.uk.
You will not have to pay a fee to access your personal information (or to exercise any of your other rights). 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.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
You can find out how to request the information we hold about you by emailing dataprotection@twenty11.co.uk.
Twenty11 is committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage. When you provide your personal data through our website or online portal, this information is transmitted across the internet securely using appropriate strength encryption.
As detailed in this Notice, we may in some instances disclose your personal data to third parties. Where we do disclose your personal data to a third party, we require that third party to have appropriate technical and organisational measures in place to protect your personal data; however in some instances we may be compelled by law to disclose your personal data to a third party, such as the police, and have limited control over how it is protected by that party.
The information that you provide us will be held in our systems, which are located on our premises or those of a contractually-appointed third party.
We may also instruct service providers outside of Twenty11, domestically or abroad, for example shared service centres, to process personal data for Permitted Purposes on our behalf in accordance with our instructions only. Twenty11 will retain control over and will remain fully responsible for your personal data and will use appropriate safeguards as required by applicable laws to ensure the integrity and security of your personal data when engaging such service providers.
All of our data is stored within the EEA with the exception of the MailChimp service which we may use from time to time to collect survey data. MailChimp is an online marketing platform operated by The Rocket Science Group LLC, a company based in the state of Georgia in the USA. MailChimp has appropriate safeguards in place in accordance with applicable legal requirements to provide adequate protection for any personal data transferred from the UK.
We will retain your personal data for as long as we need it in order to fulfil our purposes as set out in this Privacy Notice or in order to comply with the law.
Sometimes it is in everyone’s best interests for us to share some of the information we have about our customers with other organisations. Sometimes this is because we have a legal obligation to do so and sometimes it is to ensure you get the best service possible, for example we will forward your details on to utility companies to ensure that you’re supplied with energy and water in your home.
If you decide to leave your property without paying or arranging to pay and you are in arrears we may decide it is necessary to share your details with a debt collection agency to help us recover our money.
We will also share some details with our contractors, so they can contact you if your property is in need of repair or scheduled for improvement work, to arrange a suitable time to visit.
In exceptional circumstances we may feel it is necessary to provide your details to the police or a local authority social services department where there has been a case of criminal activity, a breach of your tenancy agreement, we have been made aware of potentially antisocial behaviour, or if we believe it to be in the vital interest of you or someone who lives with you.
In the event that you leave us and move to a new landlord we might be contacted for a reference and may provide some of your details to them.
If we want to share your data because we think it is in your interests but we do not have a legal basis for sharing we will always ask for your consent.
We’d like to stress that under no circumstances do we ever sell or pass on your information to businesses or organisations so they can get in touch with you directly either by phone, email or in writing in order to sell you their products or services.
Listed below are the categories of third parties we may share some of your personal information with. Where required we will ensure that any information sharing is supported by UK GDPR-compliant contracts or there are appropriate Information Sharing Protocols in place.
In some cases we may also have a duty to disclose your information by law to:
We will not share or disclose your information with anyone who claims to represent you or to be acting on your behalf unless we have verified that you have appointed them or they are acting in some recognised official capacity.
We may make changes to our Privacy Notice from time to time. We will update the Privacy Notice and we will publish on our website any new version of this Notice.
All public bodies are subject to the Freedom of Information Act. This means you’re entitled to request certain details from them.
Twenty11 is not a public body for the purposes of this Act, so we’re exempt from the requirements, but regardless we’ll still consider particular information requests and help you if we can.
We have appointed a Data Protection Officer to oversee compliance with this Privacy Notice.
If you have questions in relation to exercising any of your Privacy Rights or you have a question or concern about how we process your data, please contact our Data Protection Officer in the first instance at dataprotection@twenty11.co.uk.
If for any reason we do not address your request, or fail to provide you with a valid reason why we are unable to do so, or if you are unhappy with the way we have dealt with your personal data, you have the right to contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, to make a complaint. They can be contacted via their website or by telephone 0303 123 1113.