Privacy Policy

RHP privacy policy

1. Introduction

To operate as a housing business, RHP Group (which includes Co-op Homes (South) Ltd) must get, process and store personal information about our applicants for housing, tenants and customers. This Privacy Policy supports our Privacy Notice. It explains how RHP Group treats your personal details.

2. What is personal information?

Personal information is information about a living individual (‘data subject’) that allows them to be identified. Personal data includes information about:
• contact details and preferences
• finances
• education and employment 
• safety and security.
Certain types of personal information are classed as 'sensitive'. They might relate to:
• racial or ethnic origin
• political opinions
• religious or philosophical beliefs
• membership of a trade union
• genetic or biometric data
• health
• sexual preference.
We usually only collect personal data so we can provide housing and management services, provide regulatory and legal returns and otherwise comply with our legal obligations (see Section 6, "How will we use your information?").

3. What information does RHP Group collect?

When you contact us, you might need to provide:
• your name, address and contact details. These will only be used, as necessary, within RHP Group or by our suppliers and partners 
• your age, sex, date of birth, ethnicity, information about disability and any other needs or preferences.

We may also get your personal details from organisations you’ve dealt with in the past like councils and past landlords. We use this information so we can understand our customers and their needs better 

When we provide you with a housing service, we might gather information on: 

• your housing needs, so we can find a property that suits you 
• bank accounts and direct debits so you can make payments like rent or service charges (we only exchange the details with the account holder and we don’t store any card details) 
• benefit and council tax information 
• voice and video recordings for safety and crime reduction
• support you’re receiving from another organisation, for example, the council’s social services team

You might also provide us with other information when you chat to us or our contractors.   

We might gather the following information to improve our service:

• details of any friends, relatives, neighbours or carers you trust to contact us on your behalf 
• your name and contact details for customer satisfaction surveys, newsletters and service information 
• your name, photo, video or story for brochures, press releases, advertising or use by the media (but only with your explicit consent)
• information about complaints about our service. We keep this separate from other information about you
• accidents or incidents involving you or your home 

If you ask for additional services from us:

• we’ll hold detailed information about yours and your family’s needs 
• we’ll hold records of payments for the services 
• we’ll hold detailed information about your income and debts if you contact us about money issues. We keep this separate from our other information about you 

If we need it to look after our employees, business or anyone else, we may hold information about your history, e.g. regarding credit, or offences. 

We’ll only request personal data that’s relevant for delivering our services and meeting our legal obligations. If you feel any requests aren’t appropriate you can refuse to provide information, but this might mean we’re unable to carry out requested or essential work, like repairs. We may also get your personal details from organisations you’ve dealt with in the past, like referral agencies, councils and past landlords.

4. Controlling your personal data

Here’s how we’re committed to protecting your privacy:

• We’ll process, (collect, store and use) the information you provide in a way that meets the relevant data protection legislation
• We’ll do our best to keep your information accurate and up to date and not keep it for longer than we need it for. Sometimes the law sets the length of time information has to be kept, but in most cases, we’ll follow housing sector regulations and legal guidelines to make sure we’re not keeping information for longer than we need. 
• We don’t want to be intrusive, so we won’t ask irrelevant or unnecessary questions. We won’t use the information you give us inappropriately 
• We won’t sell, distribute or lease your personal data to third parties unless we’re required by law to do so or need it to deliver our services. We may use your personal data to send you promotional information about third parties which is related to your tenancy or that we think you may find interesting. We will only do this with your consent.
• If you’ve previously agreed to us using your personal data for direct marketing purposes, you can change your mind at any time by emailing customer.services@rhp.org.uk or homes@coophomes.coop.
• If you believe any information we hold about you is incorrect or incomplete, email customer.services@rhp.org.uk or homes@coophomes.coop ASAP and we’ll put it right 
• We gather and analyse personal data, but we don’t draw any conclusions from it. This is called ‘profiling’ and it’s covered later.

5. Where do you store my data?

We’re committed to storing your personal data securely. This means only RHP employees and contractors that need to see it can.  We’ll always store it electronically if possible – but sometimes we’ll need to keep a paper copy. 

Our computer systems are secure and protected. Sometimes we also use computers which are owned or managed by our suppliers. Their computers will always be secure and protected too.
Where we share your information with others in line with the legislation, we will make sure that those third parties also have relevant security systems in place to make sure that your information is kept safely.
6. How will you use my information?
We’ll only use your data where we have a legal reason to do so. 

For example: 

• a lot of the information we collect about you will be so that we can process your housing application and manage your tenancy with us, to ensure we are both complying with the terms of that agreement.
• some information is used to provide you with additional support outside of the terms of your tenancy agreement, and it is in the legitimate interests of both RHP and you to use the information in this way to provide you with housing information and information about other support and services available.
• we have legal and regulatory obligations to collect certain information and we sometimes need information to defend or pursue legal claims. 
• There may be times where we need your consent to use your information in certain ways, for example, if you want to agree to us sending you promotional material.  You don’t have to give us your consent but refusing to give your consent may mean that we can’t carry out work for you or provide you with specific services. This will be explained to you at the relevant time.

Information collected about you is used to:

• process your housing application
• maintain our records and provide a quality housing service
• contact you about your rent account
• manage and enforce your tenancy conditions 
• carry out repairs and maintenance work to your home
• support you to help you live independently
• support any claims you make for benefits or grants
• help improve and shape our services
• provide you with general housing information 
• provide management services 
• allow us to meet our legal and regulatory requirements
• conduct surveys and provide statistics on tenant and household profiles when the Social Housing Regulator or other agencies appointed by the government ask for them
• prevent, detect and investigate crime using Closed Circuit Television (CCTV)
• carry out data matching. This is when we compare computer records to help us identify fraudulent claims or payments 

If we need to use your personal data for any other reason, we’ll always make sure that it is in line with the law. For example, there we may need to use your information if a crime’s been committed or if there are risks to the public or our employees. We might also have a legal duty to use your data in a certain way, for example through a court order.

7. How long do you keep my information for?

We generally hold information contained in your tenancy file for six years after your tenancy ends. In some circumstances, we may be required to hold some information for longer in order to comply with our legal obligations, or to protect our or your interests, for example to defend legal claims or pursue legal claims. 

If you would like further information on specific periods, please contact us. 

8. Who has access to my information?

Those working with and for RHP are trained to handle your information properly and protect your privacy.  Only those who have an operational need to see your data will be allowed to see it. We aim to maintain high standards, adopt best practice for record keeping and regularly check and report on how we’re doing.  Your information is never sold on to third parties or processed overseas.

Where appropriate, we may need to pass your personal data on to our service providers and contractors, for example to those who:

• undertake repairs and maintenance services so that we can meet our obligations under the terms of your tenancy;
• assist us with collecting and processing rent payments by card or direct debit and collecting rent arrears;
• provide us with facilities and support for our CCTV operations; 
• help us to carry out market research or customer survey calls.

Where we work closely with these contractors, they must store your details securely and use them only to undertake the work we have asked them to do. When the job is done they will securely dispose of the details as set out in RHP Group’s procedures and the relevant data protection legislation.

We also work closely with partners to help us provide you with services and support and may need to pass on your personal data to those organisations.

For example:

• Housing benefits departments and government benefits offices – e.g., to help process a customer’s Housing Benefit claim
• Local authorities and the police – examples include responding to a councillor enquiry on behalf of a customer, supporting the council with disabled adaptations to a customer’s home or asking the police for information about a crime report that affects an RHP property
• Utility companies (electricity, water and gas) – e.g., to confirm a customer has moved out of an RHP property
• Our insurance company - to ensure that they are aware of any relevant accidents or incidents and our policy is kept up to date.

We will always ensure that when sharing your information, it is appropriate, relevant, and in line with the legislation.  We have data-sharing agreements with a number of other organisations. They sign up to a code of how data will be exchanged and used.

In some circumstances, we need to share information in an emergency or because we have a legal or regulatory obligation to do so. For example:

• for the prevention or detection of crime and fraud
• in connection with legal proceedings
• in relation to someone’s physical or mental health, to protect them or others from serious harm
• for making a safeguarding alert where there’s a concern about a child or vulnerable adult’s safety 
• for research and statistical purposes – for example, for government research on who we let homes to
• to protect the health and safety of our employees
• to comply with the law.

From time to time we’ll use credit reference agencies to make sure our records are up to date. We’ll also use them for the prevention, detection and prosecution of crime, including social housing and benefit fraud. This information won’t be used for any inappropriate purposes. 

9. Profiling

Profiling is automated processing that’s designed to evaluate an individual and analyse or predict characteristics such as:

• economic situation   
• health
• personal preferences
• reliability
• behaviour
• location
• movements.

We don’t use profiling at RHP Group. 

How to contact us:   If you have any questions about this privacy statement, the practices of our sites or services, you can contact us at: 8 Waldegrave Road,  Edington, TW11 8GT or by emailing customer.services@rhp.org.uk or homes@coophomes.coop
Interactive service:   You agree to use the services as they’re intended. You agree not to access (or try to access) the services in another way. 
You acknowledge and agree that if we deactivate your account you may be prevented from accessing the services, your account details or any other content. 
You agree and understand that you’re responsible for maintaining the confidentiality of passwords associated with your accounts. You agree you’ll be solely responsible for all activities that relate to your account. If you become aware of any unauthorised use of your password or of your account, you agree to let us know immediately. 

Exclusion of warranties:  The services are provided ‘as is’. We can’t guarantee the services will meet your requirements or that your use will be uninterrupted, timely, secure or free from error. We can’t guarantee that any information given to you through using the services will be accurate or reliable, or that defects in the operation or functionality of any software provided as part of the services will be correct. 

11. Your Rights

Data Protection law gives you the following rights:

• The right of access to see the information we hold on you. To ask for this please contact customer.services@rhp.org.uk or homes@coophomes.coop. There is no charge for this service and we have 1 month to provide you with this information - unless it interferes with other people’s rights and freedoms or requests are repetitive, excessive or unfounded
• The right for your information to be rectified it’s inaccurate or incomplete
• The right to ask for erasure (right to be forgotten) where we no longer need to continue processing your information
• The right to ask for restriction of processing your information 
• The right to data portability – where processing is automated, based on consent and not in the public interest or necessary ‘in the exercise of official authority’, you have the right to request your data from us in a commonly used, machine readable format.  
• The right to object to how your information is used if we’re not using it for legitimate business reasons.
• If you have provided us with your consent for us to use your information in a certain way, you will always be able to withdraw that consent by contacting us. This might affect the services we can provide, but we will explain the consequences to you.

12. Contacting us and complaints

If you have any questions about how your information is used or want to let us know your information has changed please email customer.services@rhp.org.uk or homes@coophomes.coop.  If you want to see your information, believe that it’s not accurate, or if you want to make a complaint about the use of your information then contact the Data Protection Officer at 8 Waldegrave Road, Teddington, TW11 8GT or by emailing customer.services@rhp.org.uk.  

If you’re not happy with the way we deal with your query you can write to:

The Information Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Tel: 0303 123 1113; Fax: 01625 524 510; Email: casework@ico.org.uk 
Website: https://ico.org.uk/


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