Your privacy is important to us, which is why we only collect the information we need from you and your household in order to provide you with our services. We take great care to ensure the information we collect is kept confidential and handled responsibly and in accordance with legal requirements.
By using our website, any of our services, or providing us with any personal information we will assume you are agreeing to your information being used and disclosed in the ways described in this policy.
Privacy and Data Protection Policy
1. How we collect information
When we ask you for information we will:
- Tell you why we need it and how it will be used
- Collect only as much as we need to provide our services
- Take steps to ensure it is accurate and up-to-date
- Make sure we don’t keep it longer than is necessary
- Keep it secure and confidential – so that it is only seen by those members of staff who need it to do their job
In return we ask you to:
- Give us accurate information
- Tell us as soon as possible of any changes in your circumstances
2. The data we collect
Personal data – This is information that can identify an individual e.g. name, address, date of birth.
Sensitive data – This is personal information such as: the racial or ethnic origin of the data subject, their political opinions, their religious beliefs or other beliefs of a similar nature among others.
We may collect your data for the following reasons:
- To complete tenancy sign-ups
- To manage your tenancy or lease
- To meet your needs in our service delivery
- When profiling you for services and to target our resources
- To prevent fraud and illegal sub-letting and to confirm eligibility for housing
- To manage the legal process if you apply to buy your home
Provision of some of the information requested by us is part of a ‘contractual requirement’. Without this information, we will be unable to accept an application for services. For example, we cannot see if you are eligible for a tenancy without being able to verify your identity.
3. Who we share your data with
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. When sharing information we will comply with all aspects of data protection law. Where the information is of a sensitive nature, for example about your health, we will generally obtain explicit consent from you prior to sharing this information, unless we are required or permitted to share this by law.
Where ‘sharing’ is in our ‘legitimate business interests’ or yours or others ‘vital interests’, we may share your information without seeking your consent first. This may be with:
- Our contractors to facilitate 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 research company carrying out a customer satisfaction survey, 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.
We may also share information when required by law for example where ordered by the Court or to protect an individual from immediate harm.
The EU General Data Protection Regulation (GDPR) effective from May 2018 gives all EU citizens more rights and protections for their personal data, to minimise the possibility of theft and fraud.
These regulations include provisions for the following areas:
- The right to be informed: Organisations must publish a privacy notice, in addition to explaining transparently how they use this personal data.
- The right of access: Individuals will have the right to demand details of any of their data that an organisation may hold. This information must be provided within one month of request at no charge to the individual.
- The right to rectification: If a person’s data is incorrect or incomplete, he or she has the right to have it corrected. If the organisation that holds the information has passed any of that information to third parties. The company must inform the third party of the correction and inform the person which third parties have their personal data.
- The right to be forgotten: A person may request the removal of his or her personal data in specific circumstances.
- The right to restrict processing: Under certain circumstances, an individual can block the processing of his or her personal data.
- The right to data portability: A person can access their data for their own use anywhere they prefer.
- The right to object: A person can object to the use of their personal data for most purposes.
5. Data Protection Act
In carrying out our day to day activities we process and store personal information relating to our stakeholders and we are therefore required to adhere to the requirements of the Data Protection Act 1998. We take our responsibilities under this act very seriously and we ensure the personal information we obtain is held, used, transferred and otherwise processed in accordance with that Act and all other applicable data protection laws and regulations including, but not limited to, the Privacy and Electronic Communication Regulations.
6. Personal information via our website
- Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction.
We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to track their journey through the website.
Although GA records data such as your approximate geographical location, device, internet browser and operating system, none of this information personally identifies you to us.
GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor.
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
- Online forms
We use online forms to help you contact us. The information collected by these forms is sent to us via email and stored in the website’s database, long enough to enable us to manage our processes.
If the form includes a payment, some information will be passed onto out third party data processors, Payment Sense. In these cases we will also store your computers IP address to help protect against fraud.
We delete any information when it is no longer needed.
- Email Newsletter
If you choose to join our newsletter mailings (which is sent via email), the email address that you submit to us will be stored in Mailchimp, which we use for our email marketing. We consider Mailchimp to be a third party data processor. The email address that you submit will be stored within this website’s own database but not in any of our internal computer systems.
Your email address will remain within Mailchimp database on our website for as long as we continue to use this platform for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
7. Third parties via our website
- What are cookies?
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work better, as well as to provide information to the owners of the site. A cookie often contains a unique number, which can be used to recognise your computer when a user of your computer returns to a website that it visited previously.
- Your rights
- Changing your cookie preferences
The “Help” menu in the toolbar of most web browsers will tell you how to change your browser’s cookie settings, including how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. An online guide is available if you have difficulties trying to change your browser settings.
9. Changes to the policy
This policy replaces all previous versions and is correct as of the date at the end of this web page. We will regularly review and update this Privacy and Data Protection Statement and will update, modify, add or remove sections at our discretion. Any changes will be notified to you through on this page. Your continued use of our website, any of our services and/or the continued provision of personal information after we have posted the changes to these terms will be taken to mean you are in agreement with those changes.
10. Privacy queries
If you have any questions or queries about this Privacy and Data Protection Statement, please contact Crown Simmons using the details below.
A: Crown Simmons Housing, First Floor, Aissela, 46 High Street, Esher, Surrey, KT10 9QY.
T: 01372 461 440
Date of publication: May 2018