This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how South Essex Homes uses your data
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
When you are using the South Essex Homes website, South Essex Homes Ltd is the Data Controller and the Data Processor.
2. Who is South Essex Homes?
South Essex Homes is the Arms Length Management Organisation for Southend on Sea Borough Council. We were set up in 2005 to manage Southend on Sea Council’s housing stock. We are owned entirely by Southend Borough Council. We have a subsidiary company called South Essex Property Services. We are managed by a Board of Directors – three Tenants, three Councillors and five Independents.
For simplicity throughout this notice, ‘we’ and ‘us’ means South Essex Homes and/or our subsidiary company, South Essex Property Services.
Much of the data that we process is owned by Southend on Sea Borough Council. For example, information that is provided by our customers that relates to their tenancy. We need this information to enable us to fulfil our Management Agreement (Contract) to manage the Council’s properties. In this case, the Council is the Data Controller and we are the Data Processer. We also hold personal information about our staff and other customers that are not tenants of the Council. In this case, we are both the Data Controller and the Data Processor.
3. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent.
For example, when you tell us that it is ok to talk to a nominated person about your tenancy
When collecting your personal data, we’ll always make it clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations.
South Essex Homes needs to collect, process and store personal information about you in order to operate as Southend on Sea’s Arms Length Management Organisation and deliver an efficient and effective housing and tenancy management service.
For example, we will need to share your contact details with our repairs contractors so they can make appointments to carry out repairs in your home.
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of customers who are involved in fraud or other criminal activity affecting us or Southend on Sea Council to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we may send you a tenants’ newsletter which gives details of upcoming events or services that may help residents sustain their tenancy.
We often have to use your personal data to help us carry out tasks and responsibilities in the public interest.
For example, checking people’s details and circumstances when they apply for social housing.
4. When do we collect your personal data?
When you apply to Southend on Sea Borough Council to become a tenant or become a customer or staff member of South Essex Homes or South Essex Property Services, we request and hold on file any information necessary to assess your application including as appropriate (but not limited to) references from other housing providers/private landlords/employers, the Police, the Probation Service, support workers, social workers, medical services, mental health workers and credit reference agencies.
It is important that you notify us of any changes to your personal information.
5. What sort of personal data do we collect?
We collect personal information about:
- Customers - This includes current, former and potential customers, who live in our properties or access our support and other services, and could also include their family and people associated with them.
- Colleagues - This includes current, former and potential colleagues, as well as Board and Committee members, staff members and volunteers.
- Anyone who makes a complaint or enquiry and visitors to our website
The information we hold on our records concerns our relationship with you. The type of information we collect is limited to the information that we may need to fulfil our contractual agreements to both Southend on Sea Borough Council, to our staff and to you. This includes information to ensure we can deliver tenancy and repair services, help tenants sustain their tenancies and safeguard our customers.
- We hold names and dates of birth, photographic ID and information about your previous housing circumstances to assess housing applications and help prevent tenancy fraud and illegal subletting.
- We hold contact details for you so we can communicate with you via various methods, and to keep you informed about other services we offer which may be useful to you. We would like to provide you with information about other products and services (of ours) which do not form part of our core landlord services but which we think may be of interest to you. This would include information such as accessing training and employment, financial guidance and digital support. You can let us know at any time how you prefer to be contacted or if you do not want us to contact you with this information. We never provide your personal information to other companies for their marketing purposes.
- We record information about your needs to ensure our services are accessible; that we take account of any support needs in our dealings with you; and to improve our communications with you. For example, if you have a carer or social worker; if you need adaptations in your home; if you need large print.
- We record information to assist us in delivering housing management services including reports of antisocial behaviour; repairs; complaints; change in circumstances e.g. if you have a medical need which means you need to move or when your employment status changes.
- We keep financial records about the amount of money you have paid us; any amount(s) outstanding and associated recovery action. Depending on your chosen method of payment, we may hold your bank account details.
- We may hold information about you if you are engaged with our additional support services such as services provided at ‘the Hubs’. For example in connection with access to training and employment we may hold information about your job history and skills and experience, or if we support you to help you maintain your rent account, we may hold information about your household income and expenditure.
- We may hold recordings of your telephone calls through our Contact Centre
- We may capture your image on our CCTV systems if you visit an estate, office or community facility which is covered by this facility. In addition we may capture your image on body worn cameras worn by our Neighbourhood Patrol however they will always inform you when they are recording you. Call recordings and CCTV recordings will be held in accordance with our and the Council’s retention policies before being erased.
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
This list is not exhaustive, as we hold records of most contacts we have with you, or about you, and we process this information so we can deliver services to you.
We may carry out market research and customer satisfaction surveys to help us to monitor our performance and to improve our services to our customers.
Generally the information we hold will have been provided by you (on application or enquiry forms or when we communicate with you), but we may also hold information provided by third parties where this is relevant to your housing circumstances e.g. from social workers and health professionals (e.g. doctors and occupational therapists).
We will only ask for personal information that is appropriate to enable us to deliver our services. In some cases, you can refuse to provide your details if you deem a request to be inappropriate. However, you should note that this may impact our ability to provide some services to you if you refuse to provide information that stops us from doing so.
Special Category or ‘sensitive’ information
Under the General Data Protection Regulations certain personal information is classified as ‘Special Category’ which you may consider ‘sensitive’. Sensitive data can be details such as information relating to physical or mental health, sex life, religious or philosophical beliefs, political opinions, membership of a Trade Union, allegations of criminal offences and criminal convictions and offences. We minimise our holding and use of sensitive categories of personal information but, given the services we provide, there are times when we use it, for example when providing accommodation for disabled persons or those with problems around substance abuse, when resolving neighbourhood disputes involving alleged criminal activity or when helping someone to access care services.
When we collect specific sensitive data we will notify you of how we will use it, including who it may be shared with. We treat all personal data with the utmost care and store it safely and we are particularly careful when the information is ‘special category’. For example if we have to share it it, we can use secure email or passwords.
6. Why do we use your personal data?
South Essex Homes recognises the importance of respecting your personal privacy and also the need to have in place appropriate safeguards surrounding the processing of personal data. South Essex Homes is registered with, the Office of the Information Commissioner. Our registration number is Z9210005.
Whether via our website, letter, email or another method, we assure you that we will only use the personal information you provide in accordance with this statement and our registered details held on the public register administered by the Information Commissioner and available via the website www.ico.org.uk
We will collect, process, share and securely store personal information in compliance with the General Data Regulations 2018.
All information will be retained in accordance with the requirements of our retention schedule.
We keep these records to allow us to:
- Work with the Council to operate its housing register and allocate properties fairly to new tenants
- Manage tenancies
- Receive rent and service charges
- Ensure bills and benefits are accurate and paid accordingly
- Provide a repairs and maintenance service
- Offer help with debts and benefits
- Provide Support services which help customers achieve their goals and sustain their tenancies
- Prevent & detect crime and resolve disputes
- Promote safety and the quiet enjoyment of our neighbourhoods & communities
- Engage with customers and make improvements to our products and services
- Promote equal opportunities and fair treatment for all colleagues and customers
- Manage employment and colleague development
- Work with partners to deliver mutual success
- Provide information (e.g. about products and services) you request from us
We need to collect, process and store personal information about you and other household members (when you provide information about household members we assume that you do so with their full knowledge and consent) in order to operate as the Councils Arms Length Management Organisation. The information allows us to meet our contractual commitments to you.
The data privacy laws allow this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
We also collect information in our capacity as an employer and in the course of business.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
7. How we manage your personal information
Processing of your personal information will be undertaken in accordance with the principles of the General Data Protection Regulations 2018. Access to personal information is restricted to authorised individuals on a strictly need to know basis. We will ensure that personal data is:
- Processed fairly and lawfully.
- Obtained for one or more specified and lawful purposes and not be further processed in any manner incompatible with that or those purposes.
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- Accurate and, where necessary, kept up to date. All reasonable steps to erase or rectify inaccurate personal data must be taken
- Not be kept longer than is necessary for the purposes for which the personal data are processed
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
We are committed to keeping your personal details up to date, and we encourage you to inform us about any changes needed to ensure your details are accurate. To help us to ensure confidentiality of your personal information we will ask you security questions to confirm your identity when you call us and as may be necessary when we call you.
We will not discuss your personal information with anyone other than you, unless you have given us prior authorisation to do so. Anyone calling on your behalf may also be subject to security questions to ensure we’re taking adequate steps to protect your personal information.
We may use notes on our computer systems (for example, in relation to your vulnerability or health status) to enable us to tailor and deliver services to you. South Essex Homes only holds records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us. If you move, and are no longer a resident we will usually keep records about you for up to 6 years.
8. How we protect your personal data
We make every effort to keep your information safe:
- We take appropriate care to secure the information we hold about you
- We have robust technical security such as passwords and information encryption
- We have policies and procedures to make sure your information is only available to our employees who need to see it to do their job, and we train these employees appropriately.
We establish robust procedures and contracts to extend these protections to any other person or organisation we made need to give your information to.
9. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected or as long as we are legally required to do so. Our Data Retention Policy gives details of how long we keep this information. At the end of the retention period, your data will either be deleted completely or anonymised.
10. Who do we share your personal data with?
Normally, only South Essex Homes (and SEPS) staff will be able to see your personal data. However, sometimes we need to share it with trusted third parties including our contractors or other departments within Southend on Sea Borough Council. We would only do this when we are required to do so legally or to safeguard you or where you have given us consent
For example, with your Social Worker or medical professional where we consider that if we don’t, it may put you at risk of harm to yourself, to others or to your property.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
- Repairs Contractors
- Law Enforcement – e.g. Essex Police
- The Fire Service
- Printing, postal and communication companies who provide us with the services to produce newsletters, leaflets and undertake customer surveys
- IT companies who support our website and other business systems such as electronic means of making rent and service payments.
- Social Services for adults and children
- Health Services
- Other Housing Organisations – for example if you are moving properties to another landlord
- CAB and other Voluntary Organisations
- Other organisations with which we share a Data Sharing Protocol
Please be aware of these examples of circumstances where we share information;
- Current or forwarding addresses may be shared with utility companies and Council Tax offices to ensure billing details are correct.
- If you default upon any tenancy/licence conditions information about you may be provided to authorised debt recovery agencies, to enable them to recover the debt. This may affect future applications for tenancies, credit and insurance.
- We may discuss your financial situation, rent payments (including any arrears) and any claims made for welfare benefits with; an external debt advice agency, Welfare rights advisor, the housing benefit department or the local authorities housing advice and homeless prevention team to make sure that benefits are paid correctly.
There are other circumstances where we may also be required to share information, for example:
To meet our legal obligations
In connection with legal proceedings (or where we are instructed to do so by Court order)
To protect the vital interests of an individual (in a life or death situation)
For further information please contact our Data Protection Officer at Dataprotection@southend.gov.uk.
Currently we use the following companies to help us deliver services.
- Kier PLC
- Aaron Services Ltd
- Other repairs contractors
- Mediation service
- Resource Media
- Google Analytics
11. Where your personal data may be processed
The majority of the personal information we store is held on systems in the UK. But there are some occasions where your information may leave the UK either in order to get to another organisation or if it is stored in a system outside of the EU.
We will have additional protections on your information if it leaves the UK ranging from secure ways of transferring information to ensuring we have a robust contract in place with that third party.
We will take all practical steps to make sure your personal information is not sent to a country that is not seen as ‘safe’ either by the UK or EU Governments.
12. What are your rights over your personal data?
An overview of your different rights
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- To withdraw consent if we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
- That we stop using your personal data for direct marketing of our services (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
- Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
Subject Access Requests (SAR)
You have the right to request a copy of any information about you that South Essex Homes holds at any time – this is known as a Subject Access Request (SAR). Also you can request to have that information corrected if it is inaccurate.
When you make a SAR, we have 28 calendar days to provide you with the information you’ve asked for (although we will try to provide this to you as promptly as possible).
You can request to see any of the information that we may hold about you, including CCTV images, but the more specific you can be about what you require, the quicker we can respond to your request.
If you are requesting CCTV footage of yourself, please specify the time, date and location of the footage, and supply a clear photograph so that we can find you on the footage.
Please be aware that we may need to edit some information out, if it relates to other people, as we must protect the privacy rights of all individuals.
In response to SARs, we will provide you with a copy of the information we hold that relates to you. This will not generally include information about your property such as repair logs, details of contractor visits, or general property maintenance information as this is unlikely to be ‘personal information’.
If we choose not to action your request we will explain to you the reasons for our refusal.
To ask us for a SAR, please complete an online form which can be found on the Council’s website. To ask for your information to be amended, please contact our Customer Services team.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
13. Contacting the Regulator
In the Council you can email the Data Protection officer at email@example.com however if you would like independent advice about data protection, privacy and data sharing issues or to lodge a complaint about how we have handled your information you can contact the Information Commissioner’s Office (ICO) at www.ico.org.uk or email firstname.lastname@example.org.
Alternatively you can write to:
Information Commissioner's Office
Cheshire SK9 5AF
Or telephone: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
This privacy notice was last updated May 2018.