Privacy statement

Trafford Housing Trust Customer Privacy Statement

I’m a Trafford Housing Trust Customer – What do you do with my personal data?

Trafford Housing Trust Limited is responsible for keeping the information we collect about you safe and complying with the law when we use it. This is called being a Data Controller.

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What information do you collect about me and why?

How do you get my information? Who collects it?

 

Why do you need my information?

When you live in one of our homes, we need information about you because:

  • When you apply to rent one of our homes, we need to check that you are eligible for it and that you can afford the rent.

  • We have responsibilities as a landlord and need your information to make sure we can carry those responsibilities out. This includes:

    • Carrying out maintenance work for example gas servicing, electrical testing, replacing kitchens, bathrooms or roofs.

    • Completing repairs.

    • Informing you about matters which are relevant to your tenancy or where you live.

  • We need to collect rent from you.

  • If we believe you aren’t complying with your responsibilities set out in your tenancy agreement, we’ll contact you to find out what’s happening. We may need to remind you of your responsibilities and sometimes take action to make sure that you take your responsibilities seriously. This might include us taking legal action against you, for example if you’ve got unpaid rent which you aren’t paying us back, or if you’ve been causing serious anti-social behaviour.

What information do you collect about me and why?

Tenancy Related

We collect information about you in relation to your tenancy agreement. This is a contractual requirement because without them, we can’t make sure that we’re doing our duties as a landlord and you’re doing your duties as a tenant.

The types of information we collect in relation to your tenancy agreement are:

  • Name, address and date of birth, National Insurance Number and other formal identification, so we can identify you.

  • Contact details so we can get in touch with you when we need to.

  • Your financial circumstances including information about benefits you receive, how much you earn, any debts and any other income you receive. If you’re going to be a tenant, we need to confirm you are eligible to rent the home and can afford to pay the rent.

  • Communication preferences – we have a diverse range of customers and it is helpful for us to know information about you which helps us to communicate with you in the way you find easiest. We might therefore ask you to share information about:

    • Disabilities – if this impacts on how we communicate with you. For example if you are deaf we can use assistive technologies to talk to you; if you have mobility issues we will make sure we wait patiently when we knock at your door or call you; if you have learning difficulties we can contact your support worker.

    • Your preferred language, for example if English is not your first language we can access translation services.

  • We collect the name, age and if appropriate contact details of the people who live with our tenants. We use this information to:

    • Confirm that you aren’t sub-letting your home

    • Identify any overcrowding issues

    • Contact someone in the house if we can’t get hold of the tenant or have concerns for their safety

    • Identify potential tenancy fraud

  • Your rent and service charge payments, so that we have accurate records of what you have paid, and take action if you are in arrears. When you are in arrears, as well as asking you to pay them back and taking legal action if you don’t, we will offer you access to our debt and benefit advisors for free. These advisors can help you to organise all of your finances, which in turn will help you to manage your rent payments.

  • When you contact us, we will keep a record of that contact on our electronic system. If you have called the Customer Hub, we will record the call.

  • If someone reports anti-social behaviour to us and it involves someone living in or visiting our property, we will investigate this and keep records of the outcome. Your tenancy agreement gives you the right to quiet enjoyment of your home, and any anti-social behaviour whether caused by you or not is a breach of your tenancy agreement.

Housing with Support

If you live in one of our homes with support (for example sheltered or extra care schemes), we will ask you for some extra information. You don’t have to provide this, but it really helps us to give you a good service if you do. We ask you for:

If you live in one of our homes with support (for example sheltered or extra care schemes), we will ask you for some extra information. You don’t have to provide this, but it really helps us to give you a good service if you do. We ask you for:

  • Some personal profile information about:

    • What people like and admire about you

    • What makes you happy

    • How you would like to be supported.

      This helps us to get to know you and support you in the way you would like, as well as ensuring that healthcare professionals who visit you also consider your wishes when providing you with a service.

  • Any relevant medical history or condition information which you want us to provide in the event that we need to call emergency services for you.

  • Next of kin details if you would like us to contact someone for you in an emergency.

Your Choice

Here is the information we collect about you which you have a choice about whether or not to agree to:

  • You can give us details about your doctor and any support workers you have working with you. This helps us to contact the right people if we are concerned about your welfare.

  • If you are a care leaver, we will ask to keep this information about you, because we are particularly keen to ensure that the products and services we offer help care leavers when they move into their own home. We can also offer you additional support if you are struggling to manage your tenancy.

  • We will sometimes contact you by letter, email or text to ask you what you think of a service you have received. It’s really important to us that we understand what our customers think or our services so we can change and improve them. If you don’t want to receive these communications, you can either ignore them, or you can reply and ask us not to contact you about this at all.

  • If you’ve asked us to send you information about our products and services, we will keep your name and contact details on a marketing database. You can opt out of this at any time by replying to the email or calling the Customer Hub on 0300 777 7777. We won’t ever sell your information to other companies for marketing purposes.

Health, Safety, Wellbeing and the Law

Situations sometimes arise which give us concerns about someone’s health, safety or wellbeing. Health and safety law gives us a duty to make sure that we don’t put people at risk if we can avoid it. We will also take action when we think someone has committed a crime.

  • If we have evidence that you threaten to or actually cause harm to someone else, we will call the Police if we observe this happening. We may also put a marker on your file and advise anyone we ask to visit you to take extra precautions. These markers will be kept under review and removed when no longer appropriate or relevant.

  • If we observe or have evidence that you have committed a crime, we will provide information to the Police or other relevant statutory bodies to help them investigate it.

  • Sometimes we observe situations or behaviour which gives us concern for a person’s wellbeing. For example we might be concerned that someone will commit suicide, or a vulnerable person might be suffering neglect. When this happens, if urgent action is needed, we will call the emergency services. If non-urgent action is needed, we will report the situation to the local council’s Safeguarding Team. We will usually tell you when we make a report to the Safeguarding Team, but please note that it is the law that we report our concerns so you cannot stop us from doing it.

  • We have CCTV cameras in many of our offices and buildings because they help us to prevent and detect crimes.

 

How do you get my information? Who collects it?

We collect your information in a number of ways:

  • Some of the information we collect comes from you when you apply and sign up to become a tenant.

  • We will add to your records when you contact us, and when we get in touch with you or carry out visits. Please always let us know when any of your details change, so we can keep our records up to date.

  • We sometimes employ other organisations to carry out work on our behalf, so they will give us information about their interactions with you.

  • Sometimes other agencies will give us information about you, for example a support worker, healthcare professional, Government bodies such as the Department for Work and Pensions or HMRC or the Local Authority.

 

How will you use my information?

We will use your information to:

  • Assess your suitability for a tenancy.

  • Sign you up to a tenancy.

  • Get in touch with you and keep you informed.

  • Provide you with the services you’ve asked for in a way which meets your needs and preferences.

  • Ensure that you and we are carrying out the responsibilities in your tenancy agreement.

  • Support yours and other people’s health, safety and wellbeing.

  • Investigate complaints including those of anti-social behaviour.

  • Review and improve our services including training staff.

  • Support the Police or other statutory agencies in investigating potential crimes.

  • Develop new products and services.

We will sometimes anonymise your information and use it to create statistics. We might do this for example to measure our performance or to better understand demand for our products. When we create these statistics, it will never be possible to see that your personal information has been used.

 

Who will my information be shared with?

Staff and Managers

Information will be shared with staff at Trafford Housing Trust, so that they can provide the services you’ve asked for. Managers will also be able to see your information, so they can oversee the work their staff are doing.

Sometimes we like to review our processes and services to see what we can learn from them and to train staff. This might involve using an interaction we’ve had with you as a case study.

Sharing with other organisations

Sometimes it’s necessary for us to share information with other organisations. Data protection law sets out a number of different legal bases under which we are allowed to share your information, we don’t always need your consent to do so.

Here are some examples of when your data will be shared with a third party:

  • We sometimes appoint other organisations to help us carry out our duties as a landlord. For example when we need to do some work to your property:

      • We will provide your contact details to a contractor so that they can contact you and carry out the work. If they can’t get in touch with you, we will provide them with the contact details of other adults who live with you.

      • If you have a mobility issue we will inform a contractor that they should knock and wait patiently for you to answer.

      • If you wish for a carer, support worker or translator to be there when the work is done, we will ensure the contractor has the details to arrange this.

  • We have a duty of care to our staff and contractors, and therefore if we have a marker on your file which indicates that someone there has threatened or caused harm, we will inform the contractor of this so that they can take extra precautions to keep themselves safe.

  • When you move in, your circumstances change, or you have vacated a property, we will give your contact details and proof of tenancy dates to the utility companies providing services to the property.

  • We carry out surveys with our customers and stakeholders to see what they think of our customer service. Sometimes we appoint another company to carry out the survey for us so we provide them with customer contact details and other relevant information so they can do their job. We will always have a contract in writing with these companies which is clear about what the data is to be used for and that it must be securely deleted once the work is complete.

  • We sometimes share your information with Government agencies to help you with benefit claims and any tenancy issues, and to help them to fulfil their public tasks. This includes Social Services, local authority council tax and benefits departments, the Department for Work & Pensions (DWP) and HMRC. We may share information with the DWP if you are in receipt of Universal Credit and have significant arrears, in order to make a request for your housing benefit to be paid direct to us. When you sign up for a tenancy, we will ask you to complete a form so that we can supply information to the Ministry for Housing Communities and Local Government (MHCLG) about social housing lettings, for further information about that please read the Privacy Notice from MHCLG.

  • If you own us money, we will make a referral to our internal debt and welfare advisors who can help you with any financial management issues you have. We may also share your data with tracing agencies for the purpose of seeking payment or repaying you if you are in credit.

  • We will share your information with third parties including the Police and other law enforcement agencies, emergency services and lone working service providers in order to prevent or detect a crime, or where we believe the health & safety of an individual is at risk. We will share personal data with a Local Authority in relation to any fraud prevention/detection work they carry out.

  • Where we are providing you with debt advice, we may share your details with other debt advice agencies in order to provide that service. With your permission, we will also contact your creditors, DWP, HMRC, HMCTS, the local authority, other advice services, charities and schools.

  • We will work in collaboration with other agencies, for example healthcare providers, law enforcement agencies, charities and third sector, in order to provide our customers with a more complete and co-ordinated service. This might be when responding to out of hours calls or working with other agencies to provide a complete healthcare service. Whenever we share information in this way, we will ask for your permission first and ensure that the third parties have appropriate arrangements in place to ensure your data is kept secure.

Please rest assured, that before we share your information with another organisation or a person who is not you, we will always confirm that they are authorised to see the information and will keep it safe.

 

Sharing information about complaints

Sometimes when a customer makes a complaint, particularly if it relates to anti-social behaviour, we will need to share some of the information in that complaint in order to investigate it. When this happens we will:

  • Talk to you about what action we will take to investigate the issue.

  • Seek to protect your identity if you have reported an issue in confidence. This may not be possible all of the time, but we will talk to you about it before saying anything to the person you’re complaining about.

  • If the issue you have reported gives is concerns for someone’s wellbeing and is therefore a safeguarding matter, we will report it to the Council’s Safeguarding Team. This is a legal requirement for us.

    When we have finished an investigation we will give you as much information about the outcome as we can, but we may have to keep back some information if it relates to other people.

 

Can someone else speak to you on my behalf?

You might like to have a family member or another advocate who is able to speak to us on your behalf. To set this up, please can you either put it in writing or telephone the Customer Hub on 0300 777 7777. You will need to confirm who you want to give permission to speak to us and whether you’re giving permission for everything to be discussed, or just certain matters e.g. rent and repairs.

If you contact us by telephone, we will take you through a security check so that we are confident we are speaking to the right person. We also ask you to set up a password for the person you are authorising, which we will ask them for each time they contact us.

If one of our customers does not have the capacity to speak to us, we will need a copy of a Power of Attorney or similar so we know who has permission to manage their account. 

 

How long will you keep my information for?

  • We need to keep most of your information on our files for 6 years after you stop using our services. This is so that, if there are any problems or complaints which might result in a legal or insurance claim, we have the information we need to respond to them.

    We keep some information for less than 6 years, here are some examples:

  • The information listed in the “Your Choice” section will only be kept for as long as you want us to keep it. You can ask for it to be erased, or opt-out, any time you like. Please contact customer.hub@traffordhousingtrust.co.uk if you want to do this.

  • We keep recordings of telephone calls to the Hub for 12 months. Please note that prior to 1st April 2018, we only kept telephone recordings for 30 days.

  • CCTV is stored for 30 days and then deleted.

  • Any photographs and videos presented as evidence for an anti-social behaviour investigation will be deleted immediately after the case has been closed. Given the sensitivity of this information, it is not appropriate for us to keep it any longer than that.

  • We keep paper copies of documents which have been scanned on to our electronic systems for 6 months in case there are errors when scanning them.

 

Where is my data kept?

The servers which host our computer systems are all based in the UK. We have agreements in place with service providers to ensure that your information is kept safe and in line with data protection law.

We hold some paper records, These are stored securely at our offices and are confidentially shredded by a reputable firm when we no longer need them.

 

How do I know my data is safe?

We train all of our staff on data protection matters, so that they know how to keep your information safe and what they can use it for. Staff are banned from sending the personal data of any customers outside of the business unless they sending it securely to someone who is authorised to have it.

Our computer systems are all accessed by a user name and password so there is less risk that someone will be able to log on who isn’t authorised.

Information kept in our office is in locked cupboards and only staff who need it have access to it.

When you get in touch with us, we will ask you some questions to confirm your identity.

When we come to visit your property for anything other than routine repairs and maintenance, we will not tell anyone else what we are there for unless you have said this is ok.

As emails are not a particularly secure way of sending information, if we are emailing you with something which we think is confidential or sensitive, we will password protect it if sending it by email.

 

Access to my information

You can ask us for a copy of the information we hold about you at any time, for more information about how to do that, contact the Customer Hub on 0300 777 7777 or email customer.hub@traffordhousingtrust.co.uk.

 

Complaints

If you’re unhappy with something we’ve done to do with your personal information, please get in touch and tell us, so we can put things right. You can visit our website to make a complaint.

If you have a complaint about the way we have used your personal information, you can also contact the Information Commissioner through their website ico.org.uk/ or by calling 0303 123 1113. They will get in touch with us to check we’re using your information properly and complying with the law.

 

Stronger Families

Trafford Housing Trust works with Trafford Council on a project called Stronger Families. This forms part of the One Trafford Response model, and details of what they do with the information they collect about people can be found here.

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