Why do we collect your data?
We will need your data to manage various elements of your tenancy. During the term of your tenancy, we may need to contact you to discuss the balance on your rent account and to help you manage your payment situation.
If you contact us regarding maintenance issues we also need your data to arrange for contractors to attend your property. We need your details to arrange for contractors to attend your property for a number of other purposes including but not restricted to annual gas safety inspections, smoke alarm testing and arranging improvement works to your property.
Your details also enable us to verify your identity when you call us.
GCHA is also a registered provider of social housing and a charitable entity, and as such is governed by various legislation. When letting our properties, we have to ensure that these are being let to persons who are entitled to social housing properties. In line with this, we need to keep evidence to show that we have appropriately verified your identity and your entitlement to social housing. On all lettings, we additionally need to be able to evidence that you have entitlement to reside in the European Union.
How do we collect your data?
Most of the data we hold about you has been provided directly by you.
When you make an application to live in one of our properties, we receive basic information about you either from the Kent Choice Based Lettings system, where this relates to social rented properties or directly from you regarding market rent properties.
When you commence your tenancy with GCHA, we run a number of checks and ask you to provide documentation to evidence that you meet the criteria discussed in the above section. This, together with the forms we ask you to complete at this point provides the most part of the data we hold about you and supersedes the previous data we attained when you applied for your housing.
During your sign-up process, we run a background check on you. This is carried out to help minimise fraud and to ensure and evidence that you meet the criteria necessary to move into your property. For market rented properties this may also include earnings verifications.
When there are changes to legislation that require us to hold additional information, or for us to ensure we hold correct information for you, we may also send you additional requests for information.
We may also check your details if you call us, and information provided on the phone call can be recorded in our system.
We may also receive data from third parties that you have a separate relationship with such as government bodies and support organisations. As an example, this could be from a local authority or the Department for Work and Pensions (DWP) regarding benefit payments.
We hold both hard copies of your data in secure units and electronic copies in secure network locations. Our network locations and back-ups are all located in EMEA areas and those are all EU GDPR compliant.
What do we collect that can identify you?
During your tenancy sign up process, we will require the name, address, date of birth and National Insurance number of each individual whose name is on the tenancy.
To help manage your tenancy, we will also ask for home and mobile phone numbers, an email address and any housing benefit or DWP reference numbers. Pending which are relevant to you, we will also hold these on our systems.
Following the checking and verification process, we will also hold copies of documents that evidence your identity and your right to occupy our housing. This may include your passport or documentation that evidences your right to remain, your driving license or your background check. Your background check may also include your previous addresses.
If you have been given permission to speak to us on behalf of one of our tenants, we will look to hold some core data about you to allow us to verify who you are when you call in.
Whilst we check bank account details in your sign-up process, these are not retained. Direct debit forms are also not retained by us and any bank or card details used when processing payments with our payment partners are stored securely and these details cannot be extracted from those systems.
We will also have records of the payments you have made to us, which are processed through our payment partners. These will be replicated in our accounting system, which will hold a full record of your transaction history with us.
We will hold most data we collect while you remain a tenant of ours or if we have a legitimate interest, such as if you owe us money. We will keep data for up to six years after the end of a tenancy. Unless you request us to destroy it, we will keep core information to evidence your tenancy (name, address, start and end dates of tenancy) should you ever require this under government schemes to help you to home ownership.
Where there is not a need to keep some data records, we will destroy this sooner. For example, we will destroy any housing benefit notices that are over two years old and government CORE forms are destroyed once these are input into the government system.
Is there anything else we hold that doesn’t identify you?
We carry out an annual tenant survey to collate your opinions on the service we provide. On the survey, you may have provided us with your name and/or address which we would use to address any concerns you have with our service. Once we have fully followed up any queries raised and made any prize draws, the data we hold will not include your name or address.
As mentioned above, data recorded by cookies records an IP address rather than your name but can be used to identify where you have connected from. The link to the cookies policy is above.
Do we pass on your data to any other third parties?
In order to manage your tenancy, we must be able to pass some key information to third parties. One key area is in relation to resolving maintenance issues for you. When you contact us regarding a maintenance issue at your property we will need to pass your name, address and contact telephone number(s) or email address to our contractor so that they can contact you. If you have provided us with specific requests for when anyone visits your property, these will be passed to our contractor so they can adhere to your requests. Our contractor may then pass this data onto a subcontractor if that subcontractor is the company that will carry out the work.
Contractors and subcontractors may also contact you directly on other maintenance issues. Whilst not exhaustive, the below lists the principal areas for which a contractor may contact you:
- to book gas or electrical safety inspections;
- to arrange a time to test your smoke alarm and inspect any fire equipment on site;
- to arrange an improvement to your property, such as a new kitchen or bathroom;
- where claims adjustors may need to view your property regarding an insurance claim;
- to view your property for the purposes of carrying out a valuation, as required by our lenders;
- where a contractor may need to visit your property under a warranty claim.
There are a number of third parties we work with, and we will endeavour to ensure that there is an up to date list of contractors on our website.
There are a number of other areas where we share data for the purposes of managing your tenancy. Where agreed, we may speak to Local Authorities or other professional bodies, though this will only be in relation to your housing situation and tenancy support needs. If there is a deposit on your property, we will share sufficient information to lodge the deposit with a deposit protection company. We will also set you up an account with our payment partners, which will involve sharing your name, address and customer reference number.
Other parties who may have exposure to your data are our IT support companies who help manage our network and systems, and our auditors who are required to review our systems and processes.
Where other circumstances arise, we may share data where:
- it is necessary to manage your tenancy;
- there is a legal obligation for us to do so;
- it is necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
We do not sell or pass any information to other third parties for marketing or advertising purposes.
What rights do I have over my data?
Your principal rights under the data protection law are:
- the right to access
- the right to rectification
- the right to erasure
- the right to restrict processing
- the right to object to processing
- the right to data portability
- the right to complain to a supervisory authority
- the right to withdraw consent.
You can ask us what personal data we process about you, and you can update, remove or correct data we hold where this does not affect our ability to manage your tenancy or compromise our obligations to hold relevant information.
You have the right to request that we update, correct, or delete (assuming that this does not impact the services we are providing to you) your personal data at any time. Please note that we may reject requests which risk the privacy of others or are unreasonable or repetitive.
You have the right to opt out of the use or collection of certain data by us and you have the right to opt-out of receiving our email newsletters, bulletins, or other information at any time. To discuss this further, please contact our office through the usual routes.
You can read guidance at the Information Commissioner’s Office website at www.ico.gov.uk. This will provide a more detailed explanation of your rights.
GCHA reserves the right to amend and/or update this policy as required.