Centra, as part of Clarion Housing Group (Clarion), needs to process personal data in order to deliver our services to you as applicable:
- To provide and manage supported housing
- To provide property management and property maintenance services
- In the provision and management of care and support services including telecare
- To deliver on our ambition to ‘transform lives and communities’.
We are committed to treating your information securely, with respect and in line with data protection legislation.
This privacy notice tells you what to expect when Centra processes your personal information. It applies to information about Centra applicants, residents and other service users.
This is the main privacy notice for Centra. However, some of our additional services provided by Clarion Housing Group may also have additional privacy notices which will be provided to you if and when you engage or register for such a service (we will make all privacy notices available on our website (www.clarionhg.com) so you can understand if they apply to you).
It is important for you to read this Notice in full to understand what information we hold about you, how we may use it and your rights in relation to your data. However, we have also produced a summary version explaining why ‘Privacy Matters at Centra ’.
Clarion Housing Group includes a number of subsidiary organisations: Clarion Housing, Clarion Response, Latimer, Grange and Clarion Futures and includes Circle Care and Support Ltd (trading as Centra Care and Support) and Invicta Telecare Ltd (trading as Centra Pulse and Connect) . Please see our website for further information.
We keep our privacy notice under regular review and we will place any updates on our website (www.centragroup.org.uk). If you would like to receive a hard copy of our current privacy notice, please let us know.
For further information you can contact the Data Protection Officer as follows:
The Data Protection Officer
Clarion Housing Group Ltd
Level 6, 6 More London Place
London SE1 2DA
For independent advice about data protection, privacy, e-privacy and data sharing issues, or to make a complaint about how Centra has processed your personal information, you can contact the Information Commissioner’s Office. (Lots of useful information is accessible on their website):
Information Commissioner’s Office,
Cheshire SK9 5AF
Phone: 0303 123 1113
What information do we collect about you and how is this used?
We will only collect personal information when we need this. The type of information we need from you will vary depending on our relationship with you. When we ask you for information, we will make it clear why we need it. We will also make it clear when you do not have to provide us with information and any consequences of not providing this.
Most information we hold will be collected from you but we may also obtain this from third parties such as the local authority, your doctor (or other health professional), a previous landlord or other relevant community partner. In addition, we may also obtain information from publicly accessible sources or engage the service of market research organisations to validate, or where appropriate, enhance the information that we hold.
We collect information (as applicable):
- To prioritise and assess applications for services, checking for eligibility, completing tenancy sign-ups and setting up services including telecare services:
- we will collect your name, preferred name, date of birth, address and contact details (including telephone numbers, email addresses and details of anyone you may choose to represent you) for use across the organisation and by our contractors, suppliers and partners.
- details of your GP, Next of Kin, case worker, cohabiters or representatives, key holder / key safe code should we need to manage an emergencysituation such as facilitating access to your property for the emergency services.
- we will need medical or other details relating to your health for the purposes of managing telecare or support services.
- details about your care agency and nature of service to you, and your housing provider or landlord and their local contact details.
- we will collect detailed personal information about you and other household members*, including age, sex, date of birth, ethnicity, income, National Insurance number, income and benefits details, employment status, gender identity, relationship status, any disabilities, any communication and accessibility requirements, religion, sexuality, nationality, caring responsibilities, access to financial services such as banks and credit unions, bank details, benefits, council tax, medical information, details of any unspent criminal convictions.
* When you provide information about household members we assume that you do so with their full knowledge and consent.
Provision of some of the information requested by us is part of a ‘Contractual Requirement’ (or for the purposes of sensitive / special categories of data, we have a legitimate interest in processing this in order to fulfil our legal obligations under Social Protection Law.) Without this information, we will be unable to accept an application for services. For example, we cannot see if you are eligible for a service or check that an application for housing is not fraudulent without being able to verify your identity. Please speak to us with any concerns.
Where enquiries relate to household members, it is in our legitimate interests to know who will be living in our premises to, check that accommodation offered is adequate for current and near future needs of the household, to check that household members’ needs are being met and to ensure that the local community will have quiet enjoyment of their homes.
Where enquiries relate to your next of kin or representatives it is within our legitimate interests to manage the services that we provide to you.
- To manage your service or tenancy:
- up to date contact details (telephone number and email address) so we can reach you when we need to discuss issues pertaining to your service or tenancy, e.g. income collection, essential servicing, access for maintenance and improvements, if we need to arrange a home visit or to contact you in the event of an emergency or to enforce the terms of your tenancy/ lease/ contract.
- we will also use your contact information to tell you about changes to Centra and Clarion Housing Group, for example our organisational structure and governance arrangements, and to resolve or investigate complaints or housing management issues such as anti-social behaviour.
- details of any change in circumstances (e.g. if you have a medical need that means your service requirements need to be re-assessed we would ask you for supporting information about your change in health) or to effect any changes to your contract or tenancy (e.g. if you want to change your name on our records we’ll ask you for a copy of your marriage or deed poll certificate).
- we will hold records of all our contact with you, your contact with us, and any contact from third parties representing you or about you. This may include call recordings.
- Financial records about the amount of money you (or the person who is contracted to pay) have paid us, any amount(s) outstanding and associated recovery action. Depending on your method of payment and circumstances, we may hold bank account details and or VAT relief eligibility declaration.
- we may hold information about your history, for example regarding credit status or criminal offences, if we need it to look after our staff, business or anyone else.
- details relating to the repair, maintenance and servicing requirements of your home (although this information will not necessarily constitute your personal data).
- If relevant to the service we will collect data from preventative monitoring devices – sometimes known as passive monitoring devices and GPS device tracking sites.
Provision of the information is a ‘Contractual Requirement’(or for the purposes of sensitive / special categories of data, we have a legitimate interest in processing this in order to fulfil our legal obligations under Social Protection Law.) Without this information, we may be unable to manage your services. For example, we cannot consult with you about changes to your service if we do not hold your contact details. Please speak to us with any concerns.
Where enquiries relate to household members, next or kin or personal representatives it is in our legitimate interests to process the information as explained above.
- To meet your needs in our service delivery
- 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 are involved with a carer, social worker or other advocate, if there are considerations we need to apply when we visit you at home, if you need large print or translated text.
- when profiling you for services and to target our resources.
Where processing information about you or your household members, we may have a legal or contractual obligation to process this information for example to provide inclusive services.
It is also in our legitimate interests to ensure that service delivery meets the needs of our service user and their household.
- To prevent fraud and illegal sub-letting and to confirm eligibility for housing
- we will ask for proof of ID and may take your photograph from time to time, e.g. Tenancy Sign-ups or subsequent Tenancy Audits, when the housing composition changes or a reasonable period of time has passed (this applies to all household members over the age of 18).
Processing for the purpose of fraud prevention is required in order to meet our legal obligations. Therefore if we are unable to verify your identity we may not be able to provide services to you.
- To assist with personal security and prevention and detection of crime
- When you engage with our additional guidance, advice and support services.(please remember, other privacy notices may apply)
- For example if you engage with ‘Clarion Futures’, we may hold information about your skills and difficulties in order to help with Digital Inclusion, or if we support you to improve your financial circumstances, we may hold detailed information about your household income and expenditure.
Provision of information requested by us may form part of a ‘Contractual Requirement’. Without this information, we may not be able to provide this service. We will make it clear at the point of data collection whether the information is voluntary.
Where processing also concerns household members, it is in our legitimate interests to ensure that we are meeting the needs and expectations of all service users.
- To understand how we’re performing
- we undertake call recordings for training and quality monitoring purposes.
- we may use your contact details to carry out market research and customer satisfaction surveys to help us to monitor our performance and to improve our services to our customers.
- to segment customers to help target our resources and prioritise services.
- in managing and analysing complaints.
- for statistical analysis.
It is in our legitimate interests to understand how we are performing so we can meet our mission statement and objectives.
There may also be a legal obligation for us to process the information or to demonstrate to our regulator that we are fulfilling our obligations, for example around anti-discrimination laws.
We also use your personal information in the following ways:
- Keeping in touch with you, understanding your needs, and inviting you to events.
It is in our legitimate interests to communicate with you and keep you up to date with news and events in order to meet our objectives around social inclusion and helping to build communities.
- Prevention and detection of crime, and quality management.
We do this to meet our legal obligations.
- Meeting our legal obligations including the requirements of our funders or regulators.
This is a legal obligation on Clarion.
Automated Decision Making and Profiling
We do not undertake automated decision making or profiling which has legal or similarly significant effect on you (where a computer system makes a decision about you without human intervention e.g. deciding if you are eligible for a loan). We do use software tools but any decisions about you are made by our staff rather than ‘automated’. Should this change in the future, we will inform you and explain your rights relating to this, for example that you have the right to challenge the validity of any decisions made in this way or object to automated decision making and ask us not to use this method of processing.
Special categories of personal data
As well as personal information (such as your name, address and data of birth) we may collect sensitive personal information (also known as special categories of data) of which may include:
- Racial or Ethnic origin
- Religious or Philosophical Beliefs
- Sexual Orientation
- Health information
We use this data to ensure services are delivered appropriately and to monitor Equality, Diversity and Inclusion.
We will apply additional security and confidentiality measures when processing your sensitive personal information.
There are times where we will not need your consent to process (including sharing) this type of data. This will apply where we are permitted or required to do so by law, for example under Health and Safety Legislation or where processing of this data is necessary in order for us to carry out our obligations under Social Protection Law. This will apply where we cannot provide services to you without doing this, for example, our telecare services rely on us being able to process data about your health. If you do not wish for us to process this data, you will be unable to continue to receive services from Centra.
Where provision of special categories or data is optional, we will make this clear at the point of collection and will ask for your specific informed consent to process this data. Where you provide consent for us to process data, you have the right to withdraw this consent at any time.
We may also process confidential data about you including bank account information.
How will we protect information about you?
We will apply appropriate technical and organisational measures to ensure your personal information is secure. For example, we have systems in place to ensure that access to personal information is restricted to authorised individuals on a strictly need-to-know basis.
When we need to share personal data with our contractors and third parties, our relationships are governed by our contracts or Information Sharing Agreements with them which include strict data sharing and confidentiality protocols.
To help us ensure confidentiality of your personal information we will ask you (and any of your representatives) 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 written authorisation to do so, where we have received a clear verbal instruction from you (as a one-off circumstance) or where there is a legal order in place such as a Power of Attorney.
Who will we share your information 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 legislation.
Where the information is of a sensitive nature, for example about your health, we will obtain 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’, we may share your information without seeking your consent first. This may be with:
- Our contractors to facilitate property or device repairs, maintenance delivery and installation or removal or improvement works.
- Other organisations in the Clarion Housing Group.
- Debt and money management advisors.
- Care agencies and 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 mailing company distributing our newsletter; 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. More information can be found on the work undertaken by the Cabinet Office at: https://www.gov.uk/government/collections/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.
There may be occasions where we need to process your information outside of the European Economic Area (EEA), for example where we use a third party computer system supported by employees in the USA. Where we do this we will take all necessary steps to ensure that your information remains secure. You can ask us for more information about how our International Processing arrangements affect you by using the contact details above.
Contact arrangements and promotion of our services
We will routinely use your contact details to send you information and communicate with you about your tenancy/service. As a customer, we will also tell you about events in your area. If you have a preferred method of contact, you can make this known to us, but we will use all means of contact available should we need to contact you in the event of an emergency or to enforce the terms of your tenancy/contract.
We would also like to keep you updated with information about other products and services (of ours and other reputable companies we work with) which do not form part of our core services but which we think may be of interest to you and where this will assist us in meeting our Group objectives to transform lives and communities. This would include information such as accessing training and employment, financial guidance, energy efficiency and digital support. It’s a legitimate business interest for us to send you postal communications (from time to time) which may comprise information about all these areas of our work. You can object to receiving this type of content from us in the post. Before sending electronic communications of this nature, we will follow the law and guidance which requires us to seek your consent. You can change your mind at any time. Please just contact us or follow the ‘unsubscribe’ instructions that will be available on all of our promotional publications.
Neither Centra, nor Clarion will ever sell your personal data to 3rd party organisations for marketing purposes.
How long will you keep my data?
Centra 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.
We have a document retention schedule which sets out how long we keep different types of information for. This is based on National Housing Federation guidance, legal requirements and best practice. Please contact us if you would like any more information.
Your rights in relation to your data
Centra is committed to upholding your rights in respect of your personal data.
The right to be informed
Through the provision of our suite of privacy notices, we will be open and transparent about how and why we use your personal information.
The right of access
You have a right to ask us what personal information we hold about you and to request a copy of your information. This is known as a ‘subject access request’ (SAR).
SARs need to be made in writing (we have a subject access form you can use for this purpose), and we ask that your written request is accompanied by proof of your address and identity.
If you are seeking to obtain specific information (e.g. about a particular matter or from a particular time period), it helps if you clarify the details of what you would like to receive in your written request.
If someone is requesting information on your behalf they will need written confirmation from you to evidence your consent for us to release this and proof of ID (both yours and theirs).
We have one calendar month within which to provide you with the information you’ve asked for (although we will try to provide this to you as promptly as possible). 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 constitute your ‘personal information’. Please be clear if you are seeking property or repairs related information as a SAR is unlikely to fulfil your information requirements.
The right to rectification
You can ask us to rectify your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by keeping us informed if your details change.
The right to erasure
The right to erasure is also known as ‘the right to be forgotten’. In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for its continued processing. This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data. Our response will also be guided by the provisions of our retention schedule.
The right to restrict processing
In some circumstances you can ask us to restrict processing, for example
- if you disagree with the accuracy of personal data
- if we’re processing your data on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate grounds entitle us to continue to process your data.
The right to data portability
If the situation arises where it would be helpful for you to move, copy or transfer personal data we hold about you, across different services, you may be able to ask us to do this. Please contact us to discuss.
The right to object
You can tell us if you object to our processing of your personal data:
- based on legitimate interests
- for the purpose of direct marketing ;
Rights in relation to automated decision making and profiling.
You can ask us to review any decisions that are determined by automated means. You can also object to our use of your personal data for profiling.
As explained earlier, we do not currently undertake this and will advise you if this position changes.
If you’d like to talk to us about your rights, you can contact us at firstname.lastname@example.org. Alternatively, if you want to raise a complaint about our processing of your data or would like to seek an independent view, you can contact the Information Commissioner’s Office using the contact details provided at the start of this notice.
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