Purpose of this Privacy Notice
This privacy notice explains how Lewisham Homes will use any personal data you provide to us for yourself and your household. Please read this notice carefully and make sure you understand your rights and responsibilities. As our services develop we will continue to update and review this statement to comply with both the law and resident feedback. Our web site we refer to in this document is www.lewishamhomes.org.uk.The contents of this notice applies to our residents, both tenants and leaseholders, some parts of the document do refer specifically to tenants or leaseholders, as appropriate.
Who we are and our contact details
Lewisham Homes owns and manages its own properties and manages, maintains and develops properties on behalf of Lewisham Council.
Lewisham Homes is a registered data controller under the Information Commissioners Office (ICO), our registration number is Z1142689. In accordance with the Data Protection Act 2018 we collect and process personal information about our residents. We do this in order to provide social housing and services related to housing or as permitted by law.
For further information or queries contact our Data Protection Officer at firstname.lastname@example.org, based at:
Old Town Hall
London SE6 4RU
Full details are set out in the relevant sections of this notice below, but in summary:
We receive personal data relating to you from you directly, but it may occasionally be provided to us by third parties with whom you have a separate relationship (such as a local authority).
We use your data to provide housing and other services to you, correspond with you, meet our legal obligations and improve our products and services.
We provide your personal data to third parties as part of our role to provide housing and services or as permitted by law.
We don’t share your data with third party advertisers.
We store data for specified periods for our limited business purposes.
You have certain rights, prescribed by law, in relation to the processing of your data, such as rights to request access, rectification or deletion of your personal data.
We do have CCTV in operation at some of our sites.
What is personal data?
Personal data is data related to a living individual who can be identified from that data. This can also include categories of personal data (personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, and genetic data, biometric data, health data and data concerning a person’s sex life or sexual orientation) and personal data relating to criminal convictions and offences.
How we use your Personal Data?
Personal data will be processed in accordance with the Data Protection Act 2018.
The exception to this is where we are sending you direct marketing, or in relation to resident involvement (see below). In accordance with the Data Protection Act 2018, we process your personal information as it is necessary for the performance of our services carried out in the public interest i.e. the provision of social housing.
This notice sets out how we use your information in the following circumstances:
- Your Tenancy or Lease
- Resident Involvement
- Marketing Communications
Who do we share your information with?
From time to time we may need to provide third parties with personal information relating to you or members of your household or obtain personal information relating to you or members of your household from third parties. However, this will only be so we can accomplish our responsibilities as a housing provider.
We may disclose your personal details if required to do so by law or any Governmental body.
We try to deal with instances of rent arrears without the involvement of third parties. However, in cases of unresolved arrears and those where arrears remain outstanding after the termination of a tenancy agreement by either party, we may disclose personal details to tracing and/or debt collection agencies.
For arrears of service charges or major works owed by a leaseholder we try to deal with the actions required without the involvement of third parties. However, in cases of unresolved arrears, we may disclose personal details to third parties in order to recover debt.
Your Tenancy or lease
During the life of your tenancy or lease Lewisham Homes will collect and process information about you and members of your household for the following purposes:
There may be some not applicable to leaseholders or alternatives available, these are noted.
- managing your tenancy or lease
- providing safe and sustainable properties
- monitoring compliance with the terms of your tenancy or lease agreement
- delivering support to you or members of your household (note that leaseholders can find detail about relevant support via our web site).
- conducting surveys in order to monitor and improve our services
- providing associated welfare services, advice and support
- maintaining our accounts and records
- recruiting, supporting and managing our board and employees
- recruiting, supporting and managing our agents and contractors that we use to help maintain properties and services
- promoting the services we provide
- carrying out surveys and conducting research
- Local Fraud Initiatives, including working in partnership with the Lewisham Council Anti-Fraud & Corruption Team to tackle tenancy fraud. Lewisham Council may share the personal information you have provided with fraud prevention agencies who will use it to prevent and detect fraud and money laundering and to verify your identity. If fraud is detected you could be refused certain services, finance or employment. For more information about this https://lewisham.gov.uk/about-this-site/privacy/resources-regeneration/privacy-notice—anti-fraud-and-corruption
- corporate administration and all activities we are required to carry out as a data controller
- ensuring we meet our legal obligations as a housing provider
- insurers and/or professional advisers in relation to maintaining insurance coverage
- where you are identified as an alleged victim, witness or perpetrator of anti-social behaviour or are the reporting party in relation to queries, complaints or reports
Unless we specifically advise you otherwise, we will only collect and process personal information that we need in order to carry out these functions.
We will collect the following personal information about our tenants:
- Phone number
- Marital status
- Whether you have any dependants
- National Insurance Number
- Homesearch application number (if applicable)
- Documentation includes:
- For a tenant: one photographic document e.g. passport, national identity card, provisional/full driving license – or a UK birth certificate where none of these are available. Home office ID card for nationals outside EEA and freedom pass. 2 passport photos, legal documents if name changed and home office documents.
- For an adult occupant: one photographic document e.g. passport, national identity card, provisional/full driving license – or a UK birth certificate where none of these are available. Freedom pass. 2 passport photos and legal documents if name changed.
- For a child occupant: full birth certificate, and documentation to confirm tenant is in receipt of child benefit for the child.
If you do not provide us with the information required we will not be able to process your application for a tenancy or provide you with a property that meets your needs.
We will collect the following information about our leaseholders
- For absentee leaseholders: your contact address, telephone number and e-mail address.
Note that if you have purchased your property under Right to Buy we will hold data for you and your household as per the tenant list above. This previous information will form part of your former tenancy record and held in line with our document retention policy.
Collection of personal information for Residents
The collection and processing of personal information allows us to provide a service that meets your needs and the information will be processed for social care purposes and as part of emergency response situations.
For tenants, the collection of criminal conviction information allows Lewisham Homes to monitor housing benefit and to assess the tenancy, such as whether bail conditions exclude the tenant from the property or area. Criminal conviction data would also be collected if a tenant applied to Lewisham Homes for a friend or relative to be a caretaker of the property whilst the tenant is in prison. This information is processed because of Lewisham Homes’ role as an arms-length management organisation to Lewisham Council which has a statutory function to provide social housing and handle housing benefit.
This personal information will be stored on our computer systems and/or a paper tenancy file. It is held securely and we have security measures in place to prevent it from being accessed by any unauthorised person. Lewisham Homes does not transfer your data outside of the European Union.
CCTV is installed on some of our estates to monitor building security and crime prevention and detection. Lewisham Homes has some mobile CCTV, however the main estate based CCTV is operated by Lewisham Council for us and is stored by them.
We operate our CCTV in accordance with the guidance issued by the ICO. The Data Protection Act 2018 covers images of people and information about people derived from CCTV, for example a vehicle registration plate.
Lewisham Homes collects this data as part of its public function as a housing provider to ensure the health and safety of residents and its staff.
We will not hold images for longer than necessary and will dispose of them securely.
Information on Children – this applies to tenants only
We do collect information from you regarding members of your household, this includes information on children.
We collect this data for the purposes of processing your application for a tenancy and providing you with a property that meets your needs.
We do not communicate with children directly and we would not normally share data with agencies or contractors on children.
We may share information on children with the necessary agencies if they were identified as an alleged victim, witness or perpetrator of anti-social behaviour.
Lewisham Homes encourages residents to become involved in helping us to improve the services that we provide. Should you decide to be kept informed about community projects and ways to get involved you will be added to the resident involvement database.
To be added to this database, the following personal information will be collected from you:
- Phone Number
- Email Address
Information on that database will be kept separate from the main database and your personal information will be used specifically for this purpose.
Lewisham Homes may use this information to contact you and for consultation exercises. This information is processed as part of our role as a public authority as resident involvement helps us to improve our services as a housing provider.
Do we send data overseas?
Our business is based solely in the United Kingdom, and so we do not ordinarily send data overseas. We may sometimes make use of cloud-based systems to support the management of our business. Where this happens we will ensure that there are appropriate safeguards in place to protect your rights.
To keep you up to date with the work of Lewisham Homes we may contact you from time to time by email and text and twice a year provide you with a copy of our magazine by e-mail.
To provide you with the updates we process the following types of information:
- Phone Number
- Email address
Lewisham Homes processes your information in this circumstance because we have your consent to do so and you may withdraw your consent to marketing communications at any time. Please note however that Lewisham Homes may still continue to process your personal data for other purposes as set out above, to continue to provide you with social housing.
You can view your marketing preferences and update your settings at any time on My Lewisham Homes.You can call us on 0800 028 2 028 to opt in or opt out of any method of marketing communication. Alternatively you can contact us by e-mail at email@example.com or write to us at Customer Relations, Lewisham Homes, Old Town Hall SE6 4RU.
How long do you keep my Personal Data for?
All personal data is retained in line with the Lewisham Homes Retention & Deletion policy. The following applies:
- Current tenants’ Tenancy Files, including rent payment records, and details of any complaints and harassment cases, are retained for the length of the tenancy plus 6 years thereafter;
- Former tenants’ Tenancy Agreements, and details of their leaving are retained for 6 years;
- If you go on to purchase your property, documentation relating to your statutory right to purchase council housing is retained for 12 years after the sale of the property.
- For leaseholders, we hold the information for the duration of the lease or if you assign the lease to someone else for 12 years after the date of the assignment.
The data we collect and retain for the necessary period of time is sourced through all types of communication, this includes telephone calls, e-mail and paper based correspondence.
How can I apply to see the Personal Data you hold about me?
If you wish to see a copy of the personal data we hold about you then you can ask us at any time and we must respond within 20 working days of the request.
You will not have to pay a fee to access your personal information. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
You can apply by email to firstname.lastname@example.org
Or write to Customer Relations, Lewisham Homes, Old Town Hall, London SE6 4RU.
This section provides some detail on the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. You can read guidance from the Information Commissioner’s Office at www.ico.gov.uk for a fuller explanation of your rights.
Your principal rights under data protection law are the:
(a) right to access
(b) right to rectification
(c) right to erasure
d) right to restrict processing
(e) right to object to processing
(f) right to data portability
(g) right to complain to a supervisory authority
(h) right to withdraw consent.
You have the right to confirmation as to whether or not we process your personal data and, where we do, to access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data. These might include if:
- the personal data is no longer necessary for the purposes for which it was collected or otherwise processed
- you withdraw consent to consent-based processing
- the processing is for direct marketing purposes.
However, there are certain general exclusions of the right to erasure, for example where processing is necessary for compliance with a legal obligation or in connection with legal claims.
In some circumstances you have the right to restrict the processing of your personal data. Where processing has been restricted on this basis, we may continue to store your personal data and will observe the restrictions on processing except in the case of processing permitted by applicable law (for example, in connection with legal claims or for reasons of public interest).
You have the right to object to our processing your personal data on grounds relating to your particular situation, but only that the legal basis for the processing is necessary for:
- the performance of a task carried out in the public interest or in the exercise of any official authority vested in us
- the purposes of the legitimate interests pursued by us or by a third party.
If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing is for legal claims.
You have the right to object to us processing your personal data for direct marketing purposes, including profiling for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.
To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the United Kingdom, the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us.
If you wish to make a complaint about how we are processing your personal information you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). You can find out how to contact the ICO on their web site ico.org.uk
Changes to this Privacy Notice
Lewisham Homes reserves the right to update this privacy notice at any time, and we will notify you when we make any fundamental changes. We may also notify you in other ways from time to time about the processing of your personal information.