Privacy Statement

It applies to information about housing applicants, residents, tenants, leaseholders, and any other customers of Town & Country Housing (TCH).

It explains why we may process your personal data and the legal basis for the processing (‘processing’ includes us just keeping your personal information). It also explains the choices you have about the data we hold about you.

This notice applies to personal data held by Town & Country Housing whether that information is collected via our website or through any other contact.

We make sure our privacy notice is kept up to date. You can find the latest version on our website (www.tch.org.uk). If you would like a hard copy, please see the “contact us” section of our website for details of how to get in touch with the relevant contact centre and we’ll send you one in the post.

We have separate privacy notices for Love Living Homes. You can find these on our website.

Who we are

How we collect your information

How we use your personal information and the legal basis for processing

Sharing your personal information

Experian and The Rental Exchange Programme

Children

Recording telephone calls

IP addresses

Keeping your personal information

Transfers outside the UK

Your privacy rights

Town and Country Housing is the data controller whose head office is located at Monson House, Monson Way, Tunbridge Wells, Kent TN1 1LQ.  We own and manage more than 13,000 homes across the South East. Our mission is to deliver quality homes, build communities and improve lives. Our vision is to provide homes that people choose.

If you would like to find out more about how we use your personal information, you can contact the Group Data Protection Officer at data_protection@tch.org.uk.

We collect most of our information directly from you, including when you apply for one of our properties or services, complete one of our forms, when you write, email or meet with us, or respond to a survey.

We also collect information from other third parties where is it relevant to our relationship with you. This includes customer survey providers or organisations that carry out maintenance and repair services on our behalf as well as:

Local councils and central government departments such as the Department of Work and Pensions – for information about your benefits

Local authorities, health and social care professionals, previous care providers – for information about your health, care and support needs, and those of your household (including your children)

Previous landlords and credit agencies such as Experian – for your rental history, credit checks and information about your financial status/history

Home Office, local authorities – for information about your immigration status, where relevant

Police and other public authority fraud departments, local authorities – for information on criminal activity, but only where it is relevant to your tenancy or application

Other residents – we may receive information in relation to complaints.

To assess your housing application and manage our contract with you

We use the information we hold about you to manage your tenancy or leasehold. We need this to deliver our housing services to you. We collect most of this information because it is necessary in the performance of a contract. You will not be able to opt out of providing this type of information.

We also process some of your data because it is in our legitimate interests to do so. You can object to this processing if you think that your legitimate interests outweigh ours.

We consider that we have a legitimate interest to make sure that:

Our services/properties meet the needs of our customers;

We can contact residents in the event of emergencies and to carry out essential repairs;

We communicate with residents to meet our business objectives, encourage social inclusion and help build communities;

We work with authorities and the police to support safer communities;

TCH remains commercially viable and protects its commercial and social assets;

We have effective procedures for preventing, and managing, outstanding debt resulting from unpaid rents;

We make the most efficient use of our resources and we understand how we are performing; and

We understand our residents’ experiences and views so that we can effectively influence and contribute to debates on future housing strategies.

To provide appropriate properties and services

We process personal information that relates to your health and social care, to help us make any reasonable changes to our properties and services, to make them fit for purpose and accessible for everyone. We also use this type of information to make sure we are protecting vulnerable individuals in our communities.

We do this to meet our legal and regulatory obligations, for example, the Equality Act 2010, and because there is a substantial public interest for us to do so.

To promote community safety and a peaceful community environment, and to safeguard individuals

We process personal data to promote a peaceful and safe community environment; this can include information about anti-social behaviour, criminal activity and convictions. We process this information because it is in our legitimate interests to do so and to prevent and detect unlawful acts.

We process information about safeguarding individuals, to fulfil our legal obligations and because there is a substantial public interest for us to do so.

To contact you about your property and other services

We use your contact details (including telephone numbers and email addresses) to get in touch with you about issues relating to your tenancy or leasehold and to deal with any legal matters arising from it. This includes repairs and maintenance, rent collection, complaints and housing management issues, in the event of an emergency, or to enforce the terms of your tenancy or lease.

We may pass on your details to contractors that provide services on our behalf, so that they can contact you to carry out essential services related to your property. We do this because it is necessary in the performance of a contract. It is not possible to opt out of this type of data processing. Where we do not have the appropriate contact details for you, we may also try and source these externally from other third parties or public sources of information.

We’re constantly working to improve our services. One of the ways we do this is by listening to our residents and asking for feedback via surveys. These surveys are carried out by contractors who are specialists in customer feedback. In such cases, we pass on your contact details to them so you that they can contact you and ask about our performance. It is in our legitimate interests to use your contact details this way, however you may opt out of further contact by letting the person requesting feedback know that you do not wish to take part in future.

We also use your contact details to keep you updated about TCH events or other services which do not form part of our contractual landlord service, but which may be of interest to you. This includes our e-newsletter and letting you know about things such as accessing training opportunities, energy efficiency, digital support, housing options events and financial advice. It is in our legitimate interests to use your contact details this way, however you may opt out of further contact by simply selecting the opt out button in the email or text.

To monitor equality, diversity and inclusion

We may ask you to provide us with your diversity data (ethnicity, religion, disability, sexual orientation). This information is not used to inform any decisions we make about you individually, but is gathered for statistical purposes to help us understand who is living in our communities. It helps us to ensure fairness and equality in the services we provide, and allows us to fulfil our legal and regulatory obligations. You do not have to provide this information but it helps us if you choose to do so.

To prevent and detect fraud and illegal subletting

We process some personal data to guard against fraud and illegal subletting, for example proof of identity. Failure to provide any information we require in relation to this could put your application or tenancy at risk.

We process this type of information to fulfil our legal obligations and to prevent and detect unlawful acts.

For profiling purposes

We use some of your personal data to create a profile of you so that we can identify relevant TCH services that might be of interest or helpful to you. For example, if information suggests that you might be having some difficulties with managing your finances, or we think you might encounter difficulties in the future, we can direct you to our Welfare Benefits and Money Advice Team. Alternatively, if our information suggests that you might be a vulnerable tenant because of age, or ill health, we may offer you an enhanced service.

We rely on our legitimate interests to process information for these purposes.

To support research and analysis

We may use your personal data to carry out internal research and analysis. We do this to develop and improve our services and to help us understand trends within the housing sector. We process information based on our legitimate interests for these purposes.

Data processors

We also share some information with our data processors, which are organisations that carry out a service on our behalf. This includes repairs and maintenance, gas servicing and debt collection. We only share information which is necessary for them to carry out the service they have been contracted to provide. All our contractors operate under the terms and conditions of a legally enforceable contract and will not use your information for anything other than carrying out a service on behalf of TCH.

In most instances we do this because it is necessary in the performance of a contract, i.e. your tenancy or leasehold agreement.  Where that does not apply we process this information based on our legitimate interests.

Ministry of Housing, Communities and Local Government (MHCLG)

We share information about social housing lettings data with the MHCLG. It is a regulatory requirement for all registered providers to supply this data as per the Tenancy Standard. The Tenancy Standard is a non-statutory Code of Guidance which we are obliged to follow.

The data sets we share include information on lettings, type of tenancy, rents and charges, demographic information about tenants (including special category data and criminal convictions) and financial information. The data set does not include names or addresses but does include the unique property reference and the full postcode.

This information is used for research and statistical purposes to allow the MHCLG to exercise their role in providing adequate social housing. The information cannot be used for any other purposes, such as making decisions in relation to specific individuals.

We share this information because it is necessary for the performance of a task carried out in the public interest and/or for reasons of substantial public interest. Individual are not able to opt out of this process.

MHCLG have their own Privacy Notice which can be found here and where you can find more information about the process and who to contact if you have any concerns.

Others

Other organisations we may share your information with include:

Local councils and government departments (including the Ministry of Housing, Communities and Local Government)

Health and care services

Police and other law enforcement agencies

Electricity, water and gas companies

Social Housing Regulator

MPs and Councillors acting on your behalf

Experian and The Rental Exchange programme

Other social landlords

Building societies & banks

Solicitors

We share some of your personal data with Experian, a consumer credit reporting agency. This is to help us prevent and detect fraud and illegal subletting and to manage our rental arrears. We also receive information about you from Experian for the same purposes. We process this information to fulfil our legal obligations and to prevent and detect unlawful acts.

As part of the Rental Exchange programme, we share your rental payment history with Experian. This programme allows tenants with a history of little or no credit, who are paying their rent on a regular basis, to build up a credit score. You can opt out of the Rental Exchange programme at any time by contacting us. Please see the “contact us” section of our website for details of how to get in touch with the relevant contact centre and we’ll opt you out.

We exchange information as part of the Rental Exchange programme because it is in our legitimate interests to do so.

If you would like more information, you can visit www.experian.co.uk/rental-exchange or call Experian on 0115 941 0888 and ask for a copy of the Rental Exchange brochure.

We do not usually gather information directly from children as part of our core landlord service. We may process information relating to children in our households where it has been provided to us during our relationship with you. In such cases, we process that information based on our legitimate interests and to fulfil our legal and regulatory obligations.

We may record your telephone calls to our Customer Contact Centres and Collections Teams, for training and monitoring purposes and to make sure we’re delivering a good service. We process data in this way because it is in our legitimate interests to do so.

If you visit our website, we collect your Internet Protocol address. TCH logs this information for internal review purposes. For example, this log information helps us determine how well our services are working so TCH can continually improve the quality of its web sites. The log information is also important for security, audit and quality improvement.

How long we keep your personal data for can depend on the type of data it is. We will never keep your information for any longer than is necessary for the purposes we need to use it for. We keep information on our tenancy files for up to six years after the tenancy ends. We hold CCTV footage for 31 days. We hold recordings of telephone conversations to our Customer Contact Centres for no longer than 18 months.

Occasionally, we may need to transfer your personal data outside the European Economic Area (EEA) to other subcontractors or agents. For example, if we were to use an IT service whose servers are situated outside of the Europe. Where this is the case we will take the appropriate steps to ensure that we only contract with organisations that have the appropriate security measures in place.

You have several rights which allow you to choose and control how we use your data. These rights are explained below. If you would like to exercise these rights, please see the Contact us section of our website for details of how to get in touch with the relevant contact centre.

Transparency: You have the right to be informed about how we are using your data. If you think we are doing something with your information that we have not told you about in this Privacy Notice, you can object to this.

Access: You have the right to ask us what personal information we hold about you, and to request a copy, free of charge. Please note if we consider that the request is manifestly unfounded, excessive, or repetitive, we can charge a reasonable fee. This fee will be based on the administrative cost of providing the information.

Objection: You can object to the processing of your personal data. You should note that this right does not apply in all circumstances, for example, where we are processing information because it is necessary in the performance of contract we will not be able to stop processing this information.

Withdrawal of consent: if we are processing your data based on your consent, you can withdraw this consent at any time. Where this is the case we may no longer be able to provide the relevant service to you.

Rectification: If you think that the personal data we hold about you is inaccurate or incomplete, you have a right to request that it be rectified.

Erasure: You can ask us to delete your personal data where it is no longer necessary for us to use it, where you have withdrawn consent (if we process based on consent), or where we have no lawful basis for keeping it.

Restriction: You can ask us to restrict the personal data we use about you where you have asked for it to be erased or where you have objected to our use of it.

Data portability: You can ask us to provide you, or a third party (if possible), with some of the personal data we hold about you in a structured, commonly used, electronic form, so that it can be easily transferred.

Appeal: If you are not satisfied with the way that we have dealt with your personal data, please let us know and we will try and resolve your concerns. If you are not satisfied with the outcome, you can make a formal complaint through our website.

If you are still not happy with our response, you have the right to appeal directly to the regulator – the Information Commissioners’ Office https://ico.org.uk, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113.