Privacy

ASPIRE HOUSING LIMITED own the trading name Cerris Homes. ASPIRE HOUSING LIMITED is registered as a Data Controller with the Information Commissioner (registration number Z7678641). Our Registered Office is Aspire Housing, Kingsley, The Brampton, Newcastle-under-Lyme, ST5 0QW Telephone: 01782 635200

ASPIRE HOUSING LIMITED is a leading housing provider, place shaper and property developer. We are a financially strong business. Profits are reinvested in new homes, in revitalising communities and in a comprehensive range of innovative support services, designed to transform lives.

ASPIRE HOUSING LIMITED is a Registered Society under the Co-Operative and Community Benefit Societies Act 2014 with number 31218R. We are also authorised by the Financial Conduct Authority to provide Debt Counselling & Debt Adjusting (FCA registration number 672504).

How we collect personal information

We get information about you from the following sources:

• Directly from you.
• Local Authorities, such as Newcastle Housing Advice and Cheshire East Council, who refer housing applications to us.
• Referees you provide, previous landlords and employers.
• Social workers, medical professionals, credit reference agencies and mortgage brokers and lenders who provide us with information relevant to your sales application and housing needs.
• Aspire employees and contractors who deal with you.
• CCTV images that we operate at our offices, residential blocks and community schemes.
• Key fob usage of communal entrances in residential blocks.

If you provide us with personal information relating to members of your family, household, or associates we will assume that you do so with their knowledge.

We will collect, process, share and securely store personal information in order to operate as a registered provider of housing and deliver efficient and effective services.

All information will be retained in accordance with the requirements of our retention schedule.

Below we describe the different lawful basis for processing personal (Section 4.1) and special categories of personal data (section 4.2). We then describe the purposes and lawful basis under which Aspire Housing processes data (section 4.3).

4.1 Shared Ownership Sales

To prioritise and assess Shared Ownership applications, eligibility, and complete sales the lawful basis we rely on for processing the following personal data is article 6(1)(b) of the GDPR, processing necessary to Perform a Contract or to take steps at your request, before entering a contract. This includes when you contact us to increase the share you own.

We will need your name 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. We will collect detailed personal information about you and other household members, including previous addresses, age, date of birth, National Insurance number, income and benefits details, employment status, relationship status, nationality, caring responsibilities, and bank details.

We will also collect information about any disabilities, any communication and accessibility requirements and medical information relevant to your housing needs. Please see the section below headed Special Category Data for more information.

We process data about criminal convictions and offences with your consent under article 10 of the GDPR and the DPA 2018, Schedule 1, Part 2 and Part 3.

If your application for Shared Ownership is successful, we are legally obliged to share your details about your background, but not your name with the Department Levelling Up, Housing and Communities. You can read about how they process your information here; CoRE Privacy Notice.

4.2 Managing Tenancies

To manage your tenancy, we continue to rely on the lawful basis of the processing being necessary for Performance of a Contract, article 6(1)(b).

We need up to date contact details (telephone number and email address) so we can reach you when we need to discuss issues pertaining to your tenancy, e.g. rent collection, access for maintenance, repairs 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. We keep details relating to the repair, maintenance, and servicing such as gas & electricity inspections of your home (although this information will not necessarily constitute your personal data).

Financial records about the amount of money you have paid us, any amount(s) outstanding and associated recovery action. Depending on the method of payment, we may hold your bank account details.

We would like to keep records of your circumstances up to date and ask that you help us to do this (e.g. if you have a medical need that means your housing requirements need to be re-assessed we would ask for supporting information about your change in health needs) or to effect any changes to your tenancy (e.g. if you want to change your name on our records we ask for a copy of your marriage or deed poll certificate).

We carry out the following processing because it is in our Legitimate Interest (article 6(1)(f)) to provide the best service we able. We will use your contact information to tell you about changes at Aspire Housing that effect you. We will hold records of all our contact with you, and any contact from third parties representing you or about you. This may include call recordings, online chat, and SMS messages.

We are under a Legal Obligation, article 6(1)(c) and there is often a public interest in carrying out a Public Task, article 6(1) (e) of the GDPR, to carry out the following processing.

To prevent fraud and illegal sub-letting and to confirm your ongoing eligibility for housing. To investigate and resolve complaints or housing management issues such as Anti-Social Behaviour which may result in us collecting relevant information about you.

4.3 Lawful basis for processing Special categories of personal data

We routinely process the health data of housing applicants, tenants, and residents where it is relevant to their housing needs and the provision of our services. We rely on GDPR Article 9 2(b), and the Data Protection Act (DPA) 2018 Schedule 1, Part 1 (1) (social security and social protection).

When we deal with antisocial behaviour complaints, we will process special category data under Substantial Public Interest (GDPR Article 9 (g)) and the DPA 2018 Schedule 1, Part 2 (10) (Preventing or detecting unlawful acts).

We also collect faith, race and sexual orientation data to monitor equality, diversity and inclusion to help ensure our services are delivered fairly. The lawful basis we rely on to process this information is Consent and the DPA 2018, Schedule 1, Part 2 (8) (Equality of opportunity and treatment).

We collect information that you provide about criminal convictions and offences so that we can safeguard our employees and the communities where we are the landlord. The lawful basis we rely on to process this information is Employment and Social Protection Law (GDPR Article 9 2(b)) and Substantial Public Interest, 9 2(g)) and the DPA 2018, Schedule 1, Part 1 (Employment and Social Protection Law) and Part 2 (Substantial Public Interest)

The DPA 2018 requires us to have an Appropriate Policy Document (APD) for certain conditions of processing special category and criminal offence data. Our APD sets out and explains our procedures for securing compliance with the principles of GDPR and policies regarding the retention and erasure of such personal data.

 4.4 Customer Forum

As a customer, we may approach you to take part in our customer forum. We further process your information in relation to this as a Legitimate Interest to improve our services, Article 6(1)(f). Your participation will be for a specified period, and you may withdraw your consent at any time.

• Security

We operate CCTV for the prevention of crime at all our office premises (both outside and inside), in the communal areas and entrances of residential blocks we own and manage and in public areas of retail and community schemes we manage.

If you are issued with a key fob to gain access to the main entrance of a block the key fob reference will be recorded against your name. The use of key fobs is recorded on a secure, computer-based system to manage the security of the building and the issuing of key fobs.

We carry out the above processing because it is in our Legitimate Interest (article 6(1)(f)) to secure our properties and it is in the Public Interest (article 6(1)(e)) to prevent crime and anti-social behaviour.

• Marketing

If you sign up for emails through our website, at an event or meeting, we will send you these until you withdraw your Consent (article 6(1)(a) of GDPR). You can do this by clicking on the unsubscribe link in each email or by contacting us.

If you are a Tenant, we will send you emails using our Legitimate Interest (article 6(1)(f) of GDPR). You can unsubscribe from marketing emails at any time. We may declare some emails or text messages as Service Messages which are not subject to marketing rules.

4.7 Customer Surveys

 The Regulator of Social Housing (“RSH”) requires Housing Associations, such as Aspire Housing, to engage with customers over the delivery and performance of our services. This is set out in the Tenant Involvement and Empowerment Standard. We carry out this processing because it is in our Legitimate Interest (article 6(1)(f)). We have a legitimate interest to contact you and find out how we can improve our service through our market research surveys. We also have a legitimate interest in making our products and services the best they can be and promote the success of our organisation. We may email, text or call you in order to gather any information.

The GDPR has provisions on:
•    Automated individual decision-making (making a decision solely by automated means without any human involvement).
•    Profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.

Aspire Housing analyse rent payment data to help understand which tenants are most likely to fall into arrears. This enables us to contact customers and help them manage their rent account and help them maintain their tenancy.

We retain.

• Unsuccessful tenancy applications for 6 months.
• Details of Tenancies for 6 years after the termination date.
• Recordings of calls to our contact centre for 40 days.
• CCTV recordings for 30 days.

We may deviate from the above if

• We are legally required to retain information for longer.
• The information relates to a complaint.
• We are preparing information in relation to a legal claim.

The above and all other information we keep, and how long we keep it for is defined on our retention schedule.

In certain circumstances we may need to share your personal data with other organisations. When we share personal data to complete a task, we will only share the minimum personal data required to complete that task. We will never sell, rent or trade your personal data.

We will also pass your information on to third parties whom you may ask us to, for example if you ask us to put you in contact with professional advisors.

Who we share data with

We may share your data with the following organisations.

• Auditors, business associates and professional advisers
• Charities and voluntary organisations
• Courts and tribunals
• Credit reference agencies.
• Current, past or prospective employers
• Debt collection agencies
• Emergency services
• Health Authorities, Healthcare, social and welfare organisations, probation services
• Local and central government (we share data of Tenancy Applicants through CoRE, to the Department of Levelling Up, Housing and Communities– see more information and their privacy notice here). We share Housing Benefit and Universal Credit data with the DWP and the relevant Local Authority. We share Council Tax liability information with the local authority. We share data about property sales with Homes England.
• Other landlords, housing associations and property exchange platforms
• Repairs and maintenance contractors (It should be noted that within the terms and conditions of your tenancy agreement it states that you will allow contractors of Aspire access to your property to carry out repairs and maintenance).
• Survey and research organisations.

Where we use data processors, we have a written agreement with them that ensures your data is protected and secure.

We have a legitimate interest to ensure utility bills are accurate and assigned to a new tenant. We use a utility broker as a single point of contact to liaise with tenants, Aspire and the utility companies.

When you move into a WDH property we share your name, contact details and the start-date of your tenancy with the utility broker, Energy Angels (https://energyangels.co.uk/).

We use contractors to carry out property repairs and maintenance who we give your contact details so that they can liaise with you.

We use several technology data processors to store data, provide electronic communications, maintain CCTV and operate key fobs.

Under the GDPR you have the following main rights:

1. The right to be informed about how and why we gather your personal information, how we keep it and what we do with it.
2. The right to access the personal data we hold about you. This is known as a ‘subject access request (SAR). SARs need to be made in writing and we have one calendar month to provide you with the information you have asked for. The period of compliance may be extended to two months where requests are complex or numerous.
3. The right to have the information rectified if it is inaccurate or incomplete.
4. The right to have your information erased from our records. You can do this where:

• the information is no longer necessary in relation to the purpose for which we originally collected/processed it
• where you withdraw consent
• where you object to the processing and there is no overriding legitimate interest for us continuing the processing
• where we unlawfully processed the information
• the personal information has to be erased in order to comply with a legal obligation

We can refuse to erase your personal information where the personal information is processed for the following reasons:

• to exercise the right of freedom of expression and information;
• to enable functions designed to protect the public to be achieved e.g. government or regulatory functions
• to comply with a legal obligation or for the performance of a public interest task or exercise of official authority;
• for public health purposes in the public interest;
• archiving purposes in the public interest, scientific research historical research or statistical purposes;
• the exercise or defense of legal claims; or
• where we have an overriding legitimate interest for continuing with the processing

5. The right to object to processing where we say it is in our legitimate interests. We must stop using the information unless we can show there is a compelling legitimate reason for the processing, which override your interests and rights or the processing is necessary for us or someone else to bring or defend legal claims.
6. You have the right to require us to stop processing your personal information. When processing is restricted, we are allowed to store the information, but not do anything with it. You can do this where:

• You challenge the accuracy of the information (we must restrict processing until we have verified its accuracy)
• You challenge whether we have a legitimate interest in using the information
• If the processing is a breach of the GDPR or otherwise unlawful
• If we no longer need the personal data but you need the information to establish, exercise or defend a legal claim.

If we have disclosed your personal information to third parties, we must inform them about the restriction on processing, unless it is impossible or involves disproportionate effort to do so.

7. The right to request that your data be copied or transferred to another organisation in certain circumstances.
8. The right to complain to us and/or to the Information Commissioner’s Office if your information is being used unlawfully (contact details are below).
9. The right to challenge any automated decision making or profiling that may be carried out using your information.

If you would like to contact us about your data protection rights please contact: Data Protection Officer, Aspire Housing, Kingsley, The Brampton, Newcastle-under-Lyme, ST5 0QW. Telephone: 01782 635200. Email: DPO@aspirehousing.co.uk.

If you would like to complain to the Information Commissioners Office the contact details are as follows: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. https://ico.org.uk

When it is necessary for us to transfer your personal information outside of the UK this will only be done in accordance with the UK GDPR. 

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• Hotjar – to monitor website use and the type of browser that is accessing the website.

Automated individual decision-making is making a decision solely by automated means without any human involvement.

Data controller means a company or person who determines the purposes for which, and the manner in which personal data is processed.  In this context, this relates to Aspire Housing as an organisation.

Data subject means an individual who is the subject of personal data.

Data processor, in relation to personal data, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.

Data Protection Officer is the person responsible for overseeing Data Protection within the organisation.

Information Commissioners Office (ICO), The Information Commissioner's Office in the United Kingdom, is a non-departmental public body which reports directly to Parliament. They are responsible for implementing data protection law and carrying out enforcement actions.

Lawful Grounds for processing data – Conditions that must apply for organisations to lawfully process personal data.

Personal data means any information relating to an identified or identifiable natural person ("data subject"); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

Processing means obtaining, recording or holding information or data or carrying out any operation or set of operations on that data.

Profiling is an automated processing of personal data to evaluate certain things about an individual.

Regulator of Social Housing (RSH) regulates private registered providers of social housing. Aspire Housing is subject to their regulation.

Sensitive personal data (also referred to as “special categories of personal data” under GDPR) means personal data relating to the data subject which includes information such as:  race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life, or sexual orientation.