This Privacy Notice explains how we will collect, store, use, share and protect the personal information of our customers.
Black Country Housing Group (BCHG) respects an individual’s right to data privacy and data protection in line with data protection legislation. By this we mean the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This Privacy Notice explains how BCHG will collect, store, use, share and protect your personal information. If you have a tenancy or other written agreement with us it may contain additional detail about our processing of your information.
2. Who we are
We are Black Country Group Ltd, 134 High Street, Blackheath, West Midlands, B65 0EE, also known as Black Country Care, and in this document, we’re referred to as ‘BCHG’. BCHG is a housing, social business, and social care organisation. This privacy notice describes how BCHG collects and uses personal information about you. It applies to all services where we collect your personal data.
BCHG is a ‘data controller’ of your personal data. This means that we are responsible for deciding how we hold and use personal information about you. It is important that you read this notice so that you are aware of how and why we are using such information.
If you have any concerns about this Privacy Notice or how your data is processed you can contact our Data Protection Officer (DPO) by writing to the above address, or by emailing firstname.lastname@example.org.
3. Why do we process personal information?
We use personal data primarily to help us manage and improve our services and our relationships with our customers, colleagues, and other stakeholders.
As a customer, we process your personal data for the following reasons:
For entering into and for the performance of your home purchase, service agreement or tenancy agreement (which is a legal contract) and to comply with our legal obligations to provide appropriate homes.
- Managing rental applications and allocating rental homes, including home exchange and tenancy succession,
- Managing shared ownership enquiries and selling shares in shared ownership homes,
Providing and managing our services and completing our administration duties,
- Supporting your tenancy or service and contractual relationship with us including property management, maintenance, and repairs,
- Monitoring defects, assessing any health & safety risks, administering tenancies and security,
- Resolving issues that you may experience with your home or neighbourhood,
- Managing financial arrangements related to your home or service, such as to enable automatic payment through direct debit or benefit payments or deal with any mortgage arrangements or solicitors.
For both our and your legitimate interests to run our business effectively and continually improve our services.
- Helping set up your council tax payments,
- Managing general enquiries and complaints,
- Collecting and acting on feedback,
- Carrying out your wishes or requirements such as any religious or cultural wishes as appropriate.
To comply with laws or regulations, and in exceptional circumstances to protect the vital interests of individuals.
- Enabling our staff to provide services in a way that protects their own safety and other people’s safety, and to protect people where necessary,
- Dealing with any medical or similar emergencies.
For acting in the public interest, and substantial public interest.
- Involving agencies such as Social Services or the Police as appropriate where we have concerns about a person’s health or welfare,
- Preventing and investigating anti-social behaviour, fraudulent activities, other crimes and to protect the welfare and security of people and property,
- For the purposes of crime detection, prevention measures and provision of safer communities,
- Carrying out meaningful equal opportunity monitoring and reporting and to help support equality of treatment and opportunity, including in relation to customers with disabilities.
In some cases, with your explicit consent.
- For referral to other services which may support you and your tenancy.
4. What personal data does BCHG collect?
We aim to limit the amount of information we process to that which is necessary to provide you with our services and carry out our responsibilities. We typically collect data about you, including where applicable:
- Identification and contact details, including: your name, address, email, and telephone number; previous names and addresses and forwarding contact details; date of birth, marital status, nationality, residential status, National Insurance number, photograph, and other proof of identity.
- Proof of housing eligibility, including interest or equity in another property; your housing history and information relating to your financial circumstances; details of family and next of kin including details of all household residents.
- Special Category Data, including race; ethnicity; religion; health; physical or mental health needs and other sensitive data including gender; incomes and outgoings; and bank details, where required so that we can provide you with the service you require, and for legislative requirements, as well as for monitoring and improving equality of opportunity and treatment in the public interest.
- Medical information & emergency contact details, next of kin / advocate, information about any accidents or incidents which involve you, your service, or your home.
- Financial information, including any credit checks, income details, bank details, housing benefit or care funding information and any guarantor details. Rent and service charge or payment information, including details of any arrears.
- Records of your/your representative’s contact with us when we make notes of our conversations with you/your representative over the phone or in person and add contact notes to our Housing Management System or Care Management System. We do not record the audio of phone calls.
- Current/previous details about your mental capacity, mental and physical health; offending and anti-social behaviour background when we require this to tailor our services or to protect the safety and wellbeing of yourself and our colleagues which we are legally obliged to do.
- Information about any complaints made by you or which relate to you; a list of those external statutory and/or voluntary agencies you are engaged with; home/service feedback and satisfaction information.
- Online account login and verification information, if you have set up an online account to access our tenant portal.
- Where CCTV is installed, images are captured for the prevention, detection and investigation of anti-social behaviour and crime. These images are only shared with law enforcement or prosecution agencies where it is believed the images will assist in a legal enquiry. CCTV images, not subject to an investigation, are held for a maximum of 30 days.
- On occasion, when investigating an Anti-Social Behaviour complaint, sound monitoring equipment are used to detect excessive noise coming from one of our properties. All sound recordings are destroyed once the Anti-Social Behaviour case is closed.
- We will collect information relating to any relevant criminal convictions from housing applicants, to ascertain whether they are unsuitable to be a tenant in a property by reason of its position, their behaviour or the behaviour of a member of their household.
- NHS Test and Trace data: name; contact phone number; date of visit, arrival/departure time of customers and visitors (or lead member in a group) to sites where deemed appropriate by Government guidelines in response to the COVID-19 pandemic. Please note, these records will be held securely for 21 days only before being securely destroyed and will be used for NHS Test and Trace purposes only.
5. Where does BCHG collect this personal information from?
We collect and /or validate this information from the following general sources:
- From you directly and from any family members or beneficiaries of products and services.
- From third-party organisations, who transfer your personal information to us when BCHG operates a service that the third party previously operated.
- From trusted external sources such as Fraud Prevention Agencies, Credit Reference Agencies, the Department of Work and Pensions, National Health Service, Local Authorities, Her Majesty’s Revenue and Customs and organisations to assist in the detection and prevention of crime, including police and law enforcement agencies.
6. Data Sharing
We may have to disclose personal information about you to comply with applicable laws or other lawful requests. Dependent on the service you receive, we also share information with:
- Relevant regulators and/or commissioners.
- External agencies or third parties that are involved in any coordinated services that you receive and require your personal details to do so (such as contractors for repairs, planned maintenance, refurbishment of properties; or software companies supporting systems on which personal data is held, the legal basis in such instances is that it is necessary to carry out a contract).
- Government or other statutory agencies to help you with benefit claims and any tenancy issues, and to help them to fulfil their public tasks. This includes Social Services, local authority council tax and benefits departments, the DWP (Department for Work & Pensions) and HMRC (HM Revenue & Customs). We may share information with the DWP if you are in receipt of Universal Credit and have significant arrears, to make a request for your housing benefit to be paid directly to us.
- If you have breached your tenancy contract and now owe us money, we may make a referral to our internal debt and welfare advisors who can help you with any monetary management issues you have. We may also share your data with tracing agencies for the purpose of seeking payment or repaying you if you are in credit. Tracing agencies are only used in extreme cases and after any risk has been assessed.
- We will share your information with third parties including the Police and other law enforcement agencies, emergency services and lone working service providers to prevent or detect a crime, or where we believe the health & safety of an individual is at risk. We will share personal data with a Local Authority in relation to any fraud prevention/detection work they carry out.
- Where we are providing you with debt advice, we may share your details with other debt advice agencies to provide that service. With your permission, we will also contact your creditors, DWP, HMRC, HMCTS, the local authority, other advice services, charities, and schools.
- We will work in collaboration with other agencies, for example healthcare providers, law enforcement agencies, charities and third sector, to provide our customers with a more complete and coordinated service and will share your personal data with them to enable you to access services or benefits you have identified you need.
- NHS Test and Trace where they deem it necessary either because someone who has tested positive for COVID-19 has listed one of our services as a place they visited recently, or because one of our services have been identified as the location of a potential local outbreak of COVID-19. This applies to NHS Test and Trace data only.
- Where we receive a one-off data request from another public body or another data controller for their own legitimate interest. (e.g., a utility company requesting forwarding details of a tenant to recover debts owed), we will usually provide your new address but only if we are certain, it is up to date and it is less than 12 months old.
All personal information is held securely and only accessed by colleagues with a legitimate business interest to access it. BCHG does not currently transfer any personal data outside of the UK. If BCHG were to transfer data outside the UK, we would ensure the necessary safeguards are in place.
7. How does BCHG protect personal data?
BCHG has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused, or disclosed. We limit access to your personal information to those employees, agents, contractors and other third parties who have a legitimate business need to access it. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so, or we believe it is important to tell you about a breach even if we are not legally required to tell you.
8. For how long does BCHG keep personal data?
Unless we inform you otherwise, we will hold your personal information based on the following:
- For as long as we have reasonable business needs, including managing the service(s) we provide to
- Retention periods that are in-line with legal/regulatory requirements or guidelines. Please see our Data Retention and Disposal Policy and appendices for more information.
9. Your rights under data protection laws
You have several rights over the way in which we process your personal data. They are listed below. If you wish to use any of them, please contact us and we will explain at the time to what extent your request is valid and how we will respond to your request.
- Your rights of access: You have the right to ask us for copies of your personal information.
- Your right to information: You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete any of your information you think is incomplete.
- Your right to erasure (to be forgotten): You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing: You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object processing: You have the right to object to the processing of your personal information in certain circumstances.
- Your right to data probability: You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights, however if a request is manifestly unfounded or excessive, we may charge a 'reasonable fee' for the administrative costs for complying with the request or we may decline to fulfil the request. If you make a request, we have one month to respond to you. We may need to request specific information from you to help us confirm your identity so that you can exercise any of these rights, this is a security measure to ensure that personal information is only disclosed to the person who proves that they have a right to access it.
Please contact us at email@example.com or write to Data Protection Officer, Black Country Housing Group, 134 High Street, Blackheath, West Midlands, B65 0EE, if you wish to make a request.
10. Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
11. Changes to this Privacy Notice
We may change this privacy notice from time to time to reflect changes in the law and/or in our privacy practices. You will be able to access the latest privacy notice via our website.
12. How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at: firstname.lastname@example.org or write to Data Protection Officer, Black Country Housing Group, 134 High Street, Blackheath, West Midlands, B65 0EE, if you wish to make a request.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: www.ico.org.uk