The Regenda Group is made up of Regenda Homes, a Housing Association, and its wholly-owned subsidiaries. Regenda Homes is a registered social landlord and processes personal data to maintain tenancies. Our subsidiary websites have separate privacy notices – see our businesses.
This privacy notice tells you what to expect when Regenda collects personal information. It applies to information we collect about:
- people who use and/or enquire about our services
- visitors to our websites
- job applicants.
The General Data Protection Regulation (GDPR) and Data Protection Act (2018) set out rules for processing personal information. This applies to personal information we might hold about you on some paper files and on computers. The regulation states that those who record and use personal information must ensure that it is handled properly. Therefore we are required to ensure that personal information is:
- processed in a lawful, fair and transparent way
- held only for the purposes we collected it for
- adequate, relevant and limited to what is necessary
- held only for as long as we need it
- kept secure.
The Information Commissioner’s Office (ICO) is responsible for regulating, enforcing and promoting good practice and transparency in the access and use of personal information.
Organisations have to notify the ICO of all the purposes for which they will be processing information. We are a happy to supply you with a copy of the notification upon request or you can contact the ICO by calling 0303 1231113, or writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
You can find out more information online at www.ico.org.uk.
We begin the process of collecting information about you, and if appropriate, your family, when you apply to us either directly or through one of our Choice Based Letting partners. Although the information we collect may vary, typically it may include:
- name and address
- contact details
- details of your contact with us
- gender and dates of birth for you and others who live in your household
- next of kin details
- income details and history of rent payments
- Criminal convictions
- information on housing need for you and others who live in your household
- Information on adaptations, applications, transfer requests, etc.
Regenda Homes also collects special categories of personal data, including:
- Race or ethnic origin
- Health and medical conditions
- Sexual orientation.
We understand that you may not feel comfortable providing some of this information and consider it private. We ask some of these questions to make sure that we do not discriminate against any of our customers and because we recognise that a person’s age, disability, ethnic origin, religion, sexual orientation or medical condition may affect their choice of home, the area they want to live, and the services they need.
Understanding the diversity of our customers is very important to help us work towards providing homes and services that meet everyone’s needs.
If you feel uncomfortable providing this information, you can say no.
We collect information in a variety of ways, including:
- When customers apply for a home
- When customers sign a tenancy agreement
- Through ongoing contact with customers during a tenancy
- When customers request or access services
- Recording calls to and from our contact centre
- When customers terminate a tenancy
- If a customer makes a complaint
- When dealing with ASB cases
- When providing welfare benefits advice
Regenda Homes collects this information for a number of reasons, including:
- to manage allocations and lettings
- to support you in maintaining your tenancy
- to ensure that your housing needs are met
- to provide a repairs and maintenance service
- to resolve ASB disputes
- to investigate complaints
- to deliver the Investment programme
- to engage with customers to get feedback on our services
- to target customers impacted by welfare reform
- to process requests from third parties, for example, Council Tax
- to monitor diversity and equality which helps to tailor services accordingly
- to prevent and/or detect of crime
- for regulatory purposes
- for legal requirements.
We will not share your personal information without your consent, unless allowed by law. Examples of organisations we may share your information with, where appropriate include:
- Local Authorities
- Housing Benefit
- Department for Work and Pensions
- Social Services
- Housing Ombudsman Service
- Ministry of Housing, Communities & Local Government (MHCLG)*
- Probation Service
- Other landlords
- Utilities companies
- Council tax
- Debt recovery agencies
- Health Service Providers, including The National Health Service (NHS)
*For further information on how the Ministry of Housing, Communities & Local Government (MHCLG) uses your personal information, please see a copy of their Privacy Notice at https://core.communities.gov.uk
Regenda needs to processes your personal data in order to manage your tenancy or deal with your enquiry.
This includes but is not limited to the following set out within the GDPR:
- Article 6.1(a) – the data subject has given consent
- Article 6.1(b) – processing is necessary for the performance of a contract
- Article 6.1(c) – processing is necessary for compliance with a legal obligation
- Article 6.1(d) – processing is necessary to protect the vital interests of individuals
- Article 6.1(e) - processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
For the processing of “special category data” such as someone’s physical and mental health:
Article 9.2(g) of the GDPR
Processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.
The processing of special category under Article 9 also requires the following conditions for processing from the UK Data Protection Act 2018 to be met:
- Schedule 1, Part 2 section 6(a), processing is met under the exercise of a function conferred on a person by an enactment
- Schedule 1, Part 1 section 2(1), this condition is met if the processing is necessary for health and social care purposes
All of your information, correspondence, and notes about your tenancy will be held in our secure housing management system and some information might be kept within our secure email and IT systems.
We keep your information for 6 years following the termination of your tenancy. If your case has been subject to an insurance claim or other dispute we may keep the data for 16 years.
All personal data is securely destroyed when no longer required. Electronic files are deleted in such a way that they cannot be retrieved and all paper records are disposed of in confidential shredding bins.
Information is held in paper files and on our computer systems. Not all members of staff are able to access this information, only those who need to. We use the information to deliver a service to you. There may be occasions when we have to share information with others (detailed in section 5) to enable us to deliver our services and fulfil our legal and contractual obligations. We are legally required to share information in the following circumstances:
- Prevention or detection of crime
- Apprehension or prosecution of offenders
- Assessment or collection of tax or duty owed to customs and excise
- In connection with legal proceedings
- To comply with the law
- Public Health
During the course of your tenancy, your needs may change so we will update our information to make sure we can provide services that meet your needs. To do this our neighbourhood team may visit you, or we might ring you or ask you for information to find out if your circumstances have changed. Any new information will be protected in the ways already outlined.
If any of the information we send is incorrect or inaccurate, please tell us so we can make the necessary changes.
10. Marketing and Communication
10.1 The Marketing and Communication Team may collect the following types of personal data:
- Video footage including interviews
We may also collect:
- Your name, age, address and contact details (email, telephone number and/or postal address).
- Name of group/organisation or event.
- If it is for consent for a child aged 13 or under, or a vulnerable adult - the name of the consenter and their relationship to you.
10.2 We may collect your personal data in a number of ways:
- Through a consent form
- By an authorised representative e.g. employed photographer at organised events
10.3 What is our lawful basis to obtain and use this personal data?
When we collect and use your personal information we rely on the following lawful basis:
- Consent: You or a representative have given consent.
- Legitimate interest – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
10.4 What does the communications and marketing team use your information for?
We use images to promote services across the Regenda Group.
Images and footage may be published on any of the following channels:
- Press and media (including newspapers, magazines, websites)
- On our websites (including Petrus and Regenda)
- On our social media feeds including LinkedIn, Twitter, Facebook and other corporate social media accounts in the future
- In our printed publications such as newsletters, brochures, flyers and display materials
- In our electronic newsletters
- Media releases
The images/footage will often be accompanied by the details of your story, however, we will not use personal details or full name of any individual in an article.
If you no longer wish for your image or personal information to be used, please contact us and ask us to remove them from the archive. Please note that we will be unable to remove any images or content in printed materials or video footage if it has already been produced or remove images and quotes that have already been published by the media.
If you have asked someone to act on your behalf (such as the Citizens Advice Bureau or a relative) you will be asked to supply or complete an Authorisation form, which you can get from the agency acting on your behalf or from Regenda Homes.
When someone visits www.regenda.org.uk we use a third-party services, Google Analytics and Hotjar to collect standard internet log information and details of visitor behavior patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
When you use our website, no user-specific data is collected by either Regenda Homes or any third party. We use Google Analytics for trend reporting and visitor behaviour to help us improve our website and search functionality.
When you use our customer portal, you are able to view information held in our housing management system, including personal details, account statements, tenancy information, repair history and pay your rent / service charges. Please note that we use a third party provider, Verseone to support our customer portal.
12.1 Security and Performance of the Regenda Homes website
Regenda Homes uses a third party service to help maintain the security and performance of the Regenda Homes website. To deliver this service it processes the IP addresses of visitors to the Regenda Homes website. This information is not used for identifying purposes, except for investigation if an intrusion occurs.
These are the cookies we use:
- Google Analytics - to monitor website use and the type of browser that is accessing the website
- Google Translate - to remember a visitors language preferences
- Hotjar – to monitor website and page usage
We use a third party provider, MailChimp, to deliver our monthly e-newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter.
Subscribers to the list give consent to receive the newsletter and can easily un-subscribe at the bottom of each email.
We only hold the following date on subscribers:
- If they are a resident of Regenda or not
Subscribers consent to giving us this information when they sign up.
We use a third-party provider, Hootsuite to manage our social media interactions.
If you send us a private or direct message via social media the message will not be shared with any other organisations.
Regenda retains social media messages for three months.
When you call Regenda Homes Customer Contact Centre, these calls are recorded for training and monitoring purposes. We use this information to help improve efficiency and effectiveness.
Our Customer Contact Centre can offer a translation service for customers when English is not their first language, this is provided by a third party company, LanguageLine Solutions. This company does not retain any information from the calls or record them.
Regenda retains calls to the Customer Contact Centre for three months.
Regenda email is encrypted at rest and in transit, using several strong encryption protocols, and technologies that include Transport Layer Security/Secure Sockets Layer (TLS/SSL), Internet Protocol Security (IPSec), and Advanced Encryption Standard (AES). If your email service does not support the same encryption, you should be aware that any emails we send or receive may not be protected in transit.
We will also monitor any emails sent to us, including file attachments, for viruses or malicious software.
Regenda use web beacons on our Websites and in our emails. When we send emails, we may track behavior such as who opened the emails and who clicked the links. This allows us to measure the performance of our email campaigns and to improve our features for specific customers. To do this, we include single pixel gifs, also called web beacons, in emails we send. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details.
Emails are retained for fifteen months.
Please note that we use a third-party provider, Verseone, to supply and support our LiveChat service, which we use to handle customer enquiries in real time.
If you use the LiveChat service we will collect your name, email address (optional) and the contents of your LiveChat session. This information will not be retained.
You can request a transcript of your LiveChat session if you provide your email address at the start of your session or when prompted at the end.
LiveChat sessions are retained for three months.
17.1 Right of access to your data
If we hold personal information about you, you have the right to ask us:
- what we use the information for
- to provide you with a copy of the information you are entitled to
- to supply you with details of the purposes for which we use the information and who it is shared with
- for incorrect information to be corrected.
This can be requested either verbally or by completing a Subject Access Request form.
We have one month from the date we receive your request to provide you with the information.
17.2 Right to rectification
If you think that Regenda is holding incorrect personal information about you, you have the right to have this personal information amended.
Once you have advised Regenda of the details of the incorrect data and the required amendments, your data will be updated within 30 days. If your personal data cannot be amended, Regenda will advise you in writing why this is the case.
17.3 Right to be forgotten
You have the right to have your personal information erased if it is no longer required to manage your tenancy or your enquiry.
17.4 Right to restriction of processing
You have the right to restrict the processing of your personal data if it is no longer required to manage your tenancy or to handle your enquiry. This means that Regenda cannot further process your data, for example we cannot share your data with a third party.
17.5 Right to data portability
You have the right to have your personal data transferred to another data controller. For example, if you move home, Regenda Homes will transfer your data to another housing provider.
17.6 Right to object
You have the right to object to the processing of your personal information if the data is not required to manage your tenancy or enquiry, or you have not given Regenda permission to process your data, for example, for direct marketing.
Regenda Homes is the data controller for the information you provide during the employment recruitment process.
The following explains how Regenda uses the information you provide in your application, along with your rights, our reasons for requesting it and who will have access to it.
18.1 What information do we collect from you?
We collect information that is specifically provided by you as part of the application process. We will collect the following (but not limited to):
- Name, address, email, telephone number
- CV (if applicable)
- Equal opportunities monitoring information (defined as special categories data) - this information is purely for statistical analysis and monitoring purposes
- Answers to application questions
- Any other information you wish to provide in support of your application
We use your details and information presented so that we can assess your suitability for employment with us and carry out our statistical analysis.
18.2 Why do we collect this information and who do we share it with?
We use your details and information so that we can assess your suitability for employment with us and carry out statistical analysis. Information you provide as part of your job application will be:
· Held on our computer systems and may be downloaded by us
· Used to deal with your application
· Made available to us and our processors
· Used for communication with you regarding the vacancy
· Used to satisfy legal requirements
· Used for statistical analysis
· Held and may be used to contact you about other vacancies
If you are successfully recruited, we will upload your details to our HR system, Cascade.
18.3 How can you access the information we hold about you?
If you choose to register on our recruitment website, hosted by Networx recruitment you may access your profile, correct and update your details, or withdraw your details at any time. To do this, you can access your personal profile by using the secure login.
You have the following rights in relation to the way in which we deal with your personal data:
· the right of erasure or to be forgotten
· the right to rectification if information is inaccurate or out of date
· the right of data portability (to obtain and reuse your personal data)
· the right to object to Regenda Homes processing your personal data
· the right to withdraw your consent with regards to the handling of your personal data
· you have the right to ask for a copy of the information we hold about you (Subject Access Request)
· You have the right to lodge a complaint with a supervisory authority - the ICO
Where you exercise your right to object or withdraw your consent we may process your personal data without your knowledge or consent where we are permitted or required by law or regulatory requirements to do so. In such a case, we will not process more personal data than is required under the circumstances.
18.4 Conditional offer
If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.
You will therefore be required to provide:
- Proof of your eligibility to work in the UK – you will be asked to attend our office with original documents, and we will take copies.
- Proof of your qualifications, if required.
- You may be asked to complete a DBS application to declare any unspent convictions, depending on the nature of the role you apply for.
- We will contact your referees, using the details you provide in your application, directly to obtain references.
- We will also ask you to complete a questionnaire about your health. This is to establish your fitness to work and any adjustments we need to consider before you start. This is done through our current occupational health provider.
- Our Code of Conduct requires all staff to declare if they have any potential conflicts of interest. If you complete a declaration, the information will be held by our Business Assurance team.
If we make a final offer, we will also ask you for the following:
- Bank details – to process salary payments.
- Emergency contact details – so we know who to contact in case you have an emergency at work.
- Membership of Pension scheme – so we can send you a questionnaire to determine whether you are eligible to join the Social Housing Pension Scheme.
18.5 Health management
Corazon provides our Occupational Health service. If we make you a conditional offer, we will ask that you complete a questionnaire which will help to determine if you are fit to undertake the work that you have been offered, or advise us if any adjustments are needed to the work environment or systems so that you may work effectively.
We will send you a form to complete and return directly to Corazon. The information you provide will be held by Corazon who will provide us with a fit to work certificate or a report with recommendations. You are able to request to see the report before it is sent to us. If you decline for us to see it, then this could affect your job offer. If an occupational health assessment is required, this is likely to be carried out by Corazon.
18.6 Fleet and mileage claims
The organisation is required to undertake statutory checks to ensure vehicles that our staff drive on behalf of the company are road worthy. To achieve this, we require staff to provide the following documents:
- Driving license details
- MOT (if applicable)
- V5 registration document (if applicable)
- Insurance details
This information is collected to ensure that any mileage payments paid to employees are done so in accordance with health and safety legislation, which requires us to ensure all travel undertaken for the business is compliant.
In addition, we carry out checks on all staff’s licenses through the DVLA to ensure they are legally able to drive both their own and company vehicles. This information includes:
- Driving convictions i.e. drink driving, speeding etc.
- Number of penalty points
This information is used to ensure all drivers are legally entitled to drive. In addition, we use this data to monitor staff who have a more than 6 penalty points on their driving license.
18.7 How long is the information retained for?
If you are successful, Cascade will be the central reference for your data for the duration of your employment, plus six years following the end of your employment.
If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the campaign.
Equal opportunities information is retained for six months following the closure of the campaign for unsuccessful candidates. Successful candidates’ data will be stored via the Cascade system.
Regenda tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Regenda’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
If you want to make a complaint about the way we have processed your personal information, you can contact us at firstname.lastname@example.org
We keep our privacy notice under regular review. This privacy notice was last updated on 8 June 2020.
42 Henry Street
Telephone: 0151 703 3000