Housing Reviews Ltd is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law. Please read it carefully.
This notice is separated into the following sections:
1. Information about us
2. S202 Reviews
3. Conferences and Training
4. Employee information
5. Job applicants
6. Storage of your information
1. Information About Us
1.1 Data Controller:
Housing Reviews Ltd is the body exercising control over the purpose for which and the manner in which your personal data is processed.
1.2 Data Controller's contact details:
Minos Perdios, Housing Reviews Ltd, PO Box 365, Leeds LS26 1FL
Telephone 0113 8160210
1.3 Data Protection Officer:
2. S202 Reviews
When you contact us about your S202 Housing Act 1996 as amended review request we will hold your personal details and the personal details for your household. This includes ‘special category data’ such as your health, sexual orientation, race, religion.
2.1 The legal basis for and the purposes of the processing:
Housing Reviews Limited has statutory duties under the housing and homelessness legislation.
Once your S202 review request has been forwarded to Housing Reviews Ltd by the respective local authority the personal data provided by you and any information obtained by the Local Authority will be used:
to assess the legality of the decision made by the Local Authority
to contact you about your situation and the information you have provided;
to request you to provide documents in relation to your review request
to contact third parties with your personal information to request further personal information about you and any other member of your household where relevant.
For the purposes of administrating your section 202 review request we have a legal power and, in some cases, a legal duty to share your information without your consent with the people and/or types of organisations listed below in this Privacy Notice. If we need to request personal information about you or share it with people or other types of organisations not listed below we will ask you for your consent.
Sometimes third parties may request information on your behalf about your Section 202 review request and they must provide your consent and show they are compliant with the Data Protection Act 2018 for us to do this. The processing of your personal data is necessary for Housing Reviews Ltd to comply with its legal obligations under the law on housing and homelessness.
Where you have criminal convictions or offences, Housing Reviews Ltd is able to process relevant personal information for the purposes of complying with the law on housing and homelessness. This is because:
the processing is necessary for the purposes of performing or exercising obligations or rights of either Housing Reviews Ltd or for you under housing and homelessness law; and
Housing Reviews Ltd has a policy document in place (which sets out how Housing Reviews Ltd will comply with the data protection principles and which clarifies Housing Reviews Ltd's policies regarding the retention and erasure of relevant personal data).
2.2 The source of the personal data:
For the purposes of your Section 202 review request you are the applicant and are the source of the personal data about you and the members of your household.
Personal information about you relating to you and your household may also be gathered from other sources such as private sector landlords, housing associations, lettings agents, mortgage lending companies, providers of emergency accommodation, friends and relatives you and your household may have been living with and/or you are happy for us to contact about your situation, health services, children, family and adult services, education services, Department of Work and Pensions, Housing Benefit and Council Tax services, Job Centre Plus, Ministry of Defence, the Police, prisons, probation, youth offending services, secure training units, employers, banks, building societies, other financial institutions where you may have money invested, Citizens Advice Bureau and voluntary sector organisations.
2.3 Recipients and categories of recipients of the personal data:
Staff involved in the administration and management of your Section 202 Homeless Review, including review officers and admin officers.
Information about you relating to your S202 review request may be shared with third parties such as private sector landlords, housing associations, lettings agents, health services, children, family and adult services, education services, Department of Work and Pensions, Housing Benefit and Council Tax services, Job Centre Plus, National Fraud Initiative, the Police, prisons, probation, youth offending services, secure training units, contractors that repair the Council's emergency accommodation, providers of emergency accommodation, Citizens Advice Bureau, voluntary sector organisations and for the purpose of gathering your feedback as one of the Council's customers.
2.4 Further information on onward transfers:
Housing Reviews Ltd will not transfer the personal data you have provided outside of the UK or European Union unless this is permitted in accordance with the Data Protection Act 2018.
2.5 How long the personal data will be kept for:
The personal data that we receive throughout your review period will be destroyed in accordance with Housing Reviews Data Retention Policy of 6 months after your Section 202 review decision is finalised. Your final Section 202 review decision letter will be kept on file for statistical purposes.
2.6 Statutory Obligations to provide the personal data:
There is no statutory obligation on you to provide any personal data about you, however, if you do not your Section 202 review decision cannot be considered further.
2.7 Automated Decision Making:
The personal data provided by you will not be used for any automated decisions.
2.8 Data Subject Rights:
From 25 May 2018 you will have some specific rights in respect of your personal data. These may include some or all of the following rights to:
see what personal data about you Housing Reviews Ltd holds at any time (subject to certain caveats, for example where third parties are identified);
have Housing Reviews Ltd correct any errors (if any) in the personal data it holds about you;
request your personal data is erased (though this right will not apply where Housing Reviews Ltd is processing your personal data because it is necessary to comply with a legal obligation);
request processing of your personal data is restricted (this will only apply in certain situations, for example where its accuracy is contested, where the processing is unlawful and then you oppose its proposed erasure by Housing Reviews Ltd, or where Housing Reviews Ltd no longer needs to process the personal data, but it is required by you in connection with legal claims);
object to the processing where the processing is necessary for a task carried out in the public interest or in the exercise of official authority vested in the data controller (though Housing Reviews Ltd will still be able to continue with the processing in certain circumstances, such as if there are compelling grounds for the processing which over ride your interests).
2.9 Will the personal data be processed for a different purpose?
No. If Housing Reviews Ltd needs to inform recipients about any action it has taken under the Data Protection Act then it will do so by placing a Notice on Housing Reviews Ltd's website informing the public of any relevant changes.
3. Conferences and Training
3.1 We may collect your name and contact details (such as your email address, phone number or address) in order to send you information about our relevant products and services which you might be interested in. We may collect this directly from you, or through a third party. If a third party collected your name and contact details, we will send you a Fair processing notice and respect any communication preferences you give us.
3.2 You always have the right to “opt out” of receiving our marketing. You can exercise the right at any time by contacting us at email@example.com. If we send you any marketing emails, we will always provide an unsubscribe option to allow you to opt out of any further marketing emails. If you “opt-out” of our marketing materials you will be added to our suppression list to ensure we do not accidentally send you further marketing. Where you unsubscribe from any postal marketing, you may initially still receive some content which has already been printed or sent, but we will remove you from any future campaigns. We may still need to contact you for administrative or operational purposes, but we will make sure that those communications don’t include direct marketing.
3.3 If you are an existing customer or are acting as a business we use your contact details as necessary for our legitimate interests in marketing to you and maintaining a list of potential customers.
3.4 We never share your name or contact details with third parties for marketing purposes. We do use third party service providers to send out our marketing, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
3.5 We retain your details on our marketing list until you “opt-out” at which point we add you to our “opt out list”. We keep that opt out list indefinitely to comply with our legal obligations to ensure we don’t accidentally send you any more marketing.
We may also collect and use the following “special categories” of more sensitive personal information in the following situations:
Information you provide about your dietary requirements in the booking process but are only stored for the purpose of providing appropriate food and beverage.
Information you provide about any disability but are only stored for the purpose of providing appropriate access to our training or conferences.
3.6 Where we collect “special categories” of medical data under conferences and training we retain this for one month.
3.7 We will not be sharing your personal information with any third parties unless there is a legal obligation to do so.
3.8 You have the same rights as those detailed in 2.8.
4. Employee Information
4.1 If you work for one of our customers, suppliers or business partners, the information we collect about you may include your contact information, details of your employment and our relationship with you. This information may be collected directly from you, or provided by your organisation. Your organisation should have informed you that your information would be provided to us, and directed you to this policy. We use this as necessary for our legitimate interests in managing our relationship with your organisation. If we have a business relationship with you or your organisation, we may receive information about you from your organisation.
4.2 We keep this information for up to 5 years after the end of our relationship with your organisation.
5. Job Applicants
5.1 We will collect and hold information on job applicants, including information you provide to us in your application (such as your name, contact details, professional and educational history), or provided to us by recruitment agencies, as well as information on you from any referees you provide.
5.2 We use this as necessary to enter into an employment contract with you, and for our legitimate interests in evaluating candidates and recording our recruitment activities, and as necessary to exercise and perform our employment law obligations and rights.
5.3 If you are successful in your application, your information will be used and kept in accordance with our own procedures. If you currently work for us, or used to work for us, you can request a copy of this from us. If you are not successful in your application, you information will be held for up to 1 month after the relevant round of recruitment has finished.
5.4 If you are listed as a referee by an applicant, we will hold your name, contact details, professional information about you (such as your employer and job title) and details of your relationship with the applicant. We will use this information as necessary for our legitimate interests in evaluating candidates and as necessary to exercise and perform our employment law obligations and rights. Your information will be kept alongside the applicant’s information.
5.5 If you are listed as an emergency contact by someone who works for us, we will hold your name, contact details and details of your relationship with that worker. We will use this to contact you as necessary to carry out our obligations under employment law, to protect the vital interests of that worker, and for our legitimate interests in administering our relationship with that worker. Your information will be kept until it is updated by that worker, or we no longer need to contact that worker after they have stopped working for us.
6. Storage of your information
6.1 Our office headquarters are based in Leeds and our main data centre is located in Ireland. The information that we hold about you will always remain within the EU.
6.2 We have put in place appropriate internal security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
6.3 We have put in place procedures to deal with any suspected data security breach and will notify you and the Information Commissioners Officer of a suspected breach where necessary.
6.4 We have set out above indications of how long we generally keep your information. In some circumstances, it may be necessary to keep your information for longer than that in order to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
6.5 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
If you are dissatisfied with how your personal data is processed by Housing Reviews Ltd then you have the right to complain to the Information Commissioner who can be contacted at: Information Commissioner's Office, Wycliffe House, and Water Lane, Wilmslow SK9 5AF.