Who are we?
This privacy notice (the “Privacy Notice”) applies to all personal information processing activities carried out by Cotman Housing Association.
Cotman Housing Association is a data controller in respect of personal information that we process in connection with our business (including the products and services that we provide).
Our principal address is 305 Gray’s Inn Road, London, WC1X 8QR and our contact details can be located on our website.
Cotman Housing Association are part of Places for People Group. More information about the Places for People Group can be found at placesforpeople.co.uk/about-us.
We respect individuals’ rights to privacy and to the protection of personal information. The purpose of this Privacy Notice is to explain how we collect and use personal information in connection with our business.
We may update our Privacy Notice from time to time. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it
Why we collect your personal information
Do you know what personal information is?
Personal information can be anything that identifies and relates to a living person. This can include information that when put together with other information can then identify a person.
Information we may collect about you may include (but is not limited to):
- Telephone numbers
- Email addresses
- Data of birth
- National insurance number
- Bank details
- Employment details
- Communication formats
- Identification Documents
- Income and expenditure
- Next of kin details
- Health data
- Criminal data
- CCTV images
- Computer IP address
- Service needs and preferences
- Benefit Entitlement
- Your information on social media
We may also collect personal information from others with whom you live or receive service from us – this may include:
- Family and household members
- Friends and visitors
- Members of public
Did you know that some of your personal information might be classified as ‘special’?
Some information is ‘special’ and needs more protection due to its sensitivity. It’s often information you would not want widely known and is very personal to you. This is likely to include anything that can reveal information relating to your:
- Sexuality and sexual health
- Religious or philosophical beliefs
- Physical or mental health
- Trade union membership
- Political opinion
- Genetic/biometric data
We will only collect this type of information if it is necessary to your contract so that we can provide the right services to you.
We may at times need to share this information we will only do this if we have your consent or if there are legal requirements for us to do so. We may receive information about you from other data controllers, such as to the police who might tell us about a crime they are investigating where this impacts on your contract with us or those who live in the same community. If you give us this information about yourself when communicating with us, you do so because you consider it forms part of a legitimate interest for us to hold this information on our records.
If we ask for any sensitive personal data about you, we will always tell you why we need it and ask for your consent to hold it.
Why do we need your personal information?
We may need to use some information about you to:
- deliver services and support to you;
- manage those services we provide to you;
- service improvement
- prevention/detection of crime/fraud
- help investigate any complaints you have about your services;
- check the quality of services;
- to help with research and planning of new services.
How the law allows us to use your personal information
There are a number of legal reasons why we need to collect and use your personal information.
Generally, we collect and use personal information for the purposes of where:
- you are entering or have entered into a contract with us
- you, or your legal representative, have given consent
- it is necessary to protect someone in an emergency
- it is required by law
- you have made your information publicly available
- it is necessary for legal cases
- it is necessary for archiving, research, or statistical purposes
- it is in both our and your legitimate interest to use your data.
Consent and Your Preferences
We may contact you or send communications to tell you about a service enhancement such as improvements to our online services or to keep you informed on how we are performing. We won’t need your consent to communicate with you this way because we have assessed that it forms part of our agreement with you and it is in our legitimate interest or of mutual interest for us to keep you informed and is relevant to your contract with us.
We will provide an unsubscribe option on communications where you have a choice to object. You can also update your communications preferences at any time by logging on to your online account at my.cotmanhousing.co.uk or alternatively if you do not want to sign up for an online account but you want to update your preferences, please contact us and tell us which service you are removing your consent so we can deal with your request.
We only use what we need
Where we can, we’ll only collect and use personal information if we need it to deliver a service or meet a requirement.
If we don’t need personal information we’ll either keep you anonymous if we already have it for something else or we won’t ask you for it. For example in a survey we may not need your contact details so we’ll only collect your survey responses.
If we use your personal information for research and analysis, we’ll keep you anonymous or use a different name unless you’ve agreed that your personal information can be used for that research.
We won’t sell your personal information to anyone else.
We may share your information with other companies within our group, we will always ask for your consent to do this and you can ask us to stop at any time.
We will always provide an option for updating your marketing preferences on our communications with you.
Visiting our websites
When you visit one of our websites, we collect standard internet log information for statistical purposes.
- We do not make any attempt to identify visitors to our websites. We do not associate information gathered from our sites with personally identifying information from any source.
- When we collect personal information, for example via an online form, we will explain what we intend to do with it.
Our websites contain links to various third party websites. We are not responsible for the content or privacy practices of any external websites that are linked from our sites.
How we use your telephone number and email address
Text messages and contact via telephone or email provide a direct way to contact and share information with you about the services we can deliver to you. It can also help you receive important messages about your tenancy or which may interest or a help to you such as new online services.
If you provide your telephone number or email address we may keep in contact with you by these methods.
Operational SMS/text/email messaging and calls
If you supply us with your telephone or email contact details, we may use them to call or send you operational text messages.
Examples of operational text messages include:
- Confirming a repair and/or a time and date for a repairs contractor to visit
- Confirming a home visit
- Rent Account updates, arrears actions
- Sending a reminder about an appointment
- Asking you to contact a named person or department
- Satisfaction surveys
- Checking that we have the correct contact details for you.
Sharing your telephone number with third parties
We may pass your telephone number to third parties so that we can meet our contractual obligations with you. We may also share your telephone numbers if we are required to by law.
We may supply the details to our approved third party contractors who are delivering or performing services on our behalf, and these companies must not use your information for any other purpose. We never share or sell your telephone numbers to telesales/marketing companies.
Communicating with you
We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes of improving our service to you.
Who do we share your information with?
We use a range of organisations to either store personal information or help deliver our services to you. Where we have these arrangements there is always an agreement in in place to make sure that the organisation complies with data protection law.
We may enter into partnerships with other organisations such as local authorities and the police. For example, we may join a partnership to help prevent and control anti-social behaviour. In order to protect your information, we will enter into a legally binding data sharing agreement with partner organisations before any sharing takes place. It is not always possible for us to tell you that personal information is being shared, for example when we are working with the police or other agencies to help the investigation or detection of a crime as to do so may prejudice that investigation.
We are likely to share your personal information with the following:
- Property Services and Repairs
Contractors and third supply chain service providers for the purposes of carrying out property related inspections and repairs. Generally we will only share your name, the property address and your contact details so that they can arrange an appointment with you. In some cases we may also share customer service information with them, for example where you have told us that you need longer to answer your door. We may also need to share information where we have recorded there is a potential risk to operatives or other representatives. We will tell you what we record about you and we have a review process in place.
- Local Authorities
We will share your personal information with local authorities usually for the purposes of providing services processed by that local authority such as Universal Credit purposes.
We may also share information with local authorities for the purpose of investigating tenancy fraud or other types of fraud or criminal investigations. You will not have a right be told about this type of sharing because to do so may affect those investigations we will take steps to protect your information and only share what is necessary for those investigations.
We may share your personal information with our insurers in the case of a public liability claim. We will only share data specifically related to the claim. Our Insurers will provide you or make available to you the Privacy Notice that is linked to our insurance policy.
- Government departments
We may share your personal data with the DWP for the purpose of assisting you with your benefit claims including UC and for the purposes of recovering outstanding debts owed to us.
We use CCTV systems in some locations. CCTV is installed for the purpose of preventing and detecting crime.
- Social Alarms Provider
We share your personal data with our social alarms company for those who receive this service for the purpose of them providing emergency backup. We only share the data that you have specifically provided for this purpose and it is shared via secure data transfer
- Mail out companies
We may share your name and address with external mail out companies who we have appointed to assist us with mail distribution
- Safeguarding, Support Agencies and Charities
We may share your personal information with these organisations where we suspect there may be safeguarding or welfare concerns. We will usually try to gain your consent in advance, but we may make a safeguarding referral without consent in situations where we feel there is a significant risk.
- Utility companies and local authorities
We may need to share your personal information with energy management companies, utility companies [gas, electric, water] and local authorities for the purpose of ensuring utility services and council tax to the property are correctly charged and supplied. We may pass on your details after you have left us if there are arrears with a utility or local authority for services received.
- Debt Recovery Agents
We may share your personal information with debt recovery agents for the purposes of recovering any outstanding charges owed to us.
- Legal Services and Partners
We may share your personal information with our legal services or solicitors if we are preparing or defending a legal claim.
- Places for People Group companies
We may share your information with shared service functions within the Places for People Group, such as for the purpose of financial transaction when making payments to us or the Insurance functions if you make a claim. Places for People Group shared services comply with and process personal information within the same privacy standards and procedures.
Where there is a high risk to your personal information we will complete a privacy assessment before we share personal information to make sure we protect privacy and comply with the law.
Sometimes we have a legal duty to provide personal information to other organisations, this is often because we need to give that data to the police, courts, local authorities or government bodies.
We may also share your personal information when we feel there’s a good reason that’s more important than protecting your privacy. This doesn’t happen often, but we may share your information:
- in order to detect and prevent a crime and fraud; or
- if there are serious risks to the public, our staff or to other professionals;
- safeguarding of vulnerable individuals
- to protect adults who are thought to be at risk, for example if they are frail, confused or cannot understand what is happening to them
If we’re worried about your physical safety or feel we need to take action to protect you from being harmed in other ways, we’ll discuss this with you and, if possible, get your permission to tell others about your situation before doing so.
For all of these reasons the risk must be serious before we can override your right to privacy.
We may still share your information if we believe the risk to others is serious enough to do so.
There may also be rare occasions when the risk to others is so great that we need to share information straight away.
If this is the case, we’ll make sure that we record what information we share and our reasons for doing so. We’ll let you know what we’ve done and why if we think it is safe to do so and will not cause harm, distress or further risks to you, our staff, other professionals and/or the public.
We may share your name and contact details with external companies who we have appointed to assist us with mail, email, phone or text message distribution or to carry out surveys so that we can obtain feedback from you on our services. The appointed companies will work on behalf of us and will never use your information for any other purposes.
Keeping your information secure
We store personal information both electronically and in paper form.
We implement security policies, processes and technical security solutions to protect the personal information we hold from:
- Unauthorised access
- Improper use or disclosure
- Unauthorised modification
- Unlawful destruction or accidental loss
We’ll do what we can to make sure we hold records about you (on paper and electronically) in a secure way, and we’ll only make them available to those who have a right to see them. Examples of our security include:
- Encryption, meaning that information is hidden so that it cannot be read without special knowledge (such as a password). This is done with a secret code or what’s called a ‘cypher’. The hidden information is said to then be ‘encrypted’
- Pseudonymisation, meaning that we’ll use a different name so we can hide parts of your personal information from view. This means that someone outside of the Places for People Group could work on your information for us without ever knowing it was yours
- Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it
- Training for our staff allows us to make them aware of how to handle information and how and when to report when something goes wrong
- Regular testing of our technology and ways of working including keeping up to date on the latest security updates (commonly called patches)
When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, support workers, solicitors) act on your behalf we will take steps to ensure that you have agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.
Employees and third parties who have access to, or are associated with the processing of, your personal information are obliged to make reasonable efforts to safeguard it.
Where in the world is your information?
Your personal information is stored on systems in the UK. But there may be some occasions as our technology services progress where your information may leave the UK either in order to get to another organisation or if it’s stored in a system outside of the EU.
We will always have additional protections on your information if it leaves the UK ranging from secure ways of transferring data to ensuring we have a robust contract in place with that third party.
We’ll take all practical steps to make your personal information is not sent to a country that is not seen as ‘safe’ either by the UK or EU Governments.
How long do we keep your personal information?
There’s often a legal or a contractual reason for keeping your personal information for a set period of time. We will keep your information for the duration of providing a service or product to you under the terms of a contract, such as your tenancy agreement. When your contract has ended we will keep your personal data for a set time for auditing and reporting purposes and for legitimate interest purposes, after that time we will either anonymise or destroy your information.
You can ask us for a copy of our retention periods by contacting us at contact us
The law gives you a number of rights to control what personal information is used by us and how it is used by us. You can contact us regarding any of the rights below by contacting us. We will deal with your request within one month from receiving your request and if we need additional information from you to identify you we will ask for this without undue delay.
You can ask for access to the information we hold about you
You have the right to ask for the information we have about you. When we receive a request from you in writing, we must give you access to what personal information we’ve recorded about you.
A request for personal information can be made via email or in writing. This is known as a subject access request. In order to make a subject access request you will need to provide the following information:
- your name
- your address
- enough information to identify your records
If we have doubts about your identity or we are finding it difficult to locate your personal information we may ask you to provide us with proof of identity.
What types of documents could I submit as proof of ID?
- copy passport with signature (please remove your passport number)
- copy driving license picture with signature (please remove your driver number)
- copy of signed tenancy or contract with us
You can write to us at the following address:
Cotman Housing Association
Data Protection Officer
South Rings Business Park,
18 Craven Drive,
Alternatively email us at contact us (Please ensure you attach you provide enough information for us to identify your records). We will not start your subject access request until we are satisfied that you have provided us with enough information for us to identify you.
Once you have made a request you will receive an acknowledgement and your request should be answered within one month. In certain circumstances, we are allowed to take longer but we will tell you if we feel we may need longer without undue delay from when we receive your request.
We can refuse to handle your request for access if it is manifestly unfounded or excessive.
You can ask to change information you think is inaccurate
You should let us know if you disagree with something we may have recorded about you.
We may not always be able to change or remove that information but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.
You can ask to delete information (right to erasure)
In some circumstances you can ask for your personal information to be deleted, for example:
- where your personal information is no longer needed for the reason why it was collected in the first place.
- where you have removed your consent for us to use your information (where there is no other legal reason us to use it).
- where there is no legal reason for the use of your information.
- where deleting the information is a legal requirement.
Where your personal information has been shared with others, we’ll do what we can to make sure those using your personal information comply with your request for erasure.
Please note that we can’t delete your information where:
- you have an account with us such as an application or a tenancy
- we’re required to have it by law
- it is for historical research, or statistical purposes where it would make information unusable
You can ask to limit what we use your personal data for
You have the right to ask us to restrict what we use your personal information for where:
- you have identified inaccurate personal information, and have told us of it
- where we have no legal reason to use that information but you want us to restrict what we use it for rather than erase the information altogether
We will assess whether you have a right to a restriction and where restriction of use has been granted, we’ll inform you before we carry on using your personal information.
Where possible we’ll seek to comply with your request, but we may need to hold or use information because we are required to by law or we have a legal basis to do so, such as a contract.
You can ask to have your information moved to another provider (data portability)
You have the right to ask for your personal information to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.
However this only applies if we’re using your personal information with consent (not where we are processing your personal information for contractual, legitimate interests, legal obligations or vital interests as a legal basis) and if decisions were made by a computer and not a human being.
It’s likely that data portability won’t apply to most of the services you receive from Cotman Housing Association.
Right to understand Automated Decisions made about you
We do not process your personal data using automated decisions
You also have the right to object if you are being ‘profiled’. Profiling is where decisions are made about you based on certain things in your personal information, e.g. your health.
If and when your personal information is used to profile you, in order to deliver the most appropriate service to you, you will be informed.
How to tell us of a data breach
Cotman Housing Association and Places for People Group takes responsibility to protect the personal information we hold about those with whom we work seriously. We are accountable for our processing and take necessary technical and operational steps to information security protections.
If you suspect your personal information or that of others may have been at risk of a data protection breach please tell us.
The above link has been made available to everyone with whom we deal so that customers, employees and supply chain processors can tell us without undue delay of a potential or actual breach.
Where can I get advice?
We have a Data Protection Officer who makes sure we respect your rights and follow the law. If you have any concerns or questions about how we look after your personal information, please contact the Group Data Protection Officer at email@example.com
For independent advice about data protection, privacy and data sharing issues, you can contact the Information Commissioner’s Office (ICO) at: ico.org.uk/concerns
Information Commissioner's Office
Telephone: 0303 123 1113 (local rate)
Why Do We Need to Collect and Store Personal Data?
Places for People will process, i.e. collect, store and use the information you provide in a manner that is compatible with the Data Protection Act. Wherever possible, we will seek your direct consent at the time that the information is provided, for example on housing application forms or when signing your tenancy agreement.
When you provide the information you will be told what it will be used for and whom it will be shared with. However, you need to be aware that Places for People is required periodically to share your information with other agencies to help reduce crime or investigate fraud.
We may also need to share your personal data with other service providers who are contracted to carry out services on our behalf. These providers are obliged to keep your personal details secure and use them only to fulfil your service request.
Places for People work closely with local authorities and community organisations and often needs to share information with them in order to deliver your services. However, we will not supply these organisations with your information unless we are satisfied that equal measures are in place to protect the information.
Once your service has been delivered or your tenancy ended, your information will be retained for a specified period to enable any further related services to be delivered to you or to allow you or Places for People to deal with any follow up actions. The information will then be destroyed in a controlled manner. The retention of this information will be in accordance with the Places for People Retention Policy.
Joined-up services: sharing across Places for People Group
Places for People is committed to delivering accessible, appropriate, timely and effective services and it is important that it can properly co-ordinate what it does for your benefit and may share your information across services within the group.
You have the right to opt out of this or any other data sharing initiatives. However, remember that Places for People is only collecting it for the purpose of providing the services on offer to you.
Sharing information with local authorities, community partners and other agencies
Places for People has a responsibility to promote social wellbeing and to work with local authorities and community partners such as the Police, Health Services and voluntary services in order to preserve life, reduce crime and improve our communities. To promote our tenants' social wellbeing Places for People may need to share your personal and sensitive information with these local authorities and partners.
We may also utilise other company's data to carry out research so that we can tailor our services, carry out credit checks or for debt recovery purposes.
Wherever possible your consent will be obtained at the time the information is collected, for example on your housing application form or when signing your tenancy agreement.
Privacy Notice for Leaseholders (and their tenants) and Garage Hire
This privacy notice explains what personal data we hold about you, how we collect it, and how we use and may share information about you during our management of the building in which you own or occupy a flat and after it ends. We are required to notify you of this information under the UK General Data Protection Regulation.
- Your Data
We will only use your personal data you have provided to manage and maintain your lease and provide you with leasehold services, in line with our legal obligations under the terms of your lease. We collect the following personal information:
- Name, address, telephone numbers, and email addresses.
- Contact details for emergency key holders where the property is sublet.
- Bank details provided to us to assist us in managing your annual service charges &
- payments or credits.
- Mortgage providers, beneficiaries of property where the leaseholder is deceased,
- Name and contact details of tenants occupying the property (if any).
- Photographs in relation to any complaints made regarding your leasehold property
- We also obtain some of the above personal information from other sources such as
- your solicitors, mortgagee or other professional advisers.
The provision of the above personal information is required from you to enable us to perform our contractual obligations as the landlord and/or freeholder. We will inform you at the point of collecting future information from you, whether you are required to provide the information to us. We seek to ensure that our information collection and processing is always proportionate. We will notify you of any material changes to information we collect or to the purposes for which we collect and process it.
- Retention of Information
We will retain your personal data for as long as you remain a lessee/occupier and 10 years thereafter which time it will be deleted from our systems and any hard copies will be securely shredded.
- Third Parties
We may share your personal data as follows:
- With other Services within Places for People as necessary to fulfil our obligations under the terms of the lease.
- Contractors & other service organisations, utility companies employed by Places for People who provide services on our behalf,
- Insurance brokers/loss adjusters, external auditors, solicitors during the sale of your property,
- Solicitors, barristers, and the court/ tribunal for the purposes of debt collection proceedings or leasehold disputes.
- Local and statutory authorities, and enforcement agencies as required to promote safeguarding, prevent fraud and identify/deter other criminal activity.
Service providers follow our instructions in respect of the use of your personal information and they must comply with appropriate security measures to protect your personal information.
- Transfer of Data
We do not transfer your personal data outside of the EU.
- Automated Decision Making
We do not engage in automated decision making using your personal data.
How can I find out what personal information you hold about me?
You have a right to know what personal data is held about you. This is known as a Data Subject Access Request. You should simply write to your local Housing Team with a request.
We may send you a form to complete, which asks you for the type of information you are interested in obtaining if it is not clear in your initial correspondence.
A fee of £10 is charged to process your request and you may be asked for identification so that we do not provide your data to anyone else. Copies of your personal information will then be supplied to you within the 40-day period required by the Act but we strive to provide it well within that period.
If you believe that any information we are holding on you is incorrect or incomplete, please inform us as soon as possible. We will promptly correct any information found to be incorrect.
You can find more information about your rights on how we handle your personal data from the Information Commissioner on 01625 545 700 or via their website ico.org.uk/ (opens in a new window)