Privacy Notice for Lettings
Published on 08 February 2022
Places for People Homes is committed to protecting your privacy when you use our services.
The Privacy Notice below explains how we use information about you and how we protect your privacy when we are dealing with lettings. This privacy notice (the “Privacy Notice”) applies to personal information processing activities carried out by Places for People Homes in relation to lettings.
Our core commitments and obligations in relation to data protection are detailed on our full Privacy Notice
Places for People Homes 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). In connection with Lettings activity, where we use common housing registers and choice based lettings systems hosted by a third party we may be a data processor or co-controller.
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 these cases.
Why we process your personal data
What is processing data?
Processing data includes the collection, use, storage and sharing of data held electronically or on paper.
What is personal information?
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.
Applying for a tenancy
We collect personal data about you and your household when you apply for the property. This is to enable us to assess whether you qualify for the tenancy for which you have applied. This can include, but is not limited to:
- Household size
- Names, dates of birth, contact details for you and your household members
- National Insurance Numbers if you are in receipt of welfare benefits
- Income details for adults and non-dependants in the household
- Household total income and expenditure
- Whether the applicant(s) have a bank account
- Previous address history and the reason for leaving your previous homes
- Proof of identification for all adults in the household
- Disability and/or support needs
- Presence on social media
- Information on unspent criminal convictions
- Information on mortgage or rent arrears and we will complete a credit check
- We may contact agencies like your support providers, probation officers or the Police
- Diversity information on you and your household
- If a member of the household has ever been a member of the armed forces
We store the personal data in paper and electronic forms and have security policies, processes and technical security solutions to protect the personal data we hold. Further details are on our Privacy Notice including information on your rights.
If you apply for a property and you change your mind at first contact or we are unable to offer you a property based on information provided, your details will be deleted.
If your application is fully verified, your information is securely retained electronically and deleted in line with our deletions policy.
During the process of signing a tenancy agreement we will take a photograph of every person on the tenancy. This is then held on your tenancy file. We implement security policies, processes and technical security solutions to protect the personal information from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss.
The picture is taken and stored for the purpose of verifying your identity at a future date. This may be:
- To identify or prevent tenancy fraud
- For the prevention and detection of crime and disorder
- The pictures may be used by officers of Places for People to confirm your identity.
- The pictures may be shared with the Police and/or solicitors for the purposes to taking legal action for breach of tenancy or for prosecutions for crime and disorder.
Guarantors and those with Power of Attorney
You may have agreed to be a guarantor or are signing the tenancy agreement on behalf of a tenant as you have Power of Attorney (Property & Financial Affairs) or are an appointed Property and Financial Affairs Deputy.
In these cases we will require:
- Your name
- Contact Details (telephone number, email)
- Date of birth
This is to enable us to contact you as the tenant’s representative. This could be on any matter that we would normally contact the tenant about.
Right to Rent
We collect copies of your Right to Rent documentation. This is any document that you, and any members of your household over the age of 18, have used to demonstrate your right to rent under the terms of the Immigration Act 2015. We are legally required to collect, record and store this documentation.
It will be used, if required, to demonstrate that when we let the property to you, you and your household members proved you had the right to rent in the UK. This will be shared with the Home Office and legal advisors if there are any challenges to your right to rent.
Why do we need this personal information?
This information is used to ensure you are eligible under the Lettings Policy to be offered the property. This can include whether the property is suitable for you and your household, whether you need support and if this is provided for you, to help you to be able to maintain your tenancy and whether your application should be refused or rejected under the criteria detailed in the Lettings Policy. We will collect diversity information for monitoring purposes and consider whether you have different service requirements that we can provide.
We also collect data to fulfil statutory or regulatory reporting requirements and responsibilities through the provision of anonymised data.
Do I have to provide the personal data?
The decision to apply for a property with Places for People and or its partners is yours. If you do decide to apply for a home with us, the information we request is required to be able assess your application and let a property to you.
The information is required for contractual purposes and our legitimate interest to be able to manage your tenancy and provide a service to you.
Sensitive or Special Category Data
Some personal information you provide might be sensitive such as information about your health, ethnicity, biometric and additional data captured by the CORE entry form. Information classed as sensitive will require your consent, therefore by giving us that information you are consenting to us holding it.
We only use what we need
We only collect and use the information that we need to confirm your eligibility for the property and to be able to manage the tenancy.
The information we collect when you sign your tenancy agreement will be retained on your tenancy file. We may use this information throughout your tenancy if relevant to do so. This may be to provide a service to you, to take legal action if required, for the purpose of service improvement and to help with research and planning new services.
Who we share the data with
For the initial application and sign up of the tenancy, if you were nominated by a local authority or offered a property through a common register, we will share the outcome of the nomination with the third party. This is required so you can either be removed from the waiting list or the offer removed so you are eligible to be offered properties by other landlords.
Utility Companies and Local Authorities
We will share your personal information such as your name, address and contact details 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 share your personal details such as forwarding address or contact information after you have left us if there are arrears with a utility or local authority for services received.
The information we collect when you sign your tenancy agreement will be retained on your tenancy file. We may use this information throughout your tenancy if relevant to do so. This may be to provide a service to you or to take legal action if required
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.
Rights to process data
When you apply for rehousing you are consenting to your personal data being processed to facilitate the letting.
During your tenancy we may process your personal data for using a number of legal basis as defined in the GDPR and DPA. These basis include but are not limited to delivering services to you under the tenancy agreement, when we have your consent or where we have a legitimate interest to do so. Privacy notices are published when we collect your personal data such as when applying for a property and again at sign up.
Automated decision making
In the area of lettings work some of the registers we use involve automatic decision making. The decision is based on the information that you have provided and has been verified. This information can then determine your rehousing priority on a register. The registers you have applied to will have details on how you can appeal your priority and provide information on the processing.
How long do we keep your personal data
The information you upload to the Places for People property website is held for a period of three months before being deleted.
If you accept a tenancy with us we will retain the application information that we need on your tenancy file. This is retained and deleted in line with our Disposal and Retention Schedule.
For information on the following, please refer to the full privacy notice at Privacy Notice
- Keeping your information secure
- Your rights
- How to tell us of a data breach
- Where you can get advice.