Your privacy is important to us, which is why we only collect the information we need from you and your household to provide you with our services. We take great care to ensure the information we collect is kept confidential and handled responsibly and in accordance with legal requirements including data protection legislation.
Under the data protection legislation, including General Data Protection Regulations (GDPR), we are required to explain to you why we collect information about you, how we intend to use the information you provide and whether we will share this with anyone else.
WHO WE ARE
We are Folio London, one of the UK’s leading providers private rented accommodation. We are part of Notting Hill Genesis.
Our registered address is:
Bruce Kenrick House,
2 Killick Street,
Where we refer to ‘we’, ‘us’ or ‘our’, this refers to Notting Hill Genesis (NHG).
THE INFORMATION WE COLLECT
The sections below explain what information we collect.
Notting Hill Genesis puts small text files, known as ‘cookies’, onto your computer to collect information about how you browse our site. Cookies are not used to identify you personally. By continuing to use our websites you accept the use of ‘cookies’.
This is information that can identify an individual – e.g. name, address, telephone number, email address, date of birth, nationality and cookie information.
HOW WE COLLECT INFORMATION
We collect information in a variety of ways including but not limited to:
• when we sign you as a new tenant
• when you enter one of our buildings via CCTV
• When you call our contact centre
• When you visit our websites
• When you attend a Folio London informational event
When we ask you for information we will:
• Tell you why we need it and how it will be used
• Collect only as much as we need to provide our services
• Take steps to ensure it is accurate and up-to-date
• Make sure we don’t keep it longer than is necessary
• Keep it secure and confidential – so that it is only seen by those members of staff who need it to do their job
In return we ask you to:
• Give us accurate information
• Tell us as soon as possible of any changes in your circumstances
Notting Hill Genesis uses CCTV cameras to manage the safety and security of staff and visitors to all corporate buildings and properties that we manage. Cameras are clearly marked with privacy notices explaining that cameras are in use. Further detail on how we manage cameras is available in our CCTV policy. Images may be captured via CCTV for the purposes of security.
We may also capture and process images during events organised and hosted by Folio London using film photography, digital photography, video or other medium and may be used on our websites, in brochures or other publicity material (such as internal and external newsletters) and may be provided to the media for publication in local or national news publications. We will tell you when we are undertaking recording of this nature.
We undertake to inform all those whose images may be recorded (or their parents/guardians if under 18 years of age) of the purposes for which the images may be used by us. Folio London informs all persons taking part in our activities that they may be photographed, filmed, videoed or otherwise captured in image form. Where reasonable and practical to do so, Notting Hill Genesis seeks written consent to image capture. Where this is not possible for practical reasons, unless express objections are received, individuals attending a Folio London event are deemed to have given their consent by attending or remaining at the event. Any queries or complaints should be raised with the event host in the first instance.
Folio London acknowledges its responsibilities in capturing images by photography or other means under the provisions of the following legislation:
• The Protection of Children Act 1978 – We recognise that it is a criminal offence to take, permit to be taken, distribute, have in one’s possession or publish indecent photographs (including films and other imagery) of children.
• The Human Rights Act 1998 – We recognise an individual’s rights to privacy as protected by this Act.
We would like to provide you with updates about events, services and other information that we believe may be of interest to you in relation to the services we offer. We may send you such information by post or telephone unless you have registered with the appropriate Preference Service or have asked us not to do so.
We do not provide your personal information to other companies for their marketing purposes.
If at any time you do not want your information used for direct marketing purposes, please contact us by email, email@example.com
We would also like to provide you with some information above by email. However, we appreciate that email ‘spam’ is a problem. If you have registered with us or have previously asked us for information on our services via email, we may use that email address to contact you. However, not all the information we will provide to you will necessarily be sent by email.
You can change your preferences on receiving emails from us at any time by emailing us, firstname.lastname@example.org
WHY WE COLLECT THIS INFORMATION
We use your personal data in various areas of work, including:
• Management of homes
• Collection of rents, other sums and receipt of benefits
• Maintenance/repair of homes
• Regulatory purposes – e.g. requirements of the Regulator of Social Housing research
• Legal proceedings
• To meet health and safety requirements of our residents and staff
• Prevention and reduction of crime including fraud
• Equal opportunities monitoring
• Market Research
Sensitive personal data is normally only held if you or someone authorised by you (e.g. a doctor or social worker, or someone living with you) has given us the data.
We only ask for special categories of information where it is necessary for the service and we will ask your explicit consent to do so.
Where we are using your information you have provided us, you are entitled to withdraw your consent at any time. The lawfulness of our use of your information before consent was withdrawn is not affected.
Typically, we hold and process such data regarding managing your housing arrangements to meet your needs. We also use anonymous information about our customers to identify which services we need to provide.
We are registered with the Information Commissioner as data controller. Our registration number is ZA337113 .
WHAT DO WE DO WITH THE INFORMATION WE COLLECT?
• It will be stored and used by us in accordance with this privacy statement and in accordance with your rights under the Data Protection Act 2018 and the General Data Protection Regulation
• In circumstances where there is a legal requirement for us to do so, we will share personal data with governing bodies, e.g sharing data with police to prevent crime.
• It will be collected and used by us fairly and openly for providing our services to you
• It will allow us to provide services which are tailored to your needs
• It will be used to improve the services you receive from us
• It will allow us to contact you in the most appropriate way. For example, we can provide literature in large print if you have difficulty reading smaller print; or provide documents in an alternative language if English is not your first language.
• An understanding of your personal situation and individual needs will allow us to provide a tailored service that meets any physical, cultural or financial needs that you may have.
WHAT IS THE LEGAL BASIS FOR USING YOUR INFORMATION?
In accordance with the data protection laws, we need a “legal basis” for collecting and using information about you. There are a variety of different legal basis for processing personal data which are set out in the data protection laws.
The lawful basis on which we rely to use the information which we collect about you for the purposes set out in this notice will be:
• Using your information in this way is necessary for us to perform the contract between us and to take steps at the request of you prior to entering into the contract;
• It is a requirement of regulatory or governing bodies;
• Internal record keeping;
• Improving service delivery;
• Answering your queries;
• Contacting you for related research and surveys.
We may contact you by email, phone, or post, unless you have registered with the appropriate preference service or requested that we do not to do so. You can request this by emailing email@example.com
OUR LEGAL REQUIREMENTS
We are committed to protecting your data. We will ensure your data is:
• Fairly and lawfully processed
• Processed for limited purposes
• Adequate, relevant and not excessive
• Not kept longer than necessary
• Processed in line with your rights
• Safe and secure
• Not transferred to countries without sufficient protection
For more information please see:
Data Protection Act
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect.
Only relevant members of staff will access the information you provide to us.
‘Phishing’ is the name given to attempts to steal personal details and financial account details from a website user. ‘Phishers’ use fake or ‘spoof’ emails to lead users to imitation websites where the user is tricked into entering their personal details, such as credit card numbers, usernames and passwords. Notting Hill Genesis will never send emails asking you for such details and our staff will never ask you for your password.
If you do receive such an email or are asked for your password by anyone claiming to represent Folio London please forward the email or report the incident by sending an email to firstname.lastname@example.org
WHO WE SHARE THIS INFORMATION WITH
The Notting Hill Genesis Group of companies
Folio London is part of the Notting Hill Genesis Group, made up of several related companies. We will share your information with other members of the Group where necessary to best provide the services to you in accordance with the contract between us. An example of this could be when we wish to let you know about a service being offered by another company in the Group that could benefit your experience with us.
Your information will only be accessed by other companies in the Group where it is necessary to do so to provide services to you in accordance with our contract with you. The obligations which are set out in this notice shall apply to the other members of the Group to the same extent that they apply to us.
When we share information about you within the Group, we will tell you that this is happening and the reasons it has been shared.
See the full list of the companies that make up Notting Hill Genesis.
We might share your personal information with companies who perform services on our behalf. They will only use this information to provide that service. We may also share it with other members of our corporate group, or a purchaser or potential purchaser of our business. If the situation occurs we may have to share your personal information without your consent if the law requires it, for example to government bodies or law enforcement agencies.
Generally, only our staff has access to your personal information. However, in some cases we share it with our business partners, such as:
• Contractors and managing agents
• Local authorities
• Legal advisors
• Police and fire service
• Government departments
• Welfare advisors
• Medical professionals
• Other housing associations
• National Fraud Initiative credit agencies
• Surveying agencies (who only act on our behalf)
We always make sure the organisations understand that the information must be used for the reasons we have specified and must be kept safe and secure. These organisations are also bound by contractual data sharing agreements.
We’ll only share information about you which is relevant and necessary to address your individual needs. Our contractors and sub-contractors are contractually required to ensure that they securely collect and store your information as set out in the Data Protection Act 2018 or the General Data Protection Regulation (as applicable).
In any other instances your personal information will not be shared with any other third parties, unless your explicit consent has been granted for example your MP to respond to a complaint.
Where we share information for these reasons we will tell you before the information is shared. The contractors acting on our behalf will also confirm to you that they are doing so when they contact you, so you know where your data came from.
Regulators and other legal obligations
We may also be required to share your information with our regulators who are permitted access to this information by law for example to respond to a complaint that you have raised with them and with other organisations where we have a legal obligation to share the information with them.
We also share your information with Government bodies for research and statistical purposes. The information helps provide the Government with a better understanding of the social housing market and help inform social housing policy. More information about how this data is used by the Government and why can be found in the Continuous Recording of Social Housing lettings and sales (CORE) notice.
The information you provide us with will never be disclosed outside of the European Economic Area, unless there are appropriate safeguards in place, including contracts and requiring any third party to adhere to these
Accuracy of your information
We endeavour to keep our records up to date. However, if any of your personal details change (e.g. telephone number, contact information), please let us know and we will ensure our systems are corrected.
OUR DATA PROTECTION OFFICER
Our data protection officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
If you have any concerns or questions about our use of your personal data, you can contact our data protection officer by writing to:
The Data Protection Officer,
Notting Hill Genesis,
Bruce Kenrick House,
2 Killick Street,
You can also get in contact by sending an email to email@example.com
MAKING A DATA PROTECTION COMPLAINT
If you have a concern about the way your data has been handled you are entitled to make a complaint. You can write to our data protection officer on the above address or you can get in touch by emailing us.
You also have the right to complain to the Information Commissioner’s Office (ICO)if you are not satisfied with the way we use your information. Please find their contact details here.
CONTROL OF YOUR PERSONAL INFORMATION
The Data Protection Act and General Data Protection Regulations are in place to protect your data privacy. You have many rights under the legislation, one of which is that you may ask to see the information we hold on you by filling out a ‘Subject Access Request’ form.
You can request this form by writing to the address below:
Subject Access Request,
Notting Hill Genesis,
Bruce Kenrick House,
2 Killick Street,
Or you can send an email to dataprotectionnhg.org.uk with the subject heading ‘Subject Access Request’
CAN WE USE YOUR INFORMATION FOR ANY OTHER PURPOSE?
In limited circumstances we may use your information for a purpose other than those set out in this policy. If we intend to use it for another purpose, we will contact you before we do.
DELETING YOUR INFORMATION
We’ll store the personal data which you provide to us for as long as you remain a service user. Once you stop using our service we’ll review your information and determine whether there are any reasons why we need to keep it. For example, if a service user is in arrears when they leave the property, it may be necessary to retain information about them to recover those arrears. Once the identified purpose comes to an end we’ll delete your information. You can also request erasure by emailing our Data Protection Team to firstname.lastname@example.org
In relation to the information which we hold about you, you are entitled to:
• Ask us for access to the information
• Ask us to rectify the information where it is inaccurate or is incomplete
• Ask us to erase the information and take steps to ask others who we have shared your information with to also erase it
• Ask us to limit what we do with your information
• Object to our use of your information and ask us to stop that use
• Instruct us to provide you with the information we hold about you in a structured and commonly used format or transmit that information directly to another organisation (for example, if you want the information to be sent to another housing provider)
Our obligations to comply with the above rights are subject to certain exemptions.