We are committed to ensuring that the personal data of our customers is handled in accordance with the principles set out in the UK General Data Protection Regulation (GDPR) and The Data Protection Act (DPA) 2018. This privacy notice tells you what to expect when Aspire Housing collects personal information about you. It applies to applicants for housing, tenants and members of their household, former tenants, visitors to our properties and schemes and visitors to the Aspire Housing Website.
Please read this notice carefully and make sure that you understand your rights and responsibilities.
From time to time, as our organisation evolves and develops we may update and make changes to this privacy notice.
ASPIRE HOUSING LIMITED is registered as a Data Controller with the Information Commissioner (registration number Z7678641). Our Registered Office is Aspire Housing, Kingsley, The Brampton, Newcastle-under-Lyme, ST5 0QW Telephone: 01782 635200
ASPIRE HOUSING LIMITED is a leading housing provider, place shaper and property developer. We are a financially strong business. Profits are reinvested in new homes, in revitalising communities and in a comprehensive range of innovative support services, designed to transform lives. ASPIRE HOUSING LIMITED own the trading name Cerris Homes.
ASPIRE HOUSING LIMITED is a Registered Society under the Co-Operative and Community Benefit Societies Act 2014 with number 31218R. We are also authorised by the Financial Conduct Authority to provide Debt Counselling & Debt Adjusting (FCA registration number 672504).
We get information about you from the following sources:
• Directly from you.
• Local Authorities, such as Newcastle Housing Advice and Cheshire East Council, who refer housing applications to us.
• Referees you provide, previous landlords and employers.
• Social workers, medical professionals, credit reference agencies and mortgage lenders who provide us with information relevant to your housing application and needs.
• Aspire employees and contractors who deal with you.
• CCTV images that we operate at our offices, residential blocks and community schemes.
• Key fob usage of communal entrances in residential blocks.
If you provide us with personal information relating to members of your family, household, or associates we will assume that you do so with their knowledge.
3.1 Housing Applications
To prioritise and assess housing applications, eligibility, and complete tenancy sign-ups. The lawful basis we rely on for processing the following personal data is article 6(1)(b) of the GDPR, processing necessary to Perform a Contract or to take steps at your request, before entering a contract.
We will need your name and contact details (including telephone numbers, email addresses and details of anyone you may choose to represent you) for use across the organisation and by our contractors, suppliers, and partners. We will collect detailed personal information about you and other household members, including previous addresses, age, date of birth, National Insurance number, income and benefits details, employment status, relationship status, nationality, caring responsibilities, and bank details.
We will also collect information about any disabilities, any communication and accessibility requirements and medical information relevant to your housing needs. Please see the section below headed Special Category Data for more information.
We process data about criminal convictions and offences with your consent under article 10 of the GDPR and the DPA 2018, Schedule 1, Part 3.
If your application for housing is successful, we are legally obliged to share your demographic details (including religion, ethnicity and sexual orientation) with the Department Levelling Up, Housing and Communities (MCHLG). You can read about how they process your information here; CORE Privacy Notice
3.2 Managing Tenancies
To manage your tenancy, we continue to rely on the lawful basis of the processing being necessary for Performance of a Contract, article 6(1)(b).
We need up to date contact details (telephone number and email address) so we can reach you when we need to discuss issues pertaining to your tenancy, e.g. rent collection, access for maintenance, repairs and improvements, if we need to arrange a home visit or to contact you in the event of an emergency or to enforce the terms of your tenancy. We keep details relating to the repair, maintenance, and servicing such as gas & electricity inspections of your home (although this information will not necessarily constitute your personal data).
We would like to keep records of your circumstances up to date and ask that you help us to do this (e.g. if you have a medical need that means your housing requirements need to be re-assessed we would ask for supporting information about your change in health needs) or to effect any changes to your tenancy (e.g. if you want to change your name on our records we ask for a copy of your marriage or deed poll certificate).
We carry out the following processing because it is in our Legitimate Interest (article 6(1)(f)).
Financial records about the amount of money you have paid us, any amount(s) outstanding and associated recovery action. Depending on the method of payment, we may hold your bank account details.
We may hold information about your history, for example regarding credit status or offences, if we need it to look after our staff, business, or anyone else. We will also use your contact information to tell you about changes at Aspire Housing that effect you.
We will hold records of all our contact with you, and any contact from third parties representing you or about you. This may include call recordings, online chat, and SMS messages.
We are under a Legal Obligation, article 6(1)(c) of the GDPR, to carry out the following processing.
To prevent fraud and illegal sub-letting and to confirm your ongoing eligibility for housing. To investigate and resolve complaints or housing management issues such as Anti-Social Behaviour which may result in us collecting relevant information about you.
3.3 Intensive Housing Management Service
Tenants who require support maintaining their ability to live independently may sign an Intensive Housing Management Agreement. This is a separate document from the Tenancy Agreement. We process information to provide this service under article 6(1)(b), Performance of a Contract.
3.4 Money Advice
We have a Money Advice Team who support Tenants and members of the public that voluntarily engage with the service. We process this information under Article 6(1)(a) Consent.
3.5 Special category data
We routinely process the health data of housing applicants, tenants, and residents where it is relevant to their housing needs and the provision of our services. We rely on GDPR Article 9 2(b), and the Data Protection Act (DPA) 2018 Schedule 1, Part 1 (1) (social security and social protection).
Our Wellbeing, Adaptations, Intensive Housing Management and Independent Living teams rely on your Consent and, where appropriate, Article 9 2(b) or (h) and the DPA 2018 Schedule 1, Part 1 (1) (social security and social protection) or Part 1(2) (health and social care).
When we deal with antisocial behaviour complaints, we will process special category data under Substantial Public Interest (GDPR Article 9 (g)) and the DPA 2018 Schedule 1, Part 2 (10) (Preventing or detecting unlawful acts).
We also collect faith, race and sexual orientation data to monitor equality, diversity and inclusion to help ensure our services are delivered fairly. The lawful basis we rely on to process this information is Consent and the DPA 2018, Schedule 1, Part 2 (8) (Equality of opportunity and treatment).
We collect information that you provide about criminal convictions and offences so that we can safeguard our employees and the communities where we are the landlord. The lawful basis we rely on to process this information is Employment and Social Protection Law (GDPR Article 9 2(b)) and the DPA 2018, Schedule 1, Part 1 (Employment and Social Protection Law).
The DPA 2018 requires us to have an Appropriate Policy Document (APD) for certain conditions of processing special category and criminal offence data. Our APD sets out and explains our procedures for securing compliance with the principles of GDPR and policies regarding the retention and erasure of such personal data.
3.6 Shared Ownership/Right to Buy
If you approach us regarding the purchase of a shared ownership property or you engage with us regarding Right to Buy entitlement the lawful basis we rely on for processing your personal data is article 6(1)(b) of the GDPR, which relates to processing necessary to Perform a Contract or to take steps at your request, before entering a contract.
If you have asked to receive emails or text messages from us about properties for sale, from Cerris Homes, you can unsubscribe from these at any time using the link in each email or by contacting us.
3.7 Customer Forum
As a Tenant we may approach you to take part in our customer forum. We will only further process your information in relation to this with your consent, Article 6(1)(a). Your participation will be for a specified period, and you may withdraw your consent at any time
We operate CCTV for the prevention of crime at all our office premises (both outside and inside), in the communal areas and entrances of residential blocks we own and manage and in public areas of retail and community schemes we manage.
If you are issued with a key fob to gain access to the main entrance of a block the key fob reference will be recorded against your name. The use of key fobs is recorded on a secure, computer-based system to manage the security of the building and the issuing of key fobs.
We carry out the above processing because it is in our Legitimate Interest (article 6(1)(f))
If you sign up for emails through our website, at an event or meeting, we will send you these until you withdraw your Consent (article 6(1)(a) of GDPR). You can do this by clicking on the unsubscribe link in each email or by contacting us.
If you are a Tenant, we will send you emails using our Legitimate Interest (article 6(1)(f) of GDPR). You can unsubscribe from marketing emails at any time.
4.0 Customer Surveys
The Regulator of Social Housing (“RSH”) requires Housing Associations, such as Aspire Housing, to engage with customers over the delivery and performance of our services. This is set out in the Tenant Involvement and Empowerment Standard.
We carry out this processing because it is in our Legitimate Interest (article 6(1)(f)).
We have a legitimate interest to contact you and find out how we can improve our service through our market research surveys. We also have a legitimate interest in making our products and services the best that they can be and promote the success of our organisation.
We may email, text or call you in order to gather any information
The GDPR has provisions on:
· Automated individual decision-making (making a decision solely by automated means without any human involvement).
· Profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.
Aspire Housing analyse rent payment data to help understand which tenants are most likely to fall into arrears. This enables us to contact customers and help them manage their rent account and help them maintain their tenancy.
• Unsuccessful tenancy applications for 6 months.
• Details of Tenancies for 6 years after the termination date.
• Recordings of calls to our contact centre for 40 days.
• CCTV recordings for 30 days.
We may deviate from the above if
• We are legally required to retain information for longer.
• The information relates to a complaint.
• We are preparing information in relation to a legal claim.
The above and all other information we keep, and how long we keep it for is defined on our retention schedule.
ASPIRE HOUSING LIMITED is committed to respecting and protecting your personal data. In certain circumstances we may need to share your personal data with other organisations. When we share personal data to complete a task, we will only share the minimum personal data required to complete that task. We will never sell, rent or trade your personal data.
We will also pass your information on to third parties whom you may ask us to, for example if you ask us to put you in contact with professional advisors.
Who we share data with
We may share your data with the following organisations.
· Auditors, business associates and professional advisers
· Charities and voluntary organisations
· Courts and tribunals
· Credit reference agencies
· Current, past or prospective employers
· Debt collection and tracing agencies
· Emergency services
· Health Authorities, Healthcare, social and welfare organisations, probation services
· Local and central government (we share data of Tenancy Applicants through CoRE, to the Ministry of Housing, Communities & Local Government). We share Housing Benefit and Universal Credit data with the DWP and the relevant Local Authority. We share data about property sales with Homes England.
· Other companies in the same group as the data controller (Achieve Training, The Realise Foundation)
· Other landlords, housing associations or trusts
· Repairs and maintenance contractors (It should be noted that within the terms and conditions of your tenancy agreement it states that you will allow contractors of Aspire access to your property to carry out repairs and maintenance).
· Survey and research organisations
Where we use data processors, we have a written agreement with them that ensures your data is protected and secure.
We use contractors to carry out property repairs and maintenance who we give your contact details so that they can liaise with you.
We use several technology data processors to store data, provide electronic communications, maintain CCTV and operate key fobs.
Under data protection law you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information
1. The right to access the personal data we hold about you. This is known as a ‘subject access request’ (SAR). This right always applies. There are some exemptions, which means you may not always receive all the information we process. We have one calendar month to provide you with the information you have asked for, although this may be extended to two months where requests are complex.
2. The right to have the information rectified if it is inaccurate or incomplete. This right always applies.
3. In certain circumstances you have the right to have your information erased from our records. You can do this where;
We can refuse to erase your personal information where the personal information is processed for the following reasons:
4. The right to object to processing where we say it is in our legitimate interests. We must stop using the information unless we can show there is a compelling legitimate reason for the processing, which override your interests and rights, or the processing is necessary for us, or someone else to bring or defend legal claims.
5. You have the right to require us to stop processing your personal information. When processing is restricted, we can store the information, but not do anything with it. You can do this where:
If we have disclosed your personal information to third parties, we must inform them about the restriction on processing, unless it is impossible or involves disproportionate effort to do so.
6. Your right to data portability. This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organization to another or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.
7. The right to complain to us and/or to the Information Commissioner’s Office if your information is being used unlawfully (contact details are below).
8. The right to challenge any automated decision making or profiling that may be carried out using your information.
If you would like to contact us about your data protection rights, please contact:
The Data Protection Officer, Aspire Housing, Kingsley, The Brampton, Newcastle-under-Lyme,
ST5 0QW. Telephone: 01782 635200. Email: DPO@aspirehousing.co.uk
If you have queries or concerns about how we have processed your information you can complain to our Data Protection Officer. If you remain di-satisfied you can complain to the Information Commissioners Office the contact details are as follows: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. https://ico.org.uk
Where we transfer data outside of the UK we will only do so in compliance with the GDPR transfer rules.
Cookies are small text files placed on your computer by the websites you visit. They are used to help make websites work efficiently. You can control cookies through the settings of your web browser. To find out more, visit www.aboutcookies.org or www.allaboutcookies.org.
These are the cookies we use when you visit our website:
· Google Analytics - to monitor website use and the type of browser that is accessing the website.
· Google Translate - to remember a visitor’s language preferences.
· Hotjar – to monitor website use and the type of browser that is accessing the website.
You can find out more information on the GDPR on the Information Commissioners web site: https://ico.org.uk
You can also contact our Data Protection Officer whose contact details are below:
The Data Protection Officer, Aspire Housing, Kingsley, The Brampton, Newcastle-under-Lyme, ST5 0QW. Telephone: 01782 635200. Email: email@example.com
We also need to share some legal information with you so we’re clear with you how we’re sharing your information as part of this referral process.
Lawful basis for processing your information
We collect this information from you & pass it to our Foodbank partners with your Consent. You may have given this Consent over the phone to a colleague at Aspire Housing when discussing the Foodbank.
Who we share your information with
Newcastle & Staffs Foodbank uses the information we share to provide you with food and provisions. We have a written agreement with them to share data. They are a controller of your data
We generate the Foodbank voucher by entering your details into software hosted by The Trussell Trust who is a controller of the data you provide. This software has strong security measures to keep your information safe. The Trussell Trust supports a nationwide network of foodbanks and to provide emergency food and support to people locked in poverty.
Retention – we will keep your information no longer than we need to. Please see the links below for more information.
Please see the Aspire Housing Privacy notice https://www.aspirehousing.co.uk/privacy to learn more about your rights in relation to processing your data. Do not forget it may be more appropriate for you to contact the Data Controllers we share your information with as follows;
If you wish to contact us, please email us at firstname.lastname@example.org, or write to us at Data Protection Officer, Aspire Housing, Kingsley, The Brampton, Newcastle-Under-Lyme, ST5 0QW.
If you are not satisfied with our response to any query you raise with us, or you believe we are processing your personal data in a way which is inconsistent with the law, you can complain to the Information Commissioner’s Office whose helpline number is:
0303 1231113 or https://ico.org.uk
Last revised January 2022