Privacy Policy

Introduction

We are committed to ensuring that the personal data of our customers is handled in accordance with applicable UK data protection legislation including, but not limited to, the UK General Data Protection Regulation (EU) 2016/679 (UK GDPR) and the Data Protection Act 2018 (the DPA). 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. This Privacy Notice explains what personal data we collect, the categories of information we record, and why we use it.

It is important that you read this notice, together with any other privacy notice as it tells you about the sort of personal information we collect and how and why it will be used by us.

In some circumstances, we may provide additional or service specific privacy notices to give more detailed information about particular activities or services. Where this happens, those notices should be read alongside this Privacy Notice.

We reserve the right to modify or amend this Privacy statement at any time and for any reason, providing it maintains compliance with the UK GDPR. We may update this Privacy Notice from time to time to reflect changes in our services, organisational changes, or updates to data protection law. We encourage you to review this notice periodically so you remain informed about how we use your personal data.

This privacy notice was last updated in May 2026.

If you would like this Privacy Notice in a printed format or an alternative accessible format, please contact us using the details provided in the ‘How to Contact Us’ section.

Who We Are

ASPIRE HOUSING LIMITED is registered as a Data Controller with the Information Commissioner (registration number Z7678641). Our Registered Office address 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, revitalising communities and 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).

How Do We Get Your Information?

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.
• The police.
• Referees you provide (these may be 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 housing needs.
• Probation Services.
• Support Workers.
• Aspire Housing 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.

Such information may be collected over the phone; by face-to-face contact; when receiving written, or electronic correspondence – this includes letters, emails, application forms (physical or online), questionnaires, and text messages.

Why We Process Personal Data and the Lawful Basis We Rely On

In summary, we use your personal data so we can provide housing services, manage your tenancy, keep residents safe, meet our legal obligations as a social housing provider, and improve the services we deliver to you. We only process your personal data where the law allows us to do so and where the processing is necessary for those purposes.

Below we explain the main activities we carry out and the legal reasons (known as “lawful bases”) we rely on under the UK GDPR when processing your personal data.

Housing Applications

To assess housing applications, eligibility, and complete tenancy sign-ups, we process your personal data under Article 6(1)(b) of the UK GDPR: processing necessary to perform a contract or 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, including any communication and accessibility requirements and/or medical information relevant to your housing needs. Please see the section below, “Special Category Data” for more information.

We process data about criminal convictions and offences in accordance with Article 10 of the UK GDPR and the DPA 2018, Schedule 1, Part 2 and Part 3, where processing is permitted by law and appropriate safeguards are in place.

If your application for housing is successful, we are legally obliged to share your details about your background, but not your name with the Ministry of Housing, Communities & Local Government. You can read about how they process your information here; CoRE Privacy Notice.

Managing Tenancies

To manage your tenancy, we continue to rely on the lawful basis of the processing being necessary for the 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 does not necessarily constitute your personal data).

We keep 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 would like to keep records of your circumstances up to date and ask that you help us to do this. Examples include:

• If you have a medical need that means your housing requirements need to be re-assessed, we will ask for supporting information about your change in health needs.
• If you want to change your name on our records, we ask for a copy of your marriage or deed poll certificate.

We process this data under our legitimate interest (Article 6(1)(f)) to provide the best service possible.

• We will use your contact information to tell you about changes at Aspire Housing that affect 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) and there is often a public interest in carrying out a public task, Article 6(1)(e) of the UK 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.

In limited circumstances, and where we are required to do so by law, Article 6(1)(c), or where it is necessary in the public interest, Article 6(1)(e), to protect our employees, contractors, residents, or other members of the public, we may record information about incidents involving violent or abusive behaviour. This may include placing a marker on a customer record to alert colleagues to potential risk.

Where appropriate and safe to do so, we will inform you if such a marker has been applied and explain why. You will have the right to challenge or appeal this decision unless we reasonably believe that doing so would pose a further risk to others. Any such marker will be reviewed and retained only where it remains necessary and proportionate.

Information about such markers may be shared with relevant partners, such as contractors, solely for the purpose of protecting their staff and ensuring safety. We will only share the minimum information necessary.

We may also process personal data relating to children and young people where this is necessary for tenancy management, safeguarding, or the provision of services.

Manage Your Home Online

Customers can manage their home online through our online portal. Through this service, customers can:

• raise non emergency repairs
• view their rent account and pay rent
• send messages to their Neighbourhood Coordinator
• raise anti social behaviour (ASB) concerns

When you use our online services, we process your personal data to provide these services and to manage your tenancy. We have appropriate technical and organisational measures in place to protect personal data processed through our online systems.

Enhanced and Intensive Housing Management Services

Tenants in our Community Living schemes who need support to live independently may sign an Enhanced Housing Management Agreement, while tenants in individual properties may sign an Intensive Housing Management Agreement. These are separate from the Tenancy Agreement. We process information for this service under Article 6(1)(b), performance of a contract.

Money Advice and Employment and Skills Support

We have a Money Advice Team and an Employment and Skills Support Team who support tenants and members of the public that voluntarily engage with the services. We process this information under Article 6(1)(a) Consent.

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 UK 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 (UK GDPR Article 9(2)(g)) and the DPA 2018 Schedule 1, Part 2 (10) - preventing or detecting unlawful acts.

We also collect information on faith, race and sexual orientation 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 Article 6(1)(a), 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 and (GDPR Article 9(2)(b)) and substantial public interest, under UK GDPR Article 9(2)(b) & (g) and the DPA 2018, Schedule 1, Part 1 and Part 2.

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 the UK GDPR and policies regarding the retention and erasure of such personal data.

The Noise App

The Noise App is a third-party application used to capture audio recordings. We use personal data collected through The Noise App to assist investigations into noise nuisance and to determine whether the noise report is anti-social behaviour, domestic living noise or a statutory nuisance.

We carry out this processing because it is in our legitimate interest (Article 6(1)(f)) (or those of a third party) and your interests and fundamental rights do not override those interests.

Using The Noise App is optional. We will use the contact details of customers who choose to use The Noise App to contact them regarding their reports of noise nuisance.

Each report/recording consists of a 30-second recording of the noise nuisance that the customer is experiencing, including the type of noise, the location within the property where the recording was made, how much it is affecting them, and the noise source address/ location.

Once submitted, the information is forwarded to the relevant team dealing with noise nuisances for further investigation. Reports and recordings may be used as evidence in investigating and managing anti-social behaviour and statutory nuisances, including where relevant, for legal proceedings.

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 UK GDPR, which relates to processing necessary to perform a contract or to take steps at your request, before entering a contract.

Foodbank Referral

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 and pass it to our Foodbank partners with your consent Article 6(1)(a). 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.

Please see the links below for more information about the processing of your personal information.
https://newcastlestaffs.foodbank.org.uk/privacy-cookies-policy/
https://www.trusselltrust.org/privacy/

Customer Forum

As a customer, we may approach you to take part in our customer forum. We further process your information in relation to this as a legitimate interest to improve our services, Article 6(1)(f). Your participation will be for a specified period, and you may withdraw your consent at any time.

Marketing

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)). 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 the UK GDPR). You can unsubscribe from marketing emails at any time. We may declare some emails or text messages as Service Messages which are not subject to marketing rules.

Customer Surveys

The Regulator of Social Housing (“RSH”) requires Housing Associations, like Aspire Housing, engage with customers regarding the delivery and performance of our services, as outlined in the Tenant Involvement and Empowerment Standard. We process this information based on 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 customer surveys. Our legitimate interest includes contacting you to gather feedback through customer surveys to improve our services. Additionally, we aim to enhance our services and ensure the success of our organisation. We may email, text or call you to gather any information.

If personal information is not necessary, we’ll keep your response anonymous. For instance, in a survey, we may only collect your responses, without needing your contact details. If we use your personal information for research and analysis, we’ll keep you anonymous unless you’ve agreed that your personal information can be used for that research.

Automated Decision Making and Profiling

The UK 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.

Sharing 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. Special categories of personal data are confidential and will only be made available to those who require it. We will never sell, rent or trade your personal data.

We will 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 information about you with third parties including government agencies, independent regulators, and external auditors. Examples of who we may share your information with include but are not limited to:

• Business associates and professional advisers.
• Charities and voluntary organisations.
• Courts and tribunals.
• Credit reference agencies.
• Current, past or prospective employers.
• Debt collection 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 Department of Levelling Up, Housing and Communities).
• Housing Benefit and Universal Credit data with the DWP and the relevant Local Authority.
• Council Tax liability information with the local authority.
• Data about property sales with Homes England.
• Other landlords, housing associations and property exchange platforms.
• 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 Housing access to your property to carry out repairs and maintenance).
• Survey and research organisations.
• Police.
• We may share information reported/recorded through The Noise App with law enforcement and third-party suppliers providing our systems.

Data Processors

Where we use data processors, we have a written agreement with them that ensures your data is protected and secure.

We have a legitimate interest to ensure utility bills are accurate and assigned to a new tenant. We use a utility broker as a single point of contact to liaise with tenants, Aspire Housing and the utility companies.

When you move into a property we share your name, contact details and the start-date of your tenancy with the utility broker, Energy Angels (https://energyangels.co.uk/).

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.

Data Security

We have put in place appropriate security measures to prevent your personal data from:

• Unauthorised access
• Improper use or disclosure
• Unauthorised modification
• Unlawful destruction or accidental loss

We limit access to your personal data to only the employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions.

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)) to secure our properties, and it is in the public interest (Article 6(1)(e)) to prevent crime and anti-social behaviour.

Data Retention

We retain:

• Unsuccessful tenancy applications for 6 months.
• Information on your tenancy file for 6 years (plus current) following the end of your tenancy with us.
• Call recordings for 40 days.
• CCTV recordings for 30 days.
• Noise App recording information for up to 2 years.

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.

In certain cases, we may need to keep it for longer where an historic noise complaint is re-activated and/or information is needed for the purpose of legal proceedings.

All information we keep and how long we keep it for, is defined in our retention schedule.

Your Data Protection Rights

As an individual you have certain rights regarding the processing of your personal information, including a right to log a complaint with the Information Commissioner’s Office as the relevant supervisory authority.

Your rights, as laid out in the UK GDPR are as follows:

• The right of access - you have the right to ask for a copy of the information we hold about you.
• The right to be forgotten - in certain circumstances you can ask for the information we hold about you to be erased from our records.
• The right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• The right to rectification – you have the right to request your information be changed, if the data we hold is inaccurate, out of date or incomplete.
• The right of data portability - you have the right to have the data we hold about you transferred to another organisation.
• The right to object – you have the right to object to certain types of processing such as direct marketing.
• The right to object to automated processing, including profiling – you have the right not to be subject to the legal effects of a decision based solely on automated processing or profiling.

We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex. In this case, we will notify you and keep you updated.

If we need to establish your identity before responding to a request to exercise your rights, we may ask that you provide us with ID, for example passport, driving licence, birth certificate or utility bill (dated within the last three months).

You can exercise any of your information rights by contacting the Data Protection Team using the details provided in the ‘How to Contact Us’ section. This request can be made verbally, in writing, via email or by completing the Data Subject Access Request Form (available on our website). You may also ask someone to do this on your behalf. No charge will be made for this service.

International Transfers

We will not transfer your personal information outside of the United Kingdom or European Economic Area unless that country, or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data. We will ensure that anyone we pass personal information to agrees to treat it securely and confidentially, and to use or process it solely for the reasons it is provided.

Website Cookies

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.
• AccessiBe - to remember a visitor’s language preferences.
• Microsoft Clarity – to monitor website use and the type of browser that is accessing the website.

Queries and Complaints

If you have any questions about our privacy notice or information we hold about you, or you wish to make a complaint about how your personal data is processed by Aspire Housing, please contact the Aspire Housing’s Data Protection Team using the details provided below in the ‘How to Contact Us’ section.

You also have the right to complain to the ICO about how we have processed your personal data.

The ICO can be contacted at:
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113 or through the website www.ico.org.uk

How to Contact Us

Our Data Protection Officer is responsible for overseeing Aspire Housing’s compliance with data protection legislation and advising the organisation on its data protection obligations.

You can contact us in the following ways to discuss any aspect of this notice or about the information we hold about you:

• Writing to the Data Protection Team at Aspire Housing, Kingsley, The Brampton, Newcastle-under-Lyme, ST5 0QW.
• Telephone: 01782 635200
• Email: DPO@aspirehousing.co.uk

Please note that if you contact us by telephone, your call may be recorded for training and quality purposes.