Introduction
Brighton & Hove Seaside Community Homes (collectively referred to as Seaside Homes, we, us or our in this privacy notice) respects your privacy and is committed to protecting your personal data.
This privacy notice will inform you about how we look after your personal data and your privacy rights and how the law protects you where you:
- are a current or previous tenant of one of our properties (Tenants);
- are an applicant for one of our properties (Applicants); and
- visit our website (regardless of where you visit it from) (Website Visitors).
Important information and who we are
Purpose of this privacy notice
This privacy notice gives you information about how we collect and process your personal data as a result of your dealings with us or our agents when you are a Tenant, Applicant, or Website Visitor.
Our website is not intended for children, and we do not knowingly collect data relating to children from our website.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.
Controller
Seaside Homes is a Housing Provider registered with the Information Commissioners Office as a Data Controller. Our registration number is ZA169287. We are responsible for your personal data.
Our [Office Manager] is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice or our data protection practices, please contact our [Office Manager] using the following details:
Post: Unit F, Hove Technology Centre, St Joseph’s Cl, Brighton and Hove, Hove BN3 7ES
Email: info@seaside-homes.org.uk
Telephone: 01273 732061
The types of personal data we collect about you
- Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
- We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
| Type of individual | Types of personal data |
|---|---|
| Applicants, and Tenants | • Identity Data includes first name, last name, (including in relation to any appointees to help with benefit applications or rent payments and anyone who will live with you), date of birth, employment status, National Insurance number, address, ID documents and medical details (allergies, health conditions, disabilities, or vulnerabilities, for example if you need wheelchair access or adaptations to your housing). • Profile Data includes details of your need when you apply to us for accommodation, so we know who needs housing most urgently, and your interests, preferences, feedback and survey responses. • Contact Data includes address, email address and telephone numbers. • Property Data includes the date on which your tenancy begins and ends, monitoring of your compliance obligations in relation to the tenancy agreement, details of complaints and repairs raised, including detail of repairs, stage of complaints, internal notes & comments detailing the complaint, Ombudsman referrals, enforcement actions, gas safety checks, electrical cert, and utilities. • Financial Data includes your household income, credit history, savings, housing benefit details, bank details, rent statements, and rent payment records. • Special Categories of Personal Data including details about your race or ethnicity, sex life, sexual orientation, information about your health and support needs including details of any medication you are required to take. • Criminal Offence Data includes details of any criminal convictions and offences but only to the extent that you or another individual tell us about this. We do not routinely keep any Criminal Offence Data. |
| Website Visitors | • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender. • Profile Data includes any information you provide to us via the website including your interests, preferences, feedback and survey responses. • Usage Data includes information about how you use our website and services. • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. • Contact Data includes address, email address and telephone numbers. • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website. • Special Categories of Personal Data including details about your race or ethnicity, sex life, sexual orientation, information about your health and support needs including details of any medication you are required to take. We only collect this type of data on the website if you insert it in a free text box. |
Special Categories of Personal Data
We may process Special Category Personal Data about you. Special Categories of Personal Data are: racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, data concerning health or data concerning a person’s sex life or sexual orientation.
Where we process this type of data about you it will do so:
- with your consent;
- where we need to protect the vital interests (i.e., the health and safety) of you or another person;
- where you have already made your personal information public;
- where we or another person needs to bring or defend legal claims; and/or
- substantial public interest grounds.
We use Special Category Data to ensure services are delivered appropriately and to monitor equality, diversity and inclusion. In the case of certain health information, this will be needed for health and safety purposes and / or social protection.
To process Special Category Data or Criminal Offence Data, we must have both a lawful basis for the processing and either legal authority or official authority for the processing. We will apply additional security and confidentiality measures when processing your Special Category and Criminal Offence Data.
Where provision of this information is optional, we will make this clear at the point of collection and we will ask for your specific informed consent at the time of collecting this type of data. Where you provide consent for us to process your personal information, you have the right to withdraw this consent at any time.
There will be times where we will not need your consent to process (including sharing) this type of data. This will apply where we are permitted or required to do so by law, for example under health and safety laws or where processing of this data is necessary in order for us to carry out our obligations under social protection law.
Criminal Offence Data
We may also in very limited circumstances process Criminal Offence Data about you. Criminal Offence Data is information that relates to criminal convictions or offences including cautions. We do not ask for or collect this information and will only process it if we are informed about this. This will generally be if you disclose this to us in the context of seeking support, or if, for example, another agency gives us this information in the context of safeguarding.
To process Criminal Offence Data, we must have both a lawful basis for the processing and either legal authority or official authority for the processing. We will apply additional security and confidentiality measures when processing any Criminal Offence Data.
Aggregated Data
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate a Website Visitor’s Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with housing or other services). In this case, we may have to cancel an application or service you have with us, but we will notify you if this is the case at the time.
How is your personal data collected?
We receive personal data relating to you from you directly or through publicly available sources, but sometimes this will be provided to us by third parties with whom you have a separate relationship, such as health professionals, local authorities or other support agencies or organisations that are involved in your support and with whom we work together to provide you with appropriate support.
In addition, as Website Visitors interact with our website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Performance of a contract: to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: where the processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests include ensuring that we monitor, analyse, deliver and improve our services to you and your household members; properly managing our business; and promoting our services. We will look to balance your interests with our legitimate interests where we rely on this category.
- Legal obligation: where we need to comply with a legal obligation.
- Public interest: where we need to perform a task in the public interest.
- Vital interests: where we need to protect the vital interests (i.e., the health and safety) of you, your family or others.
- Consent: with your express consent (for example in relation to special category data).
Generally, we do not rely on consent as a legal basis for processing your personal data although we will obtain your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To prioritise and assess housing applications, service eligibility and to complete tenancy sign-ups and property viewings which will include collecting details of any members of your household | (i) Identity (ii) Contact (iii) Profile (iv) Financial (v) Marketing and Communications (vi) Special Categories of Personal Data (vii) Criminal Offence Data (but only to the extent that you tell us about this or another agency informs us of this and only where we have a safeguarding duty) |
(i) Performance of a contract with you (ii) Necessary to comply with a legal obligation (iii) Necessary for our legitimate interests (to understand who will be living in our properties to; check that accommodation offered is adequate for current and near future needs of the household; to check that household members’ needs are being met; and to ensure that the local community will have quiet enjoyment of their homes) (iv) Condition for processing Special Categories of Personal Data: Article 9(2)(b) UK GDPR – social security and social protection law (v) Condition for processing Special Categories of Personal Data: Article 9(2)(d) UK GDPR – Not-for-profit bodies (vi) Condition for processing Criminal Offence Data: Schedule 1, paragraph 18 of the Data Protection Act 2018 – safeguarding of children and individuals at risk |
| To provide care and support services and to manage your tenancy and our relationship with you which will include: (i) Replying to requests for information and complaints (ii) Managing how we communicate with you (iii) Ensuring that we are meeting your needs when delivering our services (iv) Communicating with you in relation to any changes in your circumstances, which may impact your housing or other needs (v) Notifying you about changes to our terms or privacy notice (vi) Asking you to leave a review or take a survey – we may engage third party processors to undertake research and surveys |
(i) Identity (ii) Contact (iii) Profile (iv) Property (v) Financial (vi) Marketing and Communications (vii) Special Categories of Personal Data (viii) Criminal Offence Data (but only to the extent that you tell us about this or another agency informs us of this and only where we have a safeguarding duty) |
(i) Performance of a contract with you (ii) Necessary to comply with a legal obligation (iii) Necessary for our legitimate interests (to keep our records updated and to ensure that we are meeting your needs when delivering our services) (iv) Condition for processing Special Categories of Personal Data: Article 9(2)(b) UK GDPR – social security and social protection law (v) Condition for processing Special Categories of Personal Data: Article 9(2)(d) UK GDR – Not-for-profit bodies (vi) Condition for processing Criminal Offence Data: Schedule 1, paragraph 18 of the Data Protection Act 2018 – safeguarding of children and individuals at risk |
| To communicate with the Department for Work and Pensions, the Job Centre Plus, local authorities and other agencies and organisations to support you and the management of your benefits and in the provision of support to you. | (i) Identity (ii) Contact (iii) Profile (iv) Property (v) Financial (vi) Special Categories of Personal Data (vii) |
(i) Consent (ii) Condition for processing Special Categories of Personal Data: Article 9(a) Explicit Consent (iii) Condition for processing Special Categories of Personal Data: Article 9(2)(d) UK GDR – Not-for-profit bodies |
| To deal with any medical or other emergencies and to carry out your wishes or requirements such as any religious or cultural wishes | (i) Identity (ii) Contact (iii) Special Categories of Personal Data |
(i) Necessary to comply with a legal obligation (ii) Protecting vital interests (iii) Condition for processing Special Categories of Personal Data: Article 9(2)(c) UK GDPR – to protect your vital interests or those of another person where you are incapable of giving your consent, or Article 9(2)(a) UK GDPR – where you have given explicit consent. |
| To monitor and record telephone calls between you and us | (i) Identity (ii) Contact (iii) Financial (iv) Transaction |
(i) Necessary for our legitimate interests (to improve the service we deliver) |
| To ensure the safety of those within our neighbourhoods and communities and to tackle fraud, crime and anti-social behaviour, | (i) Identity (ii) Contact (iii) Criminal Offence Data (but only to the extent that you tell us about this or another agency informs us of this and only where we have a safeguarding duty) |
(i) Necessary to comply with a legal obligation (ii) Necessary for our legitimate interests (to maintain a safe neighbourhood and to tackle fraud and prevent crime) (iii) Condition for processing Criminal Offence Data: Schedule 1, paragraph 18 of the Data Protection Act 2018 – safeguarding of children and individuals at risk |
| To perform our obligations in relation to gas and electrical checks, repairs, maintenance and adaptations to our properties | (i) Identity (ii) Contact (iii) Property (iv) Special Categories of Personal Data |
(i) Performance of a contract with you (ii) Necessary to comply with a legal obligation (iii) Necessary for our legitimate interests (to ensure that our properties are fit for purpose) (iv) Condition for processing Special Categories of Personal Data: Article 9(2)(b) UK GDPR – social security and social protection law or Article 9(2)(g) – substantial public interest. (v) Condition for processing Special Categories of Personal Data: Article 9(2)(d) UK GDPR – Not-for-profit bodies |
| To respond to legal claims, to deliver support services and comply with our safeguarding obligations. | (i) Identity (ii) Contact (iii) Special Categories of Personal Data (iv) Criminal Offence Data (but only to the extent that you tell us about this or another agency informs us of this and only where we have a safeguarding duty) |
(i) Necessary to comply with a legal obligation (ii) Necessary for our legitimate interests (to monitor lawful activities) (iii) Condition for processing Special Categories of Personal Data: Article 9(2)(f) UK GDPR for the establishment, exercise, or defence of legal claims or whenever courts are acting in their judicial capacity and Article 9(2)(g) UK GDPR – reasons of substantial public interest in relation to the safeguarding of children and individuals at risk (iv) Condition for processing Criminal Offence Data: Schedule 1, paragraph 33 of the Data Protection Act 2018 – safeguarding of children and individuals at risk |
| To comply with lawful requests from local authority departments and other statutory bodies in areas of health and social care (e.g. in support of statutory processes for the safeguarding of vulnerable adults and children) | (i) Identity (ii) Contact (iii) Criminal Offence Data (but only to the extent that you tell us about this or another agency informs us of this and only where we have a safeguarding duty) |
(i) Necessary to comply with a legal obligation (ii) Necessary for our legitimate interests (to ensure safeguarding of vulnerable adults and children) (iii) Condition for processing Special Categories of Personal Data: Article 9(2)(d) UK GDPR – Not-for-profit bodies (iv) Condition for processing Criminal Offence Data: Schedule 1, paragraph 18 of the Data Protection Act 2018 – safeguarding of children and individuals at risk |
| Maintaining records about the amount of money you have paid us; any amount(s) outstanding and action taken to recover money you owe | (i) Identity (ii) Contact (iii) Property (iv) Financial |
(i) Performance of a contract with you (ii) Necessary for our legitimate interests (to recover any sums owed to us) |
| Publishing photographs for promotional purposes | (i) Identity | (i) Consent |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (i) Identity (ii) Contact (iii) Technical |
(i) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (ii) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. | (i) Identity (ii) Contact (iii) Profile (iv) Usage (v) Marketing and Communications (vi) Technical |
(i) Necessary for our legitimate interests (to study how customers use our goods and services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, services, marketing, customer relationships and experiences | (i) Technical (ii) Usage |
(i) Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about services that may be of interest to you | (i) Identity (ii) Contact (iii) Technical (iv) Usage (v) Profile (vi) Marketing and Communications |
(i) Necessary for our legitimate interests (to develop our services and grow our business) |
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to have an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
Opting out
You can ask us to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting the Office Manager.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.
Cookies
For more information about the cookies we use and how to change your cookie preferences, please see our cookie statement.
Disclosures of your personal data
We may share relevant and appropriate personal data with the parties set out in the table below:
- Our contractors to facilitate repairs, maintenance or improvement works.
- Healthcare professionals.
- People or agencies who provide services to you or who work with us to provide services to you, such as your care/support provider.
- Third party research agencies to undertake surveys.
- Credit reference agencies and debt collection agencies, in connection with some housing applications and in relation to any outstanding charges owed to us.
- Department for Work and Pensions, the Job Centre Plus, local authority teams and other agencies and organisations to support you and the management of your benefits and in relation to other support that Seaside Homes can offer to you in related matters such as financial, housing, training and education, childcare, social services and lifestyle support.
- Utility companies (and their representatives) to ensure billing details are correct.
- Service providers acting as processors who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Police and other relevant authorities and regulators (including the Regulator for Social Housing, Department of Work & Pensions, Probation Service and HM Revenue and Customs) based in the United Kingdom who require reporting of processing activities in certain circumstances.
We also share information when required by law for example where ordered by the Court or to protect an individual from immediate harm.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
International transfers
We do not envisage that we will transfer your personal data outside the UK.
However, if we have to transfer your personal data outside the UK we will ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:
- Request access to your personal data (commonly known as a data subject access request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
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 or you have made a number of requests. In this case, we will notify you and keep you updated.
Third-party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to this privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. This version was last updated on 28 November 2024. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
