Sanctuary Housing Right to Buy Privacy Statement
1. Purpose of our privacy statement
1.1 Under the Data Protection Act 2018 and the General Data Protection Regulation, we are required to explain to you why we are asking for this information about you, how we intend to use the information you provide and whether we will share this with anyone else.
2. Who are we?
2.1 We are Sanctuary Housing Association, a part of Sanctuary Group (“Sanctuary”) one of the UK's leading providers of housing, care and commercial services. Our address is Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ.
3. Our data protection officer
3.1 Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
3.2 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, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing firstname.lastname@example.org.
4. Why are we collecting your information?
4.1 The information that you provide to us on your application form and in any supporting documentation is required:
- by Sanctuary in order for us to determine your eligibility for the Government's Voluntary Right to Buy pilot scheme; and
- by the Ministry of Housing Communities and Local Government ("MHCLG"), for the purposes of administering and informing the pilot and other purposes. More detail can be found in the MHCLG privacy statement, an electronic copy can be found at https://righttobuy.gov.uk/wp-content/uploads/2018/09/MHCLG-VRtB-Pilot-Privacy-Notice.pdf
4.2 Without this information, we will not be able to progress your application. Upon completion of any sale your information (where applicable) will be used in connection with any ongoing landlord and tenant relationship and for estate management purposes.
5. What information are we collecting?
5.1 The only information which we are collecting about you is the information which you provide to us in the enclosed application form and any further information we may require to progress your application. We may require further information from third parties as part of our legal obligations which will be relevant to assessing your eligibility.
6. What we are going to do with your information
6.1 The information you provide to us will be used for the following purposes:
6.1.1 It will be stored and used by us in accordance with this privacy statement and also in accordance with your rights under the Data Protection Act 2018 and the General Data Protection Regulation;
6.1.2 It will be collected and used by us fairly and openly for the purpose of determining your eligibility for and extent of entitlement under the Voluntary Right to Buy pilot;
6.1.3 It will allow us to contact you (where applicable) in connection with any ongoing landlord and tenant relationship and for estate management purposes;
6.1.4 It will allow us to provide services which are tailored to your needs; and
6.1.5 It will allow us to make contact with 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.
7. What is the legal basis for using your information?
7.1 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.
7.2 The lawful basis on which we rely in order to use the information which we collect about you for the purposes set out in this notice will be:
7.2.1 using your information in this way is in our legitimate interests in order to determine whether you are eligible for the Voluntary Right to Buy pilot;
7.2.2 subject to eligibility, to perform the sale agreement between us and in order to take steps at the request of you prior to entering into the sale agreement. Where applicable, using your information may also be necessary to support any ongoing landlord and tenant relationship and for estate management purposes; and
7.2.3 in relation to special category data which we are obliged to share with MHCLG the lawful basis for processing that data which MHCLG is relying on is detailed in its privacy statement.
8. Sharing your information
Members of Sanctuary Group
8.1 Sanctuary Group is made up of a number of related companies. We will share your information with other members of Sanctuary Group where necessary in order best provide the services to you in accordance with the agreement between us.
8.2 Your information will only be accessed by other companies in the Group where it is necessary to do so in order to assist in assessing your eligibility for the Voluntary Right to Buy pilot and (if applicable) in connection with any ongoing landlord and tenant relationship and for estate management purposes. 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.
8.3 For more information on which companies make up Sanctuary Group, please go to www.sanctuary-group.co.uk/about-us.
Contractors and sub-contractors
8.4 It may be necessary to share information about you with our contractors and sub-contractors in order to provide you with the services in accordance with the agreement between us. We will only share information about you with Local Authorities, external Property Surveyors and Energy Performance Certificate contractors which is relevant and necessary to address your individual needs and progress your application. The contractors and sub-contractors shall be contractually required to ensure that they adhere to the security requirements imposed by the Data Protection Act 2018 and / or the General Data Protection Regulation (as applicable).
8.5 Our contractors and sub-contractors will not share your information with any other parties and will only be able to use the information when completing work on behalf of us.
Regulators and other legal obligations
8.6 We may also be required to share your information with our regulators who are permitted access to this information by law and with other organisations where we have a legal obligation to share the information with them. We will share your data with MHCLG. For more information about what MHCLG do with your data, please refer to MHCLG's privacy statement.
8.7 We may from time to time share your information with other organisations, such as:
8.7.1 previous landlords to determine your eligibility and any previous eligibility years that need to be counted as part of your application;
8.7.2 utility companies so they can provide services to you and contact you in respect of utility charges;
8.7.3 the police for the purpose of detection and prevention of crime;
8.7.4 organisations with a function of auditing and / or administering public funds for the purpose of detection and prevention of fraud.
9. Transferring your information abroad
9.1 We will not transfer the information you provide to us outside of the European Economic Area.
10. Security of your information
10.1 The information that you provide will be stored securely on our systems and the form that you complete will be shredded. Our security measures and procedures reflect the seriousness with which we approach security and the value we attach to your information.
10.2 Only relevant members of staff will access the information you provide to us.
11. Can we use your information for any other purpose?
11.1 In limited circumstances we may use your information for a purpose other than those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.
12. Storing your information and deleting it
We will store the personal data which you provide to us for the purpose of assessing your application and subsequently for audit requirements. Once the identified purposes come to an end, unless there is another identifiable purpose for which it is necessary to hold on to your information, we will delete your information in line with our retention periods.
13. Your rights
13.1 In relation to the information which we hold about you, you are entitled to:
13.1.1 Ask us for access to the information;
13.1.2 Ask us to rectify the information where it is inaccurate or is incomplete;
13.1.3 Ask us to erase the information, and take steps to ask others who we have shared your information with to also erase it;
13.1.4 Ask us to limit what we do with your information;
13.1.5 Object to our use of your information and ask us to stop that use;
13.1.6 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).
13.2 Our obligations to comply with the above rights are subject to certain exemptions.
13.3 Where we are using your information because you have provided your consent to that use, 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.
13.4 To exercise any of the rights referred to above, you should contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing email@example.com.
13.5 You also have the right to complain to the Information Commissioner's Office (the "ICO") if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.