Privacy Notice

We take your privacy and the security of your information very seriously. This policy sets out our approach to safeguarding the privacy of the personal information we hold.

South Liverpool Homes is responsible for collecting, processing, storing and safe-keeping personal and other information as part of our business activities. We manage personal information in accordance with the Data Protection Act 2018 and The General Data Protection Regulation, and are registered (registration number Z358280X) as Data Controllers with the Information Commissioner’s Office.

This policy applies to all personal information collected by South Liverpool Homes, our subsidiaries and partners, and contractors acting on our behalf.

Our approach to collecting, storing and using personal information

About the personal information we collect

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

In return we ask you to:

• Give us accurate information
• Tell us as soon as possible of any changes in your circumstances

If any of your personal details or circumstances do change then please tell our customer service team via the MySLH app or by calling 0330 303 3000.

The personal information we hold about you

South Liverpool Homes collects the following types of personal information;

• personal details
• goods and services
• supplier details
• financial details
• lifestyle and social circumstances
• complaints
• education and employment details
• health, safety and security details
• visual images, personal appearance and behavior
• ethnicity and sexual orientation

We also process sensitive classes of information that may include:

• physical or mental health details

We will not collect information about you that we do not need and we will ensure that the personal information we collect is updated to our systems in a timely and accurate manner.

We may apply markers to your information (for example, in relation to your vulnerability or health status) to enable us to tailor and deliver services to you.

How we use your personal information

We use your personal information for the purposes of;

• letting, renting and leasing properties
• administering waiting lists
• administering housing and property grants
• providing associated welfare services, advice and support
• maintaining our accounts and records
• supporting and managing our agents, and contractors
• responding to your enquiries
• technical administration
• research and development
• customer administration
• marketing and to identify areas where we can improve the services we provide

We will regularly review the personal information we hold about you and make changes to any service or information-handling processes when the law or the Information Commissioner request such changes.

Legal basis for holding information

Housing applicants are asked to sign a data protection consent form when they apply to us for housing. The consent form sets out the organisations and type of organisations we often have to share personal information about residents with.

Your tenancy agreement is the contract between you and South Liverpool Homes and is the legal basis for us processing personal information.

There are other reasons why we can process your personal information under the GDPR:

• Legitimate interests: where it is in our legitimate business interests as a social landlord to process your information we can do that so long as we do not interfere with your fundamental rights or freedoms
• Where we are under a legal obligation or an obligation under a contract to process/disclose the information
• Where we need to protect the vital interests (i.e. the health and safety) of you or another person

Some personal information is treated as more sensitive (for example information about health). The legal basis for processing personal information is more limited. The reasons we can use are:

• 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
• Substantial public interest grounds

Visiting our websites

When you visit one of our websites, we collect standard internet log information for statistical purposes.

To improve our service we collect anonymous web statistics using a program called Google Analytics. They store several cookies on users' computers or mobiles devices to tell us how many people have visited each web page, how they got there, and where they navigated to from there. The data collected is completely anonymous and does not store any personal details. You have the opportunity to set your computer to accept all cookies, to notify you when a cookie is issued, or not to receive cookies at any time. The way in which you do this depends upon the web browser which you use.

 We do not make any attempt to identify visitors to our websites. We do not associate information gathered from our sites with personally identifying information from any source. When we collect personal information, for example via an online form, we will explain what we intend to do with it.

Our websites contain links to various third party websites. We are not responsible for the content or privacy practices of any external websites that are linked from our sites.

Visiting our office

For the protection of our colleagues and customers, CCTV is installed in all of our reception areas, entry and exit corridors and interview rooms. Recordings may also be used to provide enforcement agencies with evidence of criminal activity. Images are retained for a maximum of 15 days.

Who we share your information with

We share personal data with law enforcement and government agencies or public bodies where we are legally required to do so. Examples may include:

• The prevention or detection of crime and fraud
• The apprehension or prosecution of offenders
• The assessment or collection of tax or duty owed to customs and excise
• Sharing in connection with legal proceedings
• Sharing in relation to the physical or mental health of an individual, where disclosure is required to protect them or others from serious harm

In order to measure our performance and to improve the services we deliver to you, we may also use third party research companies to collect customer satisfaction data, via telephone and electronic surveys.

We may also share personal data with emergency services and local authorities, where this is necessary to help them respond to an emergency situation that affects you.

In some areas we may enter into partnerships with other organisations such as local authorities and the police. For example, we may join a partnership to help prevent and control anti-social behaviour.  In order to protect your information, we will enter into a legally binding data sharing agreement with partner organisations before any sharing takes place.

If your household has entered into a social housing tenancy we will share your personal information with the Ministry of Housing, Communities & Local Government for research and statistical purposes. We may also share your personal information with the Housing Ombudsman when dealing with complaints.

There are some cases when we will share your information to support legitimate business purposes. We do this to ensure that we can meet your needs, and also to meet our health and safety obligations towards those delivering services on our behalf. This may include sharing information with our contractors and suppliers to enable them to carry out duties on our behalf or to meet contractual obligations we may have. For example, we may share information to enable our maintenance contractors to make appointments with you to carry out repairs and/or deliver services.

Keeping your information secure

We store personal information both electronically and in paper form.

We implement security policies, processes and technical security solutions to protect the personal information we hold from:

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

When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, support workers, solicitors) act on your behalf we will take steps to ensure that you have agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.

Employees and third parties who have access to, or are associated with the processing of, your personal information are obliged to make reasonable efforts to safeguard it.

Data retention

South Liverpool Homes will retain your data for as long as is necessary to provide you with a service and fulfil our contractual and legal obligations. In addition, we may retain personal information about former tenants to comply with national laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, and take other actions

How we use your telephone number

Text messages and contact via telephone provide a direct way to contact and share information with you about the services we can deliver to you. It can also help you receive important promotional/marketing messages which may interest or help you.

If you provide your telephone number we may keep in contact with you by text.

In order to improve the service we offer to you, we record all of our telephone calls, and retain them for a maximum period of 12 months.

Operational SMS/text messaging and calls

If you supply us with your telephone contact details, we may use them to call or send you operational text messages.

Examples of operational text messages include:

• Confirming a repair and/or a time and date for a repairs contractor to visit
• Confirming a home visit
• Sending a reminder about an appointment
• Asking you to contact a named person
• Satisfaction surveys

Sharing your telephone number with third parties

We may pass your telephone number to third parties so that where this is;

• necessary to meet our contractual obligations with you
• required to by law
• required by third party contractors who are delivering or performing services on our behalf

We will not disclose your telephone number to third parties for their marketing and advertising purposes.

Your rights

You have the following rights over your personal data;

Right of access: You have the right to obtain confirmation from South Liverpool Homes as to whether or not personal data concerning you are being processed, and, where that is the case, access to that personal data (see ‘Requesting a copy of your personal information’ below)

Right to rectification: You have the right to oblige South Liverpool Homes to rectify inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed by providing a supplementary statement.

Right to erasure (right to be forgotten): You have the right (under certain circumstances, but not all) to oblige South Liverpool Homes to erase personal data concerning you.

Right to restriction of processing: You have the right (under certain circumstances, but not all) to oblige South Liverpool Homes to restrict processing of your personal data. For example, you may request this if you are contesting the accuracy of personal data held about you.

Right to data portability: You have the right (under certain circumstances, but not all) to oblige South Liverpool Homes to provide you with the personal data about you which you have provided to us in a structured, commonly used and machine-readable format.

You also have the right to oblige South Liverpool Homes to transmit those data to another controller.

Right to withdraw consent: If the lawful basis for processing is consent, you have the right to withdraw that consent which you can exercise by writing to the data protection officer at the contact details provided above.

Right to object to direct marketing: Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for marketing, which includes profiling to the extent that it is related to such direct marketing.

Rights in relation to automated decision making and profiling:          South Liverpool Homes does not perform any automated decision-making based on personal data that produces legal effects or similarly significantly affects you.

For more information about any of your rights, please visit

If you wish to exercise any of your rights concerning your personal data, please contact South Liverpool Homes’ Data Protection Officer at the address shown below.

Contacting us

If you are a South Liverpool Homes customer, our customer service team will be able to help you with most queries and requests you may have. If you want to contact us specifically about the privacy of your personal information, please contact:

Data Protection Officer, South Liverpool Homes, Parklands, Conleach Road, Liverpool, L24 0TY.

Requesting a copy of your personal information

As part of our service to you, we are happy to provide you with copies of specific documents (e.g. rent statements, tenancy agreements) upon request on an informal basis. If you want to make a larger or more comprehensive request, you can do this formally by making a ‘subject access request’.

If you make a subject access request we will provide you with a readable copy of the personal information we hold about you. To make a subject access request you must contact us at the address above and provide us with proof of your identity. We will provide the information back to you within one calendar month.

Questions and complaints

Please tell us if you have a concerns about the personal information we hold about you, or how we use it. We’ll do our best to help.

If you are dissatisfied with our response, or are unhappy with the manner in which we have dealt with a subject access request (or any other type of information rights request) then you have the right to lodge a complaint with the supervisory authority. In the United Kingdom this is:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

(t) 0303 123 1113 (e) casework@ico.org.uk

Keeping this policy updated

We keep our privacy policy under regular review. This privacy notice was last updated on 17 July 2020.