SO Living Applicants Privacy Notice

Effective 25 May 2018

SO Living is a trading name and part of Plymouth Community Homes Ltd.

At Plymouth Community Homes (PCH) we are committed to ensuring that your privacy is protected, and that data is used in accordance with the data protection legislation in force in England and Wales.

This privacy notice sets out why we collect personal information from you, how we use it and who we may share it with. It also explains your individual rights under the current data protection legislation.

If we ask you to provide information which can identify you, then we will only use it in accordance with this privacy notice.

We may change this notice by updating it on our website. You should check the notice from time to time to ensure that you are happy with any changes.

Any queries regarding this notice and our privacy practices can be sent to the company Data Protection Officer by email using governance@plymouthcommunityhomes.co.uk or by writing to the Head of Governance, who is also the Data Protection Officer at -

Plymouth Community Homes
Plumer House
Tailyour Road
Crownhill
Plymouth
PL6 5DH

Alternatively you can telephone us on 0808 230 6500

Who we are

SO Living is a trading name and part of Plymouth Community Homes Ltd.
Plymouth Community Homes Limited is a registered housing provider. Our registration number is 30637R. Our registered office is Plumer House, Tailyour Road, Crownhill, Plymouth, PL6 5DH

For the purposes of data protection legislation, Plymouth Community Homes Limited is a Data Controller

Why we collect information

When being considered for shared ownership through SO Living we collect and process your personal information to assess your affordability and sustainability to purchase a home through the Help To Buy scheme. The legal basis for processing this personal data is that you wish to progress your application which may lead to a contract with us.

What information we collect about you

We will collect the following information from you when we need to carry out an affordability and sustainability assessment:

• Name
• Address
• Date of birth
• Contact details
• Family composition
• Photo ID
• Bank statements
• Income and expenditure information
• Details of your financial circumstances, including employment contract and wages, savings, loans, mortgage details and any other relevant financial information
• Copy of current tenancy agreement, if applicable
• Homeowners – solicitors confirmation of sale ‘subject to contract’

How we collect your information

Plymouth Community Homes collects information from you when you provide documentation, when you complete one of our forms either online or paper based, write, call, email or meet with us or respond to a survey. We will also obtain a copy of your application from Help To Buy which contains your personal information.

Telephone calls – which are made to Plymouth Community Homes through our call centre, are recorded. Recordings of calls may be used, in pursuit of our legitimate interests, for the following reasons:

• For staff training to develop confidence and potential of staff and to improve services
• To check and measure whether we meet standards agreed with customers
• For use in appraisals with staff to develop better customer service
• As evidence where there are disputes
• As evidence in investigations concerning either our customers or staff

Access to call recordings is through sampling apart from training purposes or when abusive or threatening behaviour has occurred or a complaint has been made and requires investigation.

We may collect information when you use our social media sites, e.g. Facebook or Twitter or our website. For more information refer to the separate Privacy Notice for SO Living website users or request a paper copy.

We operate a CCTV system at Plumer House in pursuit of our legitimate interests of building security and the detection and prevention of crime. For more information refer to the separate Privacy Notice for CCTV at Plumer House or request a paper copy.

Photographs – We may take photographs at our events and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent.

We may receive information about you from third parties including:

• Credit agencies when we apply for a credit reference check
• Financial institutions in connection with your mortgage
• Government agencies if we carry out an immigration status check

Special Category Information

Under data protection legislation certain personal information is classed as special category. This information includes racial or ethnic origin, religious or philosophical beliefs, data concerning health and data about sexual orientation.

We minimise our holding and use of special category personal information but, given the services we provide, there are times when we use it to understand our customers and their needs better. Any special category data we may hold about you will have been obtained from your Help To Buy application form.

We will normally only collect special category data with your explicit consent and you have a right to withdraw this consent at any time. However, if you do not wish us to process this data, it may have an impact on the services we provide to you.

What we do with your personal information

We may use your personal information as follows:

• To carry out an affordability and sustainability assessment
• To provide information to the mortgage valuer
• To assess any future ‘staircasing’ applications
• To comply with our legal obligations, which includes carrying out including anti money laundering checks
• For internal record keeping
• To survey you or undertake market research about our delivery of services for quality improvement and monitoring purposes
• To provide statutory statistical information

How long we keep your information

We will only store your information for as long as is reasonably necessary for us to fulfil the purposes set out in this notice. We will then securely dispose of your information.

• This is normally a maximum of six years after you cease to be a leaseholder with us or you become a freeholder.
• If when you cease to become a leaseholder there is an outstanding debt your information will be retained in pursuit of our legitimate interests in recovering that debt.
• Recorded telephone conversations are usually kept for up to 12 months. Recorded calls that are deemed abusive or threatening are kept until any investigation action is completed.
• We will retain CCTV video footage at Plumer House for no more than 10 weeks unless the footage is being used to investigate an alleged crime or incident in which case it may be retained for up to 2 years following the conclusion of any investigation.
• If you have consented to having your photograph taken, consent given is valid for three years, after which the images and recordings will be either securely destroyed or archived. Group shot photographs will be archived and photographs of individuals securely destroyed. If we’d like to use any individual material after three years, we will contact you to ask if you would be willing to renew your consent.

Sharing your information

We will only share your information where we are legally obliged and able to do so, for example:

• To provide you with the services you require
• To comply with the law (e.g. police, health authorities, inland revenue, government departments)
• Where there is a clear health and safety risk
• Where we are requested to do so by another organisation in pursuit of its legitimate interests
• For the detection and prevention of crime, money laundering, prosecution of offenders and for the detection and prevention of fraud.
We may therefore share your information with third parties from time to time such as:
• Building contractors relating to property defects etc.
• Utility companies (water, electricity, gas)
HMRC
• Our insurers and auditors
• Language translation services
• Solicitors for property conveyancing purposes
• The Regulator of Social Housing
• Credit checking agencies
• Council mortgage lenders
• A nominated third party where you have given us permission
• We also share personal information with the Government (Ministry for Housing Communities and Local Government) for research and statistical purposes. For more information on what we share and why please see the Privacy Notice for tenants/buyers of social housing (CORE) on our website or request a copy from the SO Living Team.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect and process.

Whilst the majority of the IT systems that we use are based within the UK, PCH does use the following, which
means that your data may be stored electronically outside of Europe.

• Survey Monkey
• Microsoft Cloud
• Google

Your Rights in relation to your personal data

In certain circumstances, data protection legislation gives you a number of individual rights in relation to your personal data. These are as follows:

• The Right to be Informed about how your data is managed – this right is met by this privacy notice and a range of other notices which relate to specific aspects of PCH, such as the CCTV privacy notice and the website privacy notice.

• The Right of Access to your personal information – so that you can be aware of and verify what personal data we hold. Click here or details on how to apply for this right or ask us for more information.

• The Right of Rectification – to have any personal data corrected if it is inaccurate, incomplete or out of date.

• The Right of Erasure of your personal data – this only applies in certain circumstances, such as where you have given consent for us to hold information and you withdraw that consent.

• The Right to restrict processing – in certain circumstances you have the right to block or restrict how we process your data;

• The Right to data portability – which in certain circumstances allows you to obtain obtain and reuse your personal data for your own purposes across different services

• The Right to object – in certain circumstances, to the processing of personal data. In particular you have the right to object to being sent direct marketing information.

• The Right not to be subject to automated decision making – Plymouth Community Homes does not do this

More information on the individual rights and how they apply can be obtained by clicking here, by requesting a paper copy of our individual rights guidance information or you can visit the ICO website

If you wish to exercise any of the above rights, please contact:

Governance Team
Plymouth Community Homes
Plumer House
Tailyour Road
Crownhill
Plymouth
PL6 5DH

Alternatively, you can make a request electronically, by email, to governance@plymouthcommunityhomes.co.uk or telephone the Governance Team on 01752 388134 or 388152

Making a complaint

If you believe that Plymouth Community Homes has not handled your personal information correctly you have the right to make a complaint. You can raise a complaint in a number of different ways:

• To a SO Living staff member
• At our Head Office at Plumer House, Tailyour Road, Crownhill, Plymouth, PL6 5DH
• Through our website
• Using social media
• By telephone
• In writing

You can also contact the Information Commissioner’s Office (ICO):
Wycliffe House, Water Lane, Wilmslow,
Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Plymouth Community Homes collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests should be sent to the PCH Data Protection Officer at the above address.

If you or someone you know would like this information in large print, braille, or translated into another language, please contact our Communications Team on 0808 230 6500 or email info@plymouthcommunityhomes.co.uk

Plymouth Community Homes Group
Registered Office: Plumer House, Tailyour Road, Plymouth, PL6 5DH

Legal Status:

Plymouth Community Homes Ltd is a registered society under the Co-operative and Community Benefit Societies Act 2014 (which consolidates the Industrial and Provident Societies Acts) and is registered with the Financial Conduct Authority (registration 30637R) and the Regulator of Social Housing (registration L4543).

At the time of issuing this Notice, Plymouth Community Homes Ltd has three wholly owned subsidiaries, Plymouth Community Homes Manufacturing Services Ltd (PCHMS), company number 07001677, Plymouth Community Homes Regeneration Company Ltd (PCHR), company number 7272688 and Plymouth Community Homes Energy Ltd (PCHE), company number 8028170. All three subsidiaries are incorporated under the Companies Act 2006.

Website: www.plymouthcommunityhomesco.uk

Email: info@plymouthcommunityhomes.co.uk
Tel: 0808 230 6500 / 01752 237990