Personal information provided to or to be gathered by Hightown Housing Association is controlled by Hightown Housing Association Ltd, Hightown House, Maylands Avenue, Hemel Hempstead, Hertfordshire, HP2 4XH.

This privacy notice summarises how we will process your personal data when we are providing support services to you. Additional Privacy Notices are available for Tenants, Shared Owners, Leaseholders, and current, former and prospective staff.  Hightown may update this statement at any time.

Why we collect information about you

Hightown needs to collect, process and store personal information about you, any other household members, advocates and next of kin, in order to deliver efficient and effective support services which are designed to meet your needs.

How we collect information about you

We collect information about you in a variety of ways, including:

  • When you apply for support services, a tenancy or license agreement with us
  • When you are referred to us by a commissioning body such as a Local Authority or Health Service
  • From commissioning bodies as part of ongoing support
  • When you sign a support agreement
  • Through ongoing contact with support teams
  • Recording calls to and from us
  • If you make a complaint
  • When dealing with anti-social behaviour cases or other breaches
  • When providing budgeting advice or welfare benefits information.

When you apply for care or support, we ask for and consider any references or other information necessary to assess your application. This may include, but is not limited to, information from other Landlords, the Police, Probation Service, support services, Social Services and health services.

We also collect information when you voluntarily complete customer surveys, provide feedback and participate in competitions.

Our website does not capture or store personal information but does log the user’s IP address and cookies to record the number of visitors to our website.

Who we collect information about

  • Customers – this includes current and former people we support or tenants, and applicants for housing or support services. People who live in our properties or access our services, including family members and people associated with them.
  • Visitors to our website and offices.
  • 3rd parties which could include individuals whose details you provide as next of kin and individuals who contact Hightown on your behalf such as:
  • Appointees
  • Advocates
  • Other carers (including family members)

What information do we collect?

While you are receiving support from us and as part of your application, we will generally collect and maintain the following information:

  • Your name, address and contact details
  • Your date of birth
  • Previous addresses
  • Contact details for next of kin and individuals who may contact Hightown on your behalf
  • Identification information such as National Insurance Numbers, driving licence, passport or photo identification
  • Your photograph or digital image including CCTV footage
  • Income, benefits, employment, savings and other financial details
  • Payment details
  • General details of anyone living with you
  • Information regarding your support plan or tenancy if you have one with us, including anti-social behaviour, tenancy breaches and complaints made about you, members of your household or visitors
  • Medical conditions and disabilities relevant to your housing and support needs
  • Vulnerabilities and support needs relevant to your housing and support needs
  • Case notes of the support provided to you
  • Information about ethnicity and other special category data required to tailor our services to meet your needs
  • Criminal records or convictions
  • Demographic information such as preferences and interests
  • Other general information relevant to customer surveys or required to carry out the services we provide to you
  • Voice recordings of phone calls

What do we do with the information we collect?

We use this information in order to comply with our legal obligations, manage your support service (and tenancy if you have one with us) and to understand your needs. Specifically in relation to details about your support needs and personal requirements, we use this information to ensure that our services are accessible to you and that we can take account of any support needs to improve our dealings and communication with you.  We will use your information to:

  • Process applications for housing and services
  • Discuss and arrange support for you with commissioners, next of kin, appointees, advocates, other care agencies or statutory bodies
  • Make sure the information is accurate
  • Manage the allocation, letting and maintenance of properties where required
  • Collect rent and service charges where appropriate
  • Offer welfare benefits information
  • Resolve anti-social behaviour reports and neighbour disputes
  • Investigate complaints
  • Confirm your identity and the identity of other members of your household
  • Investigate or prevent fraud
  • Enforce support, tenancy or licence conditions and if necessary, end these where conditions are breached
  • Prevent or detect crime
  • Provide information to public bodies including local authorities and health services to investigate and resolve environmental health and related issues
  • Engage with you to get feedback on our services
  • Provide information on education, employment and training opportunities
  • Target information to customers who need it, for example those who are impacted by welfare reform
  • Enquire about progress with benefit claims, award dates and amounts
  • Improve our services to our customers
  • Send you communications about our services (via post, text message or email).
  • Send you useful information, such as about benefits, safety or changes to our policies
  • Process requests from third parties for example, Council Tax, utility providers
  • For statistical analysis and returns to regulatory bodies
  • Monitor service quality, complaint resolution
  • Tailoring services to meet specific support needs
  • Ensure that communications with you are accessible.

We will not provide your information to any other company for direct marketing purposes. We will not sell or lease your personal information to third parties.

Who do we share your information with?

We will not share your personal information without your consent, unless allowed to by law. We can release account and other personal information when we believe release is appropriate to comply with the law, to enforce or apply the conditions of our agreement with you, including ending a support, tenancy or licence agreement, or to protect the rights, property or safety of Hightown Housing Association, our customers or others. This includes exchanging information with other organisations for the detection and/or prevention of crime.

Examples of organisations we may share your information with, where appropriate, are:

  • Contractors providing services on behalf of Hightown such as repairs, safety checks, estate improvements and parking schemes
  • Local Authorities
  • Housing Benefit Departments
  • Department of Work and Pensions
  • Social Services
  • Police and other law enforcement agencies
  • Probation Service
  • Solicitors
  • Other Landlords
  • Credit reference agencies
  • Banks, Lenders and Creditors when helping solve debt problems with your specific consent
  • Our Insurers
  • Utilities Companies
  • Council Tax
  • Debt Recovery Agencies or bailiff services
  • Courts
  • Printers
  • Mail distributors
  • Email marketing platforms
  • Fire Service
  • Support Agencies
  • Health Services
  • Legal and other professional advisors
  • Courts and other parties in court proceedings
  • Regulators, government agencies and other organisations where we have a lawful obligation to disclose information
  • Our Residents Portal online service provider
  • Other people who you may wish to be involved with a process e.g. your MP or a friend/family member. This will not be done without your permission, and you can withdraw your permission at any time.
  • The Housing Ombudsman, Care Quality Commission and other external agencies you authorise to contact Hightown on your behalf
  • Auditors
  • Organisations with a function of auditing and / or administering public funds for the purpose of detection and prevention of fraud
  • Third parties in the context of the possible sale or transfer of services in which you are involved.

How long do we keep your data?

Documents are retained in accordance with the latest Document Retention guidelines for Housing Associations published by the National Housing Federation.  These are available on request.

Your rights under Data Protection law

You have the right to raise a concern about these issues.  You can also raise a concern with the Information Commissioner’s Office (ICO) if you are not satisfied with the way Hightown deals with your concern.

The right to be informed

You have the right to be informed about the collection and use of your personal data, including the purpose of processing the personal data, how long it is kept for and who it will be shared with.  This information is set out in this Privacy Notice.

Accessing your information

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us using the contact details below. There is no charge for this so long as the request is not unusually large and we will respond to you within 1 month.

Correction and Removal

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove any information you think is inaccurate or no longer needs to be kept.

Object and Restrict

In certain circumstances, you have the right to object to your personal data being processed, or to request that its use is restricted.

Data Portability

You can request that your data is made available in an electronic format that can be transferred to another organisation, in a safe and secure way, without affecting its usability.

Rights in relation to automated decision making and profiling

You have the right to be informed of any use of your data that involves automated decision-making and profiling.  Currently Hightown does not profile personal data and does not have any automated decision-making process for residents’ data or that of people we support.  However, where this changes and it directly affects you, you will be informed. 

Security of information

We are committed to ensuring that your information is held securely. In order to prevent unauthorised access or disclosure we have developed separate IT policies which set out how we keep secure the information held on our systems. We also have a number of physical security measures in place, such as office security and confidential destruction of waste paper.

Your support information will be held until such time as our contract with the commissioning body expires or until all debts or legal proceedings are cleared, or longer if required by law or regulation. We will destroy information securely when we no longer need it.

All data is stored securely in accordance with data protection legislation and all data held on our own computer systems is stored in the UK.

Other websites

Our websites contains links to other websites. Hightown’s privacy policy only applies to Hightown’s websites so when you link to other websites you should read their privacy policies.

Changes to our Data Protection & Privacy policy

We keep our privacy policy under review, and we will place any updates on our website. Hightown’s privacy policy was last updated in February 2024.  Hightown’s full Data Protection & Privacy Policy can be obtained on request from Hightown.

Lawful basis for processing

The lawful basis for much of our personal data processing of your information is where it is necessary for the purposes of Hightown’s legitimate interests.  This is where we are processing your data to allow us to conduct our duties as a landlord and provider of support services.  Where we rely on legitimate interests as a reason for processing your data, we have checked that our interests are not overridden by your rights and freedoms.  Examples would include managing rent arrears, preventing anti-social behaviour, and improving our services.

We may also process your information for other reasons, such as where we are under a contractual obligation to process or disclose the information; for example, providing the services set out in your support or tenancy agreement, liaising with other support organisations or your commissioning body, arranging repairs, or collecting your rents. 

We sometimes will be required to process your data to comply with the law such as providing information to the council or preventing fraud. 

In very rare “life or death” situations, we may need to protect your vital interests or those of another person through careful sharing of data.

The lawful basis may in some instances be because we have your consent to process your personal information. This may apply for optional activities such as sending out surveys.  Where this applies this will be made clear to you and you can withdraw your consent at any time.

Some personal information is more sensitive and needs extra protection. This is called special category data. It includes things like:

  • Your racial or ethnic background
  • Religious or philosophical beliefs
  • Health information
  • Sexual orientation

We only use this type of data when it’s necessary to:

  • Support your care, support or housing needs (for example, if you have a disability and need adjustments)
  • Meet legal requirements (such as equality monitoring)
  • Provide services that are right for you.

We will always explain why we need it and ask for your permission when required. You are not obliged to share this information with us although that may impact on our ability to deliver services tailored to meet your needs. 

We take extra steps to protect this data. It’s stored securely and only shared when absolutely necessary — for example, with healthcare providers or support services, and only with your consent or when the law allows it.

National Data Opt-Out Compliance Statement

As part of providing your care and support services, we collect and use personal health information about you, some of which will need to be shared with the National Health Service.  In turn, the National Health Service may wish to use that data for the purposed of research and planning.

Under the National Data Opt-Out service, you can request that your information is not used for anything other than delivering your care and treatment at any time by following one of the options below:

  • To opt out safely online, please visit https://your-data-matters.service.nhs.uk (You will need a valid email address, mobile number and postcode of your GP Surgery)
  • To opt out over the telephone please call: 0300 303 5678 NHS Digital Contact Centre, Monday to Friday, 9am to 5 pm (excluding bank holidays)

How to contact us

If you have any questions about this Privacy Notice, or the information we hold about you, please contact us at DataProtection@hightownha.org.uk or call 01442 292300