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 supporting you as a resident. Additional Privacy Notices are available for service users and current, former and prospective staff.

You have the right to raise a concern about these issues about how your data is handled. 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.

  • Why we collect information about you

    Hightown needs to collect, process and store personal information about you, and other household members, advocates and next of kin where you provide that information, in order to operate as a registered provider of housing and deliver efficient and effective services.

  • How we collect information about you

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

    • When customers apply for a home
    • When customers sign a tenancy agreement
    • Through ongoing contact with tenants throughout their tenancy, including requests for repair, transfer and other services
    • When customers access services by logging in to our website or the resident’s portal
    • Recording calls to and from us
    • When customers end their tenancy
    • If a customer makes a complaint
    • When dealing with anti-social behaviour cases or other tenancy breaches
    • When providing welfare benefits information.

    When you apply for a Hightown home, we ask for and consider any references / 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 tenants, and applicants for housing. People who live in our properties or access our services, this includes family members and people associated with them.
    • Visitors to our website and offices.
    • 3rd parties; individuals whose details you provide as next of kin and individuals who contact Hightown on your behalf; individuals involved in complaints, tenancy breaches and reports of anti-social behaviour in relation to your tenancy.
  • What information do we collect?

    During your tenancy, we will generally collect and maintain the following information:

    • The names of all household members
    • Your address
    • The dates of birth of all household members
    • Your contact information, including phone numbers and email address
    • Contact details for next of kin and individuals who may contact Hightown on your behalf
    • Identification information such as National Insurance Numbers
    • Your photograph or digital image
    • Income, benefits and other financial details
    • Payment details
    • General details of those living in the property
    • Information regarding your tenancy, including anti-social behaviour, tenancy breaches and complaints made about you, members of your household or visitors
    • Medical conditions and disabilities
    • Vulnerabilities and support needs
    • Information about ethnicity
    • Criminal records/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
    • Your vehicle registration details where we operate Automatic Number Plate Recognition systems
    • 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 tenancy and understand your needs. We will use it to:

    • Process applications for housing and services
    • Make sure the information is accurate
    • Manage the allocation and letting of properties
    • Collect rent and service charges
    • Provide a repairs and maintenance service
    • Offer welfare benefits information
    • Resolve anti-social behaviour reports and neighbour disputes
    • Investigate complaints
    • Investigate or prevent fraud
    • Enforce tenancy conditions and end tenancies where conditions are breached
    • Prevent or detect crime
    • Engage with customers 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 customers
    • To send you communications about our services (via post, text message or email).
    • To 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.

    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 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 tenancy, 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
    • Ministry of Housing, Communities and Local Government - see their privacy notice here
    • Social Services
    • Police
    • Probation Service
    • Solicitors
    • Other Landlords
    • Credit reference agencies
    • Banks, Lenders Creditors and Financial Advisors in connection with shared ownership sales or when helping solve debt problems with your specific consent
    • Our Insurers
    • Utilities Companies
    • Council Tax
    • Debt Recovery Agencies
    • Courts
    • Bailiff services
    • Printers
    • Mail distributors
    • Email marketing platforms
    • Fire Service
    • Support Agencies
    • Health Services
    • The current provider of our Residents Portal online service.
    • 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.
    • Auditors
  • How long we keep your data for

    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 the GDPR

    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 & 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 & 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.

    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.

  • 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 the information held on our systems secure. We also have a number of physical security measures in place, such as office security and confidential destruction of waste paper.
    Information about residents is kept for the duration of the tenancy/lease and then for a period of up to 7 years or until all debts and/or legal proceedings are cleared. We will destroy information securely when we no longer need it.
    All data will be stored securely within Europe and all data held on our own computer systems is stored locally in the UK.

  • Special Categories of Data

    Information about health or medical conditions is processed with the explicit consent of the resident to carry out Hightown’s responsibilities as a landlord.
    Where Hightown processes other special categories of personal data, such as information about ethnic origin, sexual orientation, religion or belief, this is done for the purposes of equal opportunities monitoring. Data that Hightown uses for these purposes is anonymised or is collected with the explicit consent of residents, which can be withdrawn at any time. Residents are entirely free to decide whether or not to provide such data and there are no consequences of withholding this information. If you wish to withdraw your consent contact the email below.

  • Other websites

    Our websites contain 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 on 25/05/2018. Hightown’s full Data Protection & Privacy Policy can be viewed on the Hightown website.

  • Lawful basis for processing data

    Often our lawful basis for processing your information is where it is necessary for the purposes of the legitimate interests Hightown has to process that information. Where Hightown relies on legitimate interests as a reason for processing data it has considered whether or not those interests are overridden by the rights and freedoms of residents and has concluded that they are not.
    The lawful basis may in some instances be because we have your consent to process your personal information. Where this applies this will be made clear to you and you can withdraw your consent at any time.
    We may also process your information for other reasons, such as where we are under a legal or contractual obligation to process or disclose the information; or where we need to protect your vital interests or those of another person.

    Some personal information is treated as more sensitive (for example medical or diversity information). The legal basis for processing these special categories of personal information is more limited. To lawfully process special categories of personal data, we must identify a specific lawful basis for the processing, which may be because we have your consent; we need to protect the vital interests (health and safety) of you or another person; you have already made your personal information public; we or another person needs to bring or defend legal claims; there are substantial public interest grounds.

  • 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@hightowhha.org.uk or call 01442 292300.

    Our Data Protection Officer is:

    Mark Carter 
    Director of Business Transformation
    mark.carter@hightownha.org.uk