Privacy and data protection statement
This notice applies to information processed by Notting Hill Genesis about housing applicants, residents, tenants, leaseholders and any other customers.
It explains why we may use your personal data and the legal basis (our lawful justification) for using it. It also explains the choices you have about the data we hold about you.
This notice applies to personal data held by Notting Hill Genesis as well as its registered subsidiaries, whether that information is collected via our website or through any other contact.
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
This notice informs about the following:
- Who we are
- How we collect your information
- How we use your information and our justification “the legal basis” for processing
- Sharing your personal information
- Experian and The Rental Exchange Programme
- Commercial tenants
- Recording telephone calls
- Keeping your personal information
- Transfers outside the UK
- Your rights under the Data Protection and UK GDPR
We’re Notting Hill Genesis, a data controller, one of the UK's leading providers of housing, care and commercial services. Our registered address is:
Bruce Kenrick House,
2 Killick Street,
If you would like to find out more about how we use your personal information, you can contact the Data Protection Officer at email@example.com
We collect most of our information directly from you, including when you apply for one of our properties or services, complete one of our forms, when you write, email or meet with us, or respond to a survey. We may also process information that you post on social media about us if it relates to a situation that we need to be aware of and/or take action on.
We also collect information from other third parties, but only where is it relevant to our relationship with you. For example:
- Organisations that we have contract with to provide services on our behalf (our data processors), for example, maintenance and repairs, customer surveys etc
- Local authorities (councils), health and social care professionals, previous care providers – for information about your health, care and support needs, and those of your household (including your children)
- Central government departments such as Her Majesty's Revenue and Customs (HMRC)- for taxation and/or fraud prevention, Home Office, local authorities – for information about your immigration status, or the Department of Work and Pensions (DWP) – for information about your benefits.
- Former landlords for your rental history and references e.g. rent arrears, evictions etc.
- Credit reference agencies – for credit checks and information about your financial status/history when you apply for any Notting Hill Genesis property, for debt recovery purposes, and fraud investigations/data matching checks. For commercial tenants, we may carry out ongoing risk assessments on commercial viability using credit reference data
- Police forces and other public bodies such as fraud departments, enforcement authorities – e.g. crime prevention, fraud prevention etc.
- Other residents – if we receive information in relation to complaints about behaviour- e.g. noise nuisance, anti-social behaviour (ASB), safeguarding concerns etc.
- Relevant utility providers – where your heat/energy bills are included in your rent/service charge, we receive information about your energy usage
- Managing agents – where they manage properties on our behalf
To assess your property application and manage our contract with you
We use the information we hold about you to manage your tenancy or leasehold. We need this to deliver our services to you. We collect most of this information because it is necessary in the performance of a contract. You will not be able to opt-out of providing this type of information.
We also process some of your information because it is in our legitimate interests to do so. You can object to this processing if you think that your legitimate interests outweigh ours.
We rely on legitimate interest to process your personal data to ensure that:
- We meet the needs of our customers when delivering our services to our residents.
- We can contact residents in the event of emergencies and to carry out essential repairs.
- We communicate with residents to meet our business objectives, encourage social inclusion and help build communities.
- We work with authorities and the police to support safer communities.
- We remain commercially viable and protect our commercial and social assets.
- We have effective procedures for preventing, and managing, outstanding debt for example from unpaid rents, service charges etc.
- We make the most efficient use of our resources and we understand how we are performing.
- We understand our residents’ experiences and views so that we can effectively influence and contribute to debates on future housing strategies.
To provide care and support services
As a provider of care and support services, we process data about your health and social care to deliver our services and to safely meet your assessed needs. We also process this information because it is necessary for the performance of a contract, to fulfil our legal regulatory obligations and because it is in our legitimate interests to do so.
Where we are providing care and support services as part of a local authority contract, we may share your information with the commissioning local authority or NHS trust or other partner organisations that we are working with to deliver the service.
To provide appropriate properties and services
We process information that relates to your health and social care, to help us make any reasonable changes to our properties and services, to make them fit for purpose and accessible for everyone. We also use this type of information to make sure we are protecting vulnerable individuals in our communities.
We do this to meet our legal and regulatory obligations, for example, the Equality Act 2010, and because there is a substantial public interest for us to do so.
To promote community safety and a peaceful community environment, and to safeguard individuals
We process personal data to promote a peaceful and safe community environment; this can include information about anti-social behaviour, criminal activity/convictions. We process this information to prevent/detect unlawful acts, because it is necessary for the performance of a task carried out in the public interest, and/or for reasons of substantial public interest.
We process information about safeguarding individuals, to fulfil our legal obligations and because there is a substantial public interest for us to do so.
To contact you about your property and other services
We use your contact details (including telephone numbers and email addresses) to get in touch with you about issues relating to your tenancy or leasehold and to deal with any legal matters arising from it. This includes repairs and maintenance, rent collection, complaints and housing management issues, in the event of an emergency, or to enforce the terms of your tenancy or lease.
We may pass on your details to contractors that provide services on our behalf, so that they can contact you to carry out essential services related to your property. We do this because it is necessary for the performance of a contract. It is not possible to opt-out of this type of data processing. Where we do not have the appropriate contact details for you, we may also try and source these externally from other third parties or public sources of information.
We’re constantly working to improve our services. One of the ways we do this is by listening to our residents and asking for feedback via surveys. These surveys are carried out by contractors who are specialists in customer feedback. In such cases, we pass on your contact details to them so you that they can contact you and ask about our performance. It is in our legitimate interests to use your contact details this way, however, you may opt-out of further contact by letting the person requesting feedback know that you do not wish to take part in future.
We may also use your information and contact you about the service charge apportionment that a property will pay in respect of service charge costs. This is generally as a percentage of the total costs for a block or development that an individual property is liable to contribute towards. This is calculated either as a fixed percentage as outlined in the lease agreement or as a fair and reasonable apportionment as set out in the lease.
To demonstrate proportionality, transparency and reasonableness in how we are recovering service charge costs, may share your property address in the service charge statement with other relevant leaseholders. The lawful basis for this is that there is a legitimate interest in making this information available
We also use your contact details to keep you updated about our events or other services which do not form part of our contractual landlord service, but which may be of interest to you. This includes our e-newsletter and letting you know about things such as accessing training opportunities, energy efficiency, digital support, housing options events and financial advice. It is in our legitimate interests to use your contact details this way, however, you may opt-out of further contact by simply selecting the opt-out button in the email or text.
To monitor equality, diversity and inclusion
We may ask you to provide us with your diversity data (ethnicity, religion, disability, sexual orientation). This information is not used to inform any decisions we make about you individually, but is gathered for statistical purposes to help us understand who is living in our communities. It helps us to ensure fairness and equality in the services we provide and allows us to fulfil our legal and regulatory obligations. You do not have to provide this information but it helps us if you choose to do so.
To prevent and detect fraud and illegal subletting
We process some personal data to guard against fraud and illegal subletting, for example, proof of identity, data matching. Failure to provide any information we require in relation to this could put your application or tenancy at risk.
We process this type of information to fulfil our legal obligations and to prevent and detect unlawful acts. In most instances, you are unable to object to this type of processing.
For profiling purposes
We use some of your personal data to create a profile of you so that we can identify relevant services that might be of interest or helpful to you. For example, if information suggests that you might be having some difficulties with managing your finances, or we think you might encounter difficulties in the future, we can direct you to our welfare benefits and money advice team. Alternatively, if our information suggests that you might be a vulnerable tenant because of age, or ill health, we may offer you an enhanced service.
We sometimes use profiling information to contact you about our community programmes that we think you might be interested in. These are provided by NHG Community Foundation which is part of the Notting Hill Genesis Group.
We rely on our legitimate interests to process information for these purposes.
We do not use automated profiling or automated decision making to make any decisions on your application, tenancy or leasehold.
To support research and analysis
We may use your personal data to carry out internal research and analysis. We do this to develop and improve our services and to help us understand trends within the housing sector. We process information based on our legitimate interests for these purposes.
Where needed, we share information with our subsidiaries, to make sure that you receive all the services available to you. This is done on our legitimate interests.
Data processors (our suppliers, contractors)
We also share some information with our data processors, which are organisations that carry out a service on our behalf. This includes repairs and maintenance, managing agents, gas servicing, credit reference agencies, heat meter providers etc. We only share the information which is necessary for them to carry out the service they have been contracted to provide. All our contractors operate under the terms and conditions of a legally enforceable contract and will not use your information for anything other than carrying out a service on our behalf.
In most instances, we do this because it is necessary for the performance of a contract, i.e., your tenancy or leasehold agreement. Where that does not apply, we process this information based on our legitimate interests.
Where managing agents are acting on our behalf we may share any information with them that is necessary for the effective management of the buildings, including any health and safety issues. Where other landlords (or managing agents acting on their behalf) are involved in the joint management of properties, we may also share the same information.
We do this because it is necessary for the performance of a contract or in order to fulfil our legal obligations. Where this does not apply, we do this on the basis of our legitimate interests.
Department for Levelling Up, Housing and Communities (DLUHC)
We share information about social housing lettings data with the DLUHC. It is a regulatory requirement for all registered providers to supply this data as per the Tenancy Standard. The Tenancy Standard is a non-statutory code of guidance which we are obliged to follow.
The data sets we share include information on lettings, type of tenancy, rents and charges, demographic information about tenants (including special category data and criminal convictions) and financial information. The data set does not include names or addresses but does include the unique property reference and the full postcode.
This information is used for research and statistical purposes to allow the DLUHC to exercise their role in providing adequate social housing. The information cannot be used for any other purposes, such as making decisions in relation to specific individuals.
We share this information because it is necessary for the performance of a task carried out in the public interest and/or for reasons of substantial public interest. Individuals are not able to opt-out of this processing.
DLUHC have their own Privacy Notice where you can find more information about the process and who to contact if you have any concerns.
Other organisations we may share your information with include:
- Local councils and government departments (including the Department of Levelling Up, Housing and Communities)
- Health and care services
- Police and other law enforcement agencies
- Electricity, water and gas companies
- Regulator of Social Housing
- MPs and councillors acting on your behalf
We share some of your personal data with Experian, a consumer credit reporting agency. This is to help us prevent and detect fraud and illegal subletting and to manage our rental arrears. We also receive information about you from Experian for the same purposes. We process this information to fulfil our legal obligations and to prevent and detect unlawful acts.
As part of the Rental Exchange Programme, we share your rental payment history with Experian. This programme allows tenants with a history of little or no credit, who are paying their rent on a regular basis, to build up a credit score. You can opt-out of the Rental Exchange Programme at any time by contacting us. Please see the “contact us” section of our website for details of how to get in touch with the relevant contact centre and we’ll opt you out.
We exchange information as part of the Rental Exchange Programme because it is in our legitimate interests to do so.
If you would like more information you can visit www.experian.co.uk/rental-exchange or call Experian on 0115 941 0888 and ask for a copy of the Rental Exchange brochure.
We collect very limited personal data about our commercial tenants, as most of the information we collect is about your business. However, some personal data is collected about individual sole traders and individual shareholders and/or directors of companies.
We collect most of our information directly from you when you apply, either directly to us or through our managing agent, to rent/lease a property for commercial business. We may also collect information about you, your shareholders and/or directors from public sources using credit reference agencies. Information collected from credit references may also be used to carry out ongoing risk assessments on the commercial viability of commercial premises.
We use the information we hold about you, your shareholders and/or directors to manage your tenancy or leasehold. We need this to deliver our services to you. We collect most of this information because it is necessary in the performance of a contract. You will not be able to opt-out of providing this type of information.
We also process some of your data because it is in our legitimate interests to do so. You can object to this processing if you think that your legitimate interests outweigh ours.
We do not usually collect information directly from children as part of our core landlord service. We may process information relating to children in our households where it has been provided to us during our relationship with you. In such cases, we process that information based on our legitimate interests and to fulfil our legal and regulatory obligations.
We may record your telephone calls to our customer service centre, for training and monitoring purposes and to make sure we’re delivering a good service. We process data in this way because it is in our legitimate interests to do so.
CCTV footages and image captures
We use CCTV cameras to manage the safety and security of staff and visitors to all corporate buildings and properties that we manage. Cameras are clearly marked with privacy notices explaining that cameras are in use. Images may be captured via CCTV for the purposes of security.
We may also capture and process images during events organised and hosted by us using film photography, digital photography, video or other medium and may be used on our websites, in brochures or other publicity material (such as internal and external newsletters) and may be provided to the media for publication in local or national news publications. We will tell you when we are undertaking recording of this nature.
We inform all those whose images may be recorded (or their parents/guardians if under 13 years of age) of the purposes for which the images may be used by us. We inform all persons taking part in our activities that they may be photographed, filmed, videoed or otherwise captured in image form.
How long we keep your personal data for can depend on the type of data it is. We have set retention periods for different categories of data. We keep information on our tenancy files for up to six years after the tenancy ends. We hold CCTV footage for 30 days. We hold recordings of telephone conversations to our customer service centre for no longer than six months.
Occasionally, we may need to transfer your personal data outside the European Economic Area (EEA) to other subcontractors or agents. For example, if we were to use an IT service whose servers are situated outside of the EEA. Where this is the case, we will take the appropriate steps to ensure that we only contract with organisations that have the appropriate security measures in place.
We won’t disclose the information you give us to anyone else unless:
- It is necessary to do so to comply with any of our legal obligations.
- Where there is a substantial public interest to do so (including where it is necessary for reasons of public health). For example, we may have to approach Public Health England or another relevant statutory body.
- Where we are working with partners to deliver services, e.g. food/medication deliveries, befriending services etc, and you have requested such support.
Our lawful conditions for processing this information are:
- Where we have a legal obligation to ensure the health and safety of our employees/contractors, and the wider community.
- Substantial public interest (including for reasons of public health) and
- Legitimate interests.
You have several rights which allow you to choose and control how we use your data. These rights are explained below. If you would like to exercise these rights, please see the Contact us section of our website for details of how to get in touch with the relevant contact centre.
Transparency: You have the right to be informed about how we are using your data. If you think we are doing something with your information that we have not told you about in this privacy notice, you can object to this.
Access: You have the right to ask us what personal information we hold about you, and to request a copy, free of charge. Please note if we consider that the request is manifestly unfounded, excessive, or repetitive, we can charge a reasonable fee. This fee will be based on the administrative cost of providing the information.
Objection: You can object to the processing of your personal data. You should note that this right does not apply in all circumstances, for example, where we are processing information because it is necessary in the performance of contract, we will not be able to stop processing this information.
Withdrawal of consent: if we are processing your data based on your consent, you can withdraw this consent at any time. Where this is the case, we may no longer be able to provide the relevant service to you.
Rectification: If you think that the personal data we hold about you is inaccurate or incomplete, you have a right to request that it be rectified.
Erasure: You can ask us to delete your personal data where it is no longer necessary for us to use it, where you have withdrawn consent (if we process based on consent), or where we have no lawful basis for keeping it.
Restriction: You can ask us to restrict the personal data we use about you where you have asked for it to be erased or where you have objected to our use of it.
Data portability: You can ask us to provide you, or a third party (if possible), with some of the personal data we hold about you in a structured, commonly used, electronic form so that it can be easily transferred.
Providing accurate information
It is important that we hold accurate and up to date information about you in order to assess your needs and deliver the appropriate services. If any of your details have changed, or change in the future, please ensure that you inform us as soon as possible so that we can update your records.
Data Protection Officer (DPO)
Our Data Protection Officer (DPO) is responsible for overseeing the compliance with this privacy notice. If you wish to contact us regarding your personal data and any other concerns you may have regarding its processing you can do so by contacting us on firstname.lastname@example.org
If you are unhappy with how we process your personal data, or if you feel we have acted in a way that has breached your data protection rights you have the right to complain to the information commissioner’s office on the contact details below:
The Information Commissioner’s Office,
Wycliffe House, Water Lane,
Tel: 01625 545745
Or you can visit their website at www.ico.org.uk