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Privacy Policy
HOUSING SYSYEMS DATA PRIVACY POLICY

Introduction
Our Privacy Policy is explained in detail below, but the main points to note are:

·         We will only ever ask for what we really need to know

·         We will collect and use the personal date shared with us transparently, honestly and fairly

·         We will always respect an individual’s choices around the data that they share with us and the communications channels that they ask us to use

·         We have security measures in place to protect the personal data we hold and these are regularly reviewed

·         In general, unless still required in order to fulfil a contract, personal data will be removed from our records 5 years after the date it was collected

·         We never sell personal data.

At Housing Systems we are committed to protecting personal data and being transparent about what data we hold. We have developed the following policy to help you understand how personal data will be treated as you engage with us both online and off. It’s important that organisations and individuals know how we record personal data when you do things like visit our website or use our other services so that they know they can trust us with that information.

We ensure that we use personal data in accordance with all applicable laws concerning the protection of that information. Maintaining personal data in a secure manner is important to us. This privacy policy explains all you need to know about:

·         What personal data we may collect

·         Why we collect it

·         What we do with it

·         When we may share it with others

·         How that data can be accessed and updated by the individual.

By taking out a subscription, requesting a trial, arranging or attending a training course or using any of our services, you accept this privacy policy and authorise Housing Systems to collect, store and process personal data in the ways explained.

If you have any questions about this privacy policy or would like more information on our legal basis for processing personal data please contact us using the details at the end of this statement.

Who we are

Housing Systems is a limited company registered in England and Wales (registration number 3028972). Our registered office is at 54 Holme Grove, Burley in Wharfedale, Ilkley, West Yorkshire. BD23 3AQ.


Where we collect personal data from

We collect personal data in the following ways:

When we are given it DIRECTLY

We collect personal data for many reasons, including to provide individuals with the services they are entitled to in line with the contract their employer has with us, to enable us to communicate with them about our services and to send them information that they have requested. 
Depending on what that interaction with us is, we may process personal data when:

·         An individual requests a service from us - such as requesting a free trial

·         An organisation becomes a subscriber

·         An organisation buys our publications or requests a training course, or

·         An individual applies for a job or acts as a freelancer for us.

This data may be collected via any paper forms completed, telephone conversations, emails, face-to-face interactions, digital forms completed via our website, or communication via social media.

When we are given it INDIRECTLY

Personal data may be shared with us by third parties for example where an individual attends a training course or workshop arranged by that third party. The Privacy Policy of this third party organisation should be checked to understand fully how they will also process personal data.

We may also access information available publicly, such as via Companies House or information that has been printed in newspapers, magazines etc.

When we collect it as individuals use our WEBSITE

Like most websites, we use cookies to help us make our website better. Cookies mean that a website will remember a user. They’re small text files that websites transfer to a computer, phone or tablet. They make visits to websites faster and easier, for example by automatically filling a name and address in the text fields.

We use cookies, like most websites, to help us provide users with the best experience when they visit our site. Some cookies are essential to the smooth running of our website, for example our pages recording user frequency replies on this.  Other cookies allow us to understand how visitors are interacting with our website, so that we can improve it.

All browsers allow you to control which cookies you accept and which you delete. For more information about cookies, please see http://www.allaboutcookies.org/.

Please note, no personal data is held on our website.


What types of data do we collect?

Non-personal data

This type of data does not identify an individual, but it does help us to improve our services. When a user visits and looks around our website, we record things like IP (internet protocol), which pages are visited, when they were visited, and the browser being used. This information helps us create a better experience for everyone who uses our website.

Personal data

This means any information that may be used to identify an individual, such as a name, telephone number, postal and email addresses and includes:

·         Full name

·         Contact details including work postal address, work telephone number(s) and work email address

·         Records of correspondence and engagement with us and the subscription an organisation holds or have held with us

·         Occupation or other biographical information

·         Other information shared with us.

We will only ask for personal date where it is appropriate, reasonable and relevant.

Children’s data

We do not knowingly process data of any person under the age of 16. If we come to discover, or have reason to believe, that an individual is under 16 and we are holding their personal data, we will delete that information.


How we use personal data

Subscribers

If an organisation signs up to become a subscriber to the Housing Systems website, we have a contractual obligation to provide them with the membership benefits they have signed up for. If they do not wish to receive these benefits, let can us know by getting in touch using the details in the ‘Contact us’ section below.

We use a range of methods to keep in contact with our subscribers and their staff - email, direct mail, and occasional telephone calls in order to fulfil the requirements of our contract – unless an individual has opted out.

An organisation’s employees are in control of how we contact them. If they want to stop receiving emails, they are able to click the ‘unsubscribe’ link at the bottom of any of our Newsletters. If they would like to make changes to the type of communications they get from us, or if their personal details change, we encourage them to get in touch using the details in the ‘Contact us’ section at the end of this statement.

Administrative communications to subscribers
We will also communicate with organisations by post, telephone, and email to deal with any administrative matters. Even if Companies or individuals opt out of communications from us, we may still need to communicate occasionally for administrative purposes. 

Newsletters and Briefings
If an individual lets us know that they are interested in our newsletters and briefings they will then receive communications relating to the newsletter/briefing. They can withdraw their consent, unsubscribe, or update their preferences at any point by using the contact details in the ‘Contact us’ section below. If they make any changes to their consent, we will update their records as soon as we possibly can. Email communications will be stopped immediately.  It may take up to 14 days to stop any postal communications from us being sent.

Email Query Service
If an organisation or a member of their staff emails our query service to seek help with their work, our staff may take notes on the information given to us and record it on our systems.  This data is used for quality assurance, complaint investigations and to collect the data needed to fulfil our obligations to our subscribers in terms of interactions with our services.

Please note that we will immediately delete any benefit query that is sent to us with personal data of any of an organisation’s customers.  We will also notify our Main Contact at the organisations of this as it constitutes a data breach.

We may use this data for statistical reports. These statistics will not include information that could be used to identify any individual.

Any personal data collected is held for 5 years in case of complaint investigations. An individual can ask for us to remove their data before then if they do not want us to hold it.

Representation
If an organisation or a member of their staff receives advice or representation from us, we will need to process their personal data because of their specific relationship with us. We use a customer relationship management system (Insightly) to support our work. This means that we can keep the information provided to see the history and relevant details of their interactions with us. This ensures that we can provide organisations with appropriate and accurate advice and representation. We take information security very seriously and no one is allowed to access our system or files unless they need this to provide the service to our member organisations or to regulate the quality of the service.

Any personal data collected is held for 5 years in case of complaint investigations. An individual can ask for us to remove their data before then if they do not want us to hold it.

Non-Subscribers

We use a range of methods to keep in contact with non-subscribers and their staff - email, direct mail, and occasional telephone calls or order to keep them up to date with information relating to the welfare reforms – unless an individual has opted out.

We will always gain an individual’s consent to contact them by email for marketing purposes. We will send marketing by post, on the basis of it being within our legitimate interests (see below section on ‘Our legal basis for processing your data’ for more information) to do so, unless an individual has opted out.

We send the following marketing email communications from time to time:

·         Updates about Housing Systems work, including newsletters, magazines, and other publications with useful information about welfare benefits and welfare reform;

·         Updates about what training is currently available and in what areas

·         Training materials, letters and flow charts

Non-subscribers who have opted in to receive these updates can choose how they hear form us, whether by post, phone, or email. We will never share or sell personal data to a third-party organisation for its campaigning or marketing purposes.

Non-subscribers can withdraw consent, unsubscribe, or update their marketing preferences at any point by using the contact details in the ‘Contact us’ section below. If they make any changes to their consent, we will update their record as soon as we possibly can. Marketing email communications will be stopped immediately if they unsubscribe. Updates to contact preferences sent by email may take up to one week to process. It may take up to 14 days to stop any postal communications from being sent.

Business services and professional contacts

We may collect data about the professional contacts and partners we work with, or who have used our services such as attending training courses or buying publications. Personal data collected in this way will be processed according to data protection law and this policy.

We may send our professional contacts information and updates about our work by email and by post if they have opted in to these services. They can opt out of receiving this information at any time. They can withdraw their consent, unsubscribe, or update their preferences at any point by using the contact details in the ‘Contact us’ section below. If they make any changes to their consent, we will update their record as soon as we possibly can. Email communications will be stopped immediately. It may take up to 14 days to stop any postal communications from being sent.

Job applicants and volunteers

When an individual applies for a job or contract training role, their personal data will be collected to monitor the progress of their application. Where we need to share their data, for example to gather references, they will be informed beforehand unless the disclosure is required by law. These checks are only done after a position has been offered to the successful candidate. Personal data about unsuccessful applicants is held for 12 months. An individual can ask for us to remove their data before then if they do not want us to hold it.

Our legal basis for processing personal data

We need a lawful basis to collect and use personal data under data protection law. The law allows for six ways to process personal data (and additional ways for sensitive personal data). Four of these are relevant to the types of processing that we carry out at Housing Systems. This includes information that is processed on the basis of:

·         A contractual relationship, for example, to provide the goods or services an organisation has purchased from us including a membership subscription

·         A person’s consent, for example, to send direct marketing by email

·         Processing that is necessary for compliance with a legal obligation, for example accounting data

·         Housing Systems legitimate interests: please see below for more information.

Personal data may be legally collected and used if it is necessary for a legitimate interest of the organisation using the data, if its use is fair and does not adversely impact the rights of the individual concerned. When we use personal data, we will always consider if it is fair and balanced to do so, and if it is within reasonable expectations. We will balance an individual’s rights and our legitimate interests to ensure that we use personal data in ways that are not unduly intrusive or unfair.

Our legitimate interests include:

·         Company governance: including delivery of our purposes, statutory and financial reporting and other regulatory compliance purposes

·         Administration and operational management: including responding to solicited enquiries, providing information and services, research, events management, administrating recruitment processes for staff and freelancers.

Anyone who requires more information on our uses of legitimate interests, or to change our use of personal data in this manner, should get in touch with us using the details in the ‘Contact us’ section below.

When we may disclose personal data

We will not share any personal data with any third party – except where:

·         The third-party is helping us provide a service to an organisation or a person working for that organisation*or

·         The transfer is to a secure data processor, which carries out data processing operations on our behalf, for example to process a mailing*or

·         It is necessary to protect the vital interests of an individual – i.e. to protect someone’s life, or

·         We have obtained the individual’s consent.

*These third parties have access to that personal data only to perform these specific tasks on our behalf and are obligated not to disclose or use it for any other purpose.

We will never share or sell personal data to a third-party organisation for any purpose.


How we keep personal data secure

We endeavour to ensure that there are appropriate and proportionate technical and organisational measures to prevent the loss, destruction, misuse, alteration, unauthorised disclosure or of access to personal data.

We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as: 

·         Ensuring the physical security of our office

·         Ensuring the physical and digital security of our equipment and devices by using appropriate password protection

·         Maintaining an internal data protection policy for, and delivering data protection training to, our employees

·         Limiting access to personal information to those in our company who need to use it in the course of their work, and

·         Using trusted third-party suppliers to provide services for data recording, processing and mailing.

Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect personal data, we cannot guarantee the security of the data sent to third parties e.g to process our Newsletters. Once we have received personal information, we will use strict procedures and security features to try to prevent unauthorised access.

The security of personal data is important to us but it must be remembered that no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect personal data we cannot guarantee its absolute security.

How we use data processors

We may use third parties for software, systems, platform support, print and mailing, cloud hosting services.  We may also use a third-party supplier to manage marketing or to conduct surveys on our behalf. We actively check these companies to ensure privacy and security is protected. These third-party suppliers are only permitted to use the data in accordance with data protection law, under instruction from us, and in accordance with a data processing agreement made between Housing Systems and the supplier.

Organisations can find out more about the suppliers we use by getting in touch with us using the details in the ‘Contact us’ section below.

Links to websites

Our website contains links to other websites. Our inclusion of such links does not imply that we endorse those websites. We do not control the content of those third party websites, and assume no responsibility for the third party or their polices or practices. We encourage users to review the privacy policies of these third party websites because their procedures for collecting, handling and processing personal data may be different from ours.

How long we keep personal data

Whatever the relationship with us, we will only store personal data for a limited amount of time.

The length of time we keep personal data may depend on the reasons we are processing it, on the law or regulations that the information falls under, such as financial regulations, Limitations Act, Health and Safety regulations, or on any contractual obligation we might have, such as with government contracts. For business case data, we will anonymise the data so no individual is identifiable.

In general, unless still required in order to fulfil a contract, personal data will be removed from our records 5 years after the date it was collected. After this period, we will confidentially dispose of and / or permanently delete personal data.

If an individual asks not to be contacted by us, we may keep some basic information about them on our suppression list to avoid sending unwanted materials in the future.

Rights to your personal data

An individual has a right to request a copy of the personal information we hold about them, and to have any inaccuracies corrected. They also have the right to request that we erase their personal information, restrict our processing of their personal information or to object to our processing of their personal information.

An individual who wishes to exercise these rights, may need to prove their identity with two pieces of approved identification. Requests used be submitted using the contact details below and we will respond within 28 days. An Individual should provide as much information as possible about the nature of their contact with us to help us locate their records, including all of the email addresses they have used when in contact with us.

Where an individual has provided their consent for us to use their personal information, they always have a right to withdraw their consent at any time.

How to find out more about personal data rights

The way we collect and use personal data on is in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act. For further information please visit the Information Commissioner’s Office at www.ico.org.uk. 

Ability to edit and delete account information preferences

An individual has a choice about whether or not they wish to receive information from us. If they do not want to receive any information or only certain types of information then they can update those choices at any time.

The accuracy the personal data we hold is important to us. This can be updated at any time. If someone would like to change their preferences or update the details we hold about them they can get in touch using the details in the ‘Contact us’ section below. If an individual would like changes to be made to their personal data, they should provide as much information as possible about the nature of their contact with us to help us locate their records, including all of the email addresses they have used when in contact with us.

Contact us

If you have any questions about this policy, would like more information, or want to exercise any of rights in relation to data protection, you can get in touch with us in the following ways:

        Email us at info@housingsystems.co.uk

        Telephone us on 01756 796394

        Write to us at Housing Systems Ltd, Tom Hill House, Gargrave Road, Broughton, Skipton, BD23   3AQ


Changes to this policy

This policy may change, but we will always have the latest version available for you on our website. If there are any major changes, we will add a notice on our website or contact you. This policy was last updated on 25th May 2018.

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