Privacy Notice

Platform Housing Group’s Privacy Notice

The Platform Housing Group includes Platform Housing Group Limited, Platform Housing Limited (formerly Waterloo Housing Group Limited and Fortis Living Limited), Platform Property Care, ESHA (Developments) Limited, and Waterloo Homes Limited.

This privacy notice applies to customers of Platform Housing Group including tenants, leaseholders, shared owners, and applicants for housing. It lets you know what happens to any personal data that you share with us, or any data that we may collect from or about you. It applies to all products and services and instances where we collect your personal data.

Changes to this privacy notice

We may change this privacy notice from time to time by updating the Privacy Notice page on our website in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website – www.platformhg.com or log in to your online account.

Platform Housing Group and our Data Protection Officer

Our contact address is Platform Housing Group, Progress House, Midland Road, Worcester, WR5 1DU.

We are a data controller of your personal data. We are registered with the Information Commissioner’s Office for the processing of personal data. To see the details of our registration visit www.ico.org.uk.

We have a dedicated Data Protection Officer (DPO). You can contact the DPO by emailing dpo@platformhg.com or by writing to the above address, marking it for the attention of the Data Protection Officer.

1. What personal information we process

Personal information that we will process in connection with providing you with a landlord service or appropriate advice and support includes:

Personal details, such as title, full name, contact details, photographic ID
Your date of birth, gender and/or age
Details of joint tenants, leaseholders or applicants
Family and household members, so we know who is living in the property, and can adapt any services to meet their needs
Records of your contact with us such as through our telephone call centre and online forms
CCTV images if you visit a property, office or communal facility covered by a CCTV system
Property addresses and occupation dates you have rented, leased or bought, currently or in the past with Platform Housing Group or its predecessor organisations
Information associated with managing your tenancy, lease or application including bank details; payments, visits, contacts, letters, interviews or legal enforcement actions
Marketing messages about our homes and services to you and analyses of that data.
Information we obtain from third parties, if relevant, see section 5 below for more details
Fraud, debt and theft information, if relevant, including details of money you owe, suspected instances of fraud or theft, and details of any devices used for fraud
Reasons for the risk of possible homelessness, if relevant
Information relating to your Voluntary Right to Buy Pilot application, if relevant
Criminal records information, if relevant, to manage, risk assess, and adapt services due to any known criminal or anti-social behaviour activity
Information about your health or if you are a vulnerable customer, if relevant
Information about your property, if relevant, such as location, value, number of rooms, property type, permissions given and building work you’ve had done
Financial details about you, if relevant, such as your household income, source of income, details of your savings, borrowings and loans, and details of other expenditure
Information about your employment status, if relevant
Your National Insurance number
Information about your property occupier status, such as whether you are a tenant, live with parents or are an owner occupier of the property where you live at the time of your application
Your nationality, if relevant
Information about your marital status, family, lifestyle or social circumstances, including religion, ethnic origin, sexuality to monitor that our service provision is not discriminatory and reflects the diversity of our local communities
Insights about you and our customers gained from analysis or profiling of customers
Where relevant, information about any guarantor which you provide in any application
Third party transactions; such as where a person other than the account holder makes a payment, contacts us or acts on your behalf
Records of your internet browsing activity if you access Platform Housing Group’s Public Wi-Fi services including site names, category and device names and IP addresses.
Records of your webchat including email address, user name, Chat transcripts, completed surveys, anonymised Operating System/Browser information - which is only for the purposes of product development and cannot be tied back to a specific session or user.

2. How we obtain your personal information

We’ll collect personal information from the following sources (this list is not exhaustive):

From you directly, and any information from family members, associates or guarantors
Information generated about you when you use our homes and services including our public Wi-Fi services
From a 3^rd Party organisation such as other Registered Social Landlords, local authorities, utility companies, social services, NHS, Police, Fire and Rescue Services.
Business partners (for example, property maintenance contractors) or others who are a part of providing your homes and services or operating our business
From other sources such as fraud prevention agencies, credit reference agencies, other lenders, HMRC, DWP, publically available directories and information (for example, telephone directory, social media, internet, news articles), debt recovery and/or tracing agents and other organisations, police and law enforcement agencies.

3. How we use your personal information

We use your personal information for the following purposes:

Assessing an application for a tenancy, lease or service, including considering whether or not to offer you the tenancy, lease or service
Managing the tenancy, lease, application or service request you have with us
To comply with our legal obligations
To comply with our obligations in relation to the Voluntary Right to Buy Pilot
Updating your records, tracing your whereabouts and recovering debt
To monitor and to keep records of our communications with you and our staff
To develop and/or test the performance of our homes, services and internal processes
To improve the operation of our services and that of our business partners
To comply with, and follow guidance and best practice under any change to rules and requirements by governmental and regulatory bodies
For management and auditing of our business operations
To carry out checks at fraud prevention agencies where relevant
For market research and analysis and developing statistics
Assessing and profiling aspects of your home’s performance such as energy efficiency and condensation
For direct marketing communications and related profiling to help us to tell you about relevant services and events
To keep you informed of company news, community events, health and fitness events, safety messages, universal credit reform and other Government led policy changes
To provide personalised services to you, such as tailoring our homes and services and our digital offerings
Sharing your personal information with business partners and services providers when you hold a lease or tenancy to help provide landlord services
Sharing your personal information with third parties to help provide support services
To facilitate the sale, merger or take-over of one or more parts of our group of companies.

4. The legal grounds for processing your personal information (including when we share it with others)?

We rely on the following legal basis to use your personal information:

Where it is needed for Performance of a Contract. This is either your tenancy or lease or purchase of a property
Where it is in our legitimate interests to do so, such as:
Managing your tenancy, lease or service request, updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate)
To perform and/or test the performance of, our products, services and internal processes
To follow guidance and recommended best practice of Government and regulatory bodies
For management and audit of our business operations
To comply with our Commitment to Refer (Duty to Refer under the Homelessness Reduction Act 2017)
To carry out checks at fraud prevention agencies where relevant
To carry out monitoring and to keep records of our communications with you and our staff
For market research and analysis and developing statistics
Assessing and profiling aspects of your home’s performance such as energy efficiency and condensation
For direct communications to help us to tell you about relevant services and events
To inform utility and council tax companies of occupants, occupancy dates, forwarding address, and meter readings to ensure accurate billing can take place
Where we need to share your personal information with people or organisations in order to run our business or comply with any legal, contractual and/or regulatory obligations
Where we contact you through automated text, email or other electronic messaging to remind you of appointments, payments due or to take part in customer satisfaction surveys
To comply with our legal obligations
With your consent or specific consent:
For direct marketing communications
For some of our profiling and other automated decision making
For processing of special categories of personal data such as about your health, if you are a vulnerable customer or some criminal records information
For some of our statutory and regulatory returns
For a public interest, such as:
- Processing of your special categories of personal data such as about your health, criminal records information (including alleged offences), or if you are a vulnerable customer
For your vital interests where you may be physically or legally incapable, such as:
- Providing personal details, health and vulnerabilities in the event of a medical emergency where you are unable to provide those details yourself.

5. 3^rd Parties and organisations we share information with

As stated in section 2 and 3 above we may source or share personal information with 3^rd parties.

Below, is a list of the types of organisations with whom some data sharing occurs where it is relevant to do so and for the reasons stated. Please note, your personal information will only be shared with an organisation where it is relevant to you.

Organisations we may share data with
Third party sharing
Type of Organisation	Reason for Sharing Data	Legal Basis for Processing Data
Asbestos Survey Provider	Asbestos Surveys	Performance of Contract, Legitimate Interest, Legal Obligation
Choice Based Lettings scheme Provider	Allocation of properties within Platform Housing Group / Local Authority Lettings Policy	Statutory & Legal obligations, Legitimate Interest
County Courts	Application for Money Order or Judgement, Application for Court Order, Undertaking or Injunction	Performance of Contract, Legitimate Interest, Legal Obligation
Data Protection Regulator	In response to Queries and complaints from Customers and Members of Public	Legitimate interest, Legal obligation
Direct Debit Service Provider	Provision of Direct Debit Service	Performance of Contract, Statutory & Legal obligations, Legitimate Interest
Energy Utility Companies	Correct Billing Dates / Prevention & Detection of Fraud	Statutory & Legal obligations, Legitimate Interest
Fire & Rescue Services	Identification of properties with Oxygen bottles / Hoarding Issues	Public Interest, Vital Interests, Legitimate Interest
Governmental Departments	CORE Letting & Sales data, HMRC, Research (Right to Buy or Right to Acquire and Voluntary Right to Buy), Voluntary Right to Buy Pilot	Statutory & Legal Obligations, Specific consent, Performance of Contract
Health Authority inc. GP surgeries	Provision and monitoring of a Falls response service, Occupational Therapy Assessments	Performance of Contract, Legitimate Interest
Housing Ombudsman	Response to complaint made to the Housing Ombudsman	Legitimate interest, Legal obligation
Inland Revenue	Collection of Tax , Prevention and detection of fraud	Statutory & Legal Obligations
Local Authorities	Council Tax Assessment, Housing Benefit Assessment, Homelessness Investigations, Environmental & Other Statutory Nuisance Investigations, Private Sector Aids & Adaptations, Commitment to Refer (Duty to Refer under the Homelessness Reduction Act 2017)	Statutory & Legal obligations, Specific Consent, Legitimate Interest
Maintenance Contractors	Provision of Property Improvement Works	Performance of Contract, Legitimate Interest
Online Fraud Prevention Service Provider	Prevention & detection of Tenancy Fraud	Legitimate Interest
Online Marketing Service Providers	Marketing of Platform Housing Group Homes & Services	Specific Consent
Out of Hours/Call Alarm Contact Service Provider	Provision of Call Alarm Monitoring/Out of Hours Repairs & Emergency Contact Service	Performance of Contract, Legitimate Interest, Vital Interests of Data Subject
Payment Service Providers	Receipt and detail of Payments made	Performance of Contract, Legitimate Interest
Police Forces	Prevention & detection of Crime / Management of Tenancy Breaches	Public Interest, Vital Interest, Legal obligation, Legitimate Interest
Registered Social Landlords	Lettings, Transfers and Mutual Exchanges	Performance of Contract, Legitimate Interest
Support Service Providers	Provision of identified and agreed support requirements	Legitimate Interest, Vital Interest, Performance of Contract, Specific Consent
Water Utility Companies	Correct Billing Dates / Prevention & Detection of Fraud, Legal obligation on landlords (Welsh Water customers)	Statutory & Legal obligations, Legitimate Interest
Web Service Provider	Provision of Online Tenancy Account	Performance Of Contract

We use a number of data processors who act on our behalf to process personal data.

All these organisations are subject to the same legal rules and conditions for keeping personal confidential data secure. We ensure that our partner agencies have contracts / information sharing agreements which outline that your information is processed under strict conditions and in line with the law. Platform Housing Group Limited remains the data controller (the organisation responsible for determining the purposes for which and the manner in which personal data is used under the Data Protection Act and General Data Protection Regulation) of such information at all times.

6. How and when you can withdraw consent

When we are relying upon your consent as stated in Section 4 to process personal information, you can withdraw this by contacting us using the details at the bottom of this page (unless there is a legal basis for processing). Examples of where you may withdraw your consent are:

For direct marketing communications
For some processing of special categories of personal data such as your ethnicity, religion, sexuality, health, if you are a vulnerable customer or some criminal records information
For some of our statutory and regulatory returns
Where we contact you through automated text, email or other electronic messaging to remind you of appointments.

7. How your personal information is kept secure

We have put in place appropriate operational, technical and security measures to reduce the risk of your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This includes use of encryption where relevant. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We and our business partners are based in the UK but sometimes your personal information may be transferred outside the European Economic Area. If we do so, we’ll make sure that any transfers will be done securely and only after assessing the adequacy of local data protection laws and regulations.

8. What to do if you need to make changes to your personal information

You should tell us so that we can update our records using the details in the Contact Us section of our website, by calling our Contact Centre on 0333 200 7304 or by logging on to your Online Account, where relevant. We’ll then update your records where appropriate.

9. Providing your personal information to us

We’re unable to provide you with a tenancy, lease or landlord service if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.

10. How we monitor and process your personal information

In this section monitoring means any; listening to, recording of, viewing of, intercepting of, or taking and keeping records of calls, email, text messages, social media messages, CCTV, in person (face to face) meetings and other communications.

We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.

11. Automated decision making

Currently, no decisions are made about you using only technology, where none of our employees or any other individuals have been involved.

12. How long we retain your personal information

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
Retention periods in line with legal and regulatory requirements or guidance as detailed in Platform Housing Group’s Data Retention Policy

13. Your rights under data protection laws

These rights don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are applicable or not.

The right to be informed about the processing of your personal information
The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
The right to object to processing of your personal information
The right to restrict processing of your personal information
The right to have your personal information erased (the “right to be forgotten”)
The right to request access to your personal information and to obtain information about how we process it
The right to move, copy or transfer your personal information (“data portability”)
Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you

You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/ You can also contact us using the details below.

14. Your right to request access to your personal information

The current Data Protection law provides individuals with rights over how their personal data is processed. These rights entitle you to a copy of your information; confirmation that your data is being processed; confirmation on how and why your data is processed; the purposes for which it is used; and to whom your data may be disclosed.

Further information can be obtained by emailing dpo@platformhg.com or contacting us using the details below.

15. Opting out of Marketing

You can opt out of any email or text marketing by following the unsubscribe links. If you receive a marketing call from us, you can ask the person who called you to opt you out. You can also write to us at: Platform Housing Group, Progress House, Midland Road, Worcester, WR5 1DU, marking it for the attention of the DPO.

16. Our website

Cookies

Cookies are small text files which, with your permission, are placed on your computer's hard drive by websites that you visit. They are widely used to help websites work more efficiently, to analyse web traffic and to gather information about your preferences.

We use traffic log cookies to identify which pages of our website are being used. This helps us improve our website and tailor it to our visitors’ needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Cookies do not enable us to identify you personally and do not give us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from using all the functions of the website.

Links to other websites

Our website contains links to other third-party websites of interest. When you use these links to leave our site, please be aware that we do not have any control over these external websites. We cannot be responsible for the protection and privacy of any information which you provide whilst visiting these sites and they are not governed by this privacy statement. You should be careful about the information you provide and look at the privacy statement applicable to the individual website.

Google Analytics

Our website uses Google Analytics to analyse the traffic on our website. For more information on Google's services please go to www.google.com/analytics

17. Contacting Us

If you have any questions about this privacy notice, or if you wish to exercise your rights you can contact the DPO, by emailing dpo@platformhg.com

Our contact address is Platform Housing Group, Progress House, Midland Road, Worcester, WR5 1DU, marking it for the attention of the DPO.

Privacy Notice

Platform Housing Group’s Privacy Notice

The Platform Housing Group includes Platform Housing Group Limited, Platform Housing Limited (formerly Waterloo Housing Group Limited and Fortis Living Limited), Platform Property Care, ESHA (Developments) Limited, and Waterloo Homes Limited.

We are Platform Housing Group

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