Privacy notice

Our purpose(s) for processing and lawful basis

The information you provide is used to evaluate your application for a tenancy with us.

The legal bases which apply to the processing described above are:

• Where we need to take measures to enter into and then perform a contract we have entered into with you (provision of services set out in a tenancy or leasehold agreement)
• Where we need to comply with legal obligations (e.g. housing regulations, health and safety, safeguarding, tenancy fraud investigation);
• Where we need to comply with social protection responsibilities (where we gather health data to make sure your home is appropriate for your needs)
• Where there is a public interest (to ensure there are no risks posed to our staff, customers, or contractors if you declare criminal convictions)

Please see equality and diversity for more information.

How we use your information

We will use your personal data to:

• verify that you are eligible for social or supported housing
• ensure that you meet our letting criteria
• assess your application and provide a suitable property or accommodation
• ensure your home meets your needs (including aids and adaptations)
• determine any assistance that you or other member of your household may require

Who we may share your information with

There may be instances where we are required to share your personal data in order to provide you with our services, or where we have an obligation to do so. We may share data with:

• other parts of Riverside to provide the services specified or any requirements identified in your application
• local authorities
• the Ministry of Housing, Communities and Local Government you can access the CORE Privacy Notice here (this does not apply to Riverside Scotland)
• identity verification providers, which may include credit reference agencies who provide this service. You can read their Privacy Notice here.
• the Department for Work and Pensions (DWP)
• providers of health or social care

How long we will keep it

• If your application is successful and you become a customer of Riverside, we will keep your application alongside your tenancy data for 6 years after your tenancy ends.
• If your application is unsuccessful, we will keep your application for 6 months.
• We may be required to retain a copy of the CORE letting form for as long as it is deemed necessary to support social housing policy under the MHCLG data sharing agreement.

Our purpose(s) for processing and lawful basis

In addition to promoting human rights, we aim to eliminate discrimination and actively promote equal opportunities in all that we do, including the services we provide and the decisions we make.

In accordance with equality legislation, we may ask you and members of your household for your ‘protected characteristics’, namely, age, disability, gender reassignment, marriage & civil partnership, pregnancy & maternity, race, religion & belief, sex & sexual orientation.

We ask for this information so we can give everyone an equal opportunity to access our services, but also in order to understand you and your particular needs better. You do not have to provide this information, but it helps us if you choose to do so.

The legal bases which apply to the processing described above are:

• Where we have your consent
• Where we need to comply with legal obligations (such as the Disability or Equality Acts)
• Where the processing is necessary in the public interest, including the monitoring of diversity and equality where we work with local authorities and monitoring equality of opportunity or treatment (where the data isn’t used to make decisions on particular individuals)

How we use your information

You have the option to provide this information when you apply for a property. If you choose not to do so at this stage, you can choose to provide this information at any point once you are a customer of Riverside through ‘My Riverside’ or by contacting Customer Services. You may also update or delete this information at any time. Only Riverside staff with valid business reasons have access to this data.

We will use this data to:

• ensure your home meets your needs (including aids and adaptations)
• determine any assistance that you or other member of your household may require
• assist us in understanding any issues you may raise

We will also anonymise this data so that you cannot be identified and use this to:

• provide statistical data for monitoring and reporting purposes
• build a picture of the diversity of our customers at a local and national level
• inform our training, education, and awareness

Who we may share your information with

Where this personal data is required to ensure that your home meets your needs (including any assistance or modifications) identify support you or any household members may need or to help us comprehend any concerns you may have; we may share this data with those third parties listed in management of your tenancy.

We may also share anonymised data with government bodies, our regulators, our partners, or commissioners of our services to ensure that we share values and a genuine commitment to equality, diversity, and inclusion and to demonstrate our staff are representative to the customers and areas we provide homes in.

How long we will keep it

We keep information on our tenancy files for six years after the tenancy ends

You can contact us to delete this data at any time unless we have an obligation to retain it. Please see Your rights and right to erasure for more information.

Our purpose(s) for processing and lawful basis

During your tenancy we will collect and process information about you and members of your household to ensure that we can deliver our services to you.

The legal bases which apply to the processing described above are:

• Where we need to take measures to perform a contract we have entered into with you (provision of services set out in a tenancy or leasehold agreement);
• Where we need to comply with legal obligations (e.g. housing regulations, health and safety, safeguarding, tenancy fraud investigation);
• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. maintaining security of our property, customer satisfaction surveys and market research).

We may also use your sensitive personal data under the following legal bases:

• Where we have your consent (e.g. provision of additional benefits or services, information gathered through feedback or surveys).
• Where we need to protect your vital interests (or someone else’s vital interests).
• Where we need to comply with social protection responsibilities (safeguarding of individuals at risk or where we gather health data to make sure your home is appropriate for your needs)
• Where there is a public interest (to ensure there are no risks posed to our staff, customers, or contractors if you declare criminal convictions)

How we use your information

We will use your personal data to:

• Be able to contact you and respond to you directly.
• Manage your tenancy and property (including carrying out maintenance and repairs, notifying utility companies and local authorities);
• Monitor compliance with the terms of your tenancy or service agreement, investigate and report issues (e.g. tenancy fraud, anti-social behaviour)
• Share information with other agencies where we have your agreement, are required to do so, or were doing so gives effect to the tenancy/leasehold agreement.
• Investigate and resolve complaints and queries raised by residents and others.
• Comply with our safeguarding and health and safety duties.
• Deliver support for special needs to you or any member of your household.
• Provide information about additional services we offer, including opportunities to participate in meetings, training, employment services, youth services and events.
• Complete consultations, facilitate residents’ groups and community grant applications.
• Conduct transactional surveys in order to monitor and improve our service, for example, repairs and maintenance, complaints, lettings, anti-social behaviour issues and training.
• Monitor equality and diversity
• Provide information about our performance and services through newsletters and email campaigns.
• Verify your identity so that we can give you access to your MyRiverside account;
• Share information with our payment gateways to enable payments to be taken online

Who we may share your information with

Generally we collect personal data directly from you, but we may in some cases also receive personal data from government bodies and local authorities, third party suppliers, other individuals, or partner organisations (e.g. where work with other parties to provide services, for investigating a complaint etc.).

Normally, only Riverside staff will be able to see and process your personal information. However, there will be occasions when we will need to share personal information with third parties for the purposes as outlined or where we are legally required to do so.

We may communicate any information essential for the successful administration of the buildings, including any health and safety issues, with managing agents operating on our behalf. We may share the same information with other landlords (or managing agents acting on their behalf) who are involved in the joint management of properties.

We also share information:

• To allow us to tailor our services to you
• For detecting possible fraud (e.g. as part of the National Fraud Initiative)
• To deal with rent arrears (e.g. tracing and/or debt collection agencies)
• To deal with unpaid bills (e.g. utility or council tax bills) we may need to pass on your forwarding address
• To help us communicate with you (e.g. we sometimes use external printers, translators etc.)
• To assist the Police in solving crime and investigating anti-social behaviour.

As part of the government’s reform of welfare benefits, we can now share limited information about our residents and their properties with local authorities, for example, name, address, and National Insurance Number. This assists us in identifying and assisting those who may be impacted by welfare reform.

We will also disclose your personal details, if required to do so, by law or by any Government body.

Riverside contracts external organisations to manage certain areas of our business to fulfil our obligations as a social landlord. We share limited personal information of our residents with external contractors, such as name, address, and telephone number.

Examples include:

• Repairs and maintenance contractors (including Evolve)
• Out of hours call centre service
• Health and safety compliance checks (i.e. gas servicing, lifts, asbestos, legionella)

How long we will keep it

We keep information on our tenancy files for six years after the tenancy ends.

Our purpose(s) for processing and lawful basis

We want to be able to assist you in improving your credit history. The Rental Exchange enables tenants with little or no credit history who pay their rent on time to build up a credit score.

Having additional information on your credit file can make it quicker and easier to:

• Open a new bank account
• Arrange a better utilities tariff, or qualify to pay for gas/electricity via a non-prepay tariff
• Apply for a mortgage

The legal bases which apply to the processing described above are:

• We rely on our, and your, legitimate interests to share your data for the Rental Exchange

How we use your information

Unless you choose to opt out/object, we will share selected information with the credit reference agency Experian to allow your rent payments to count toward your credit score.

We will not share any information before you are provided with specific notification and given time to object. We will respect your objection.

You can object to this processing by using this form.

Who we may share your information with

We will share the following information with Experian:

• Name, address, and date of birth
• Tenancy start (and end) dates
• Your required weekly or monthly rent payment
• Your actual weekly or monthly rent payment
• The total of any outstanding rent on your account
• If applicable, your Housing Benefit or Universal Credit payment amount

How long we will keep it

We keep information on our tenancy files for six years after the tenancy ends

You can read Experian’s Credit Reference Agency Information Notice here.

Our purpose(s) for processing and lawful basis

If you or your community may be impacted by planned regeneration work, we may collect information from you and other household members in order to better understand any needs you may have in regard to the regeneration. If you do not provide information, we may not be able to meet your housing needs and may not be able to provide an adequate level of service

The legal bases which apply to the processing described above are:

• Where we need to take measures to perform a contract we have entered into with you (provision of services set out in a tenancy or leasehold agreement);
• Where we need to comply with legal obligations (e.g. housing regulations, health and safety);

We may also use your sensitive personal data under the following legal bases:

• Where we have your consent (e.g. provision of additional benefits or services, information gathered through feedback or surveys).
• Where the processing is necessary in the public interest, including the monitoring of diversity and equality where we work with local authorities and monitoring equality of opportunity or treatment (where the data isn’t used to make decisions on particular individuals)
• Where we need to comply with social protection responsibilities (safeguarding of individuals at risk or where we gather health data to make sure your home is appropriate for your needs)

How we use your information

We will only use the information collected to:

• Ensure that we have accurate and up to date contact details for you, so that we are able to engage with you effectively
• Ensure that we are able to communicate in your preferred language or make any reasonable adjustments required to communicate with you
• Allow us to determine the relevant mix of housing required, based on the requirements collated through our engagement with you, and others
• Ascertain specific requirements such as aids or adaptations (based on physical health, or religious needs)
• Determine any demand for housing for specific populations, such as veterans and their families
• Inform the quality of the services and properties required, including financial viability of the regeneration
• Assist us in making decisions, developing policies, and designing and delivering services.
• Identify fraudulent activity

Who we may share your information with

We may share data with carefully selected third parties assisting us in the design and development of the regeneration project. If we do share data, we will only ever share the minimum amount required; and all third parties are contractually required to ensure that your data is secure and not used for any other purpose.

How long we will keep it

We keep information on our tenancy files for six years after the tenancy ends. You can also exercise your right to request that we erase all or part of your data (where it has been collected for the regeneration project and we do not have a legal obligation to retain it) at any time, though this may also impact the service we are able to provide.

Our purpose(s) for processing and lawful basis

In order to provide our customers with the best service possible, Riverside may contact you for feedback.

In most instances the legal basis which will apply to the processing described above is

• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. maintaining security of our property, customer satisfaction surveys and market research).

Where our legal basis is legitimate interests, you are not obligated to complete surveys and can opt out of providing future feedback.

The Social Housing Regulator and Scottish Housing Regulator are legally obliged to monitor, assess, and report on how well Riverside and Riverside Scotland demonstrate compliance with regulatory standards., This means that we may occasionally also be required by law to conduct tenant perception surveys. In these instances our legal basis is:

• Where we need to comply with legal obligations (e.g. housing regulations)

You cannot opt out of surveys that we are required to conduct by law, though you are under no obligation to participate. It’s important to note that the responses to these surveys will ultimately be used to inform our approach to service delivery in the future, which is why it is important that you take the opportunity to have your say.

How we use your information

When making choices, developing policies, planning, and delivering services, we use survey data to monitor our commitment to listening to and working with our communities.

When you are asked to participate, you will be provided with more detail about the reason behind the survey in a separate privacy notice. Information collected in surveys will be anonymised and cannot be attributed back to you directly unless you:

• identify yourself to raise a comment or concern
• indicate you would like further support
• express an interest to participate in specific events or activities

Surveys may provide you the opportunity to provide feedback on:

• The quality and safety of your home
• Repairs and maintenance services
• Communal areas
• Our approach to keeping you informed
• Our approach to managing complaints
• If you feel you are being treated fairly and with respect
• If you feel Riverside is making a positive contribution to your neighbourhood and community

Who we may share your information with

We may share your contact data with carefully selected third parties to deliver electronic and paper surveys on our behalf. If we do share data, we will only ever share the minimum amount required; and all third parties are contractually required to ensure that your data is secure and not used for any other purpose.

Anonymised survey results will be shared with our regulators. They may also be shared with other organisations such as local authorities to inform research and analysis, develop and improve services and to help us (and other organisations) understand trends and requirements within the housing and Care and Support sectors.

How long we will keep it

We will keep anonymised data for as long as required to allow us to make informed decisions about survey results and to allow us to monitor and compare responses over a reasonable period of time.

If you have identified yourself to allow us to attribute feedback directly to you for the reasons listed above, we will keep any personal information you have provided on our tenancy files for six years after the tenancy ends.

Our purpose(s) for processing and lawful basis

Riverside, and in particular Riverside Home Ownership and Prospect Homes, will process your data to develop, promote and sell our private and shared ownership properties. This includes acquiring further percentages of joint/shared ownership properties.

We will also use your data for marketing purposes where you have consented to this, or where we have a legitimate interest to do so following an enquiry or expression of interest.

The legal bases which apply to the processing described above are:

• Where we need to take measures to enter into and then perform a contract we have entered into with you (provision of services set out in a tenancy or leasehold agreement)
• Where we need to comply with legal obligations (e.g. housing regulations, health and safety, safeguarding, fraud investigation);

We may also use your sensitive personal data under the following legal bases:

• Where we have your consent
• Where the processing is necessary in the public interest, including the monitoring of diversity and equality where we work with local authorities and monitoring equality of opportunity or treatment (where the data isn’t used to make decisions on particular individuals)
• Where the processing is necessary for the establishment, exercise, or defence of legal claims

How we use your information

• To maintain records of those who have enquired or expressed an interest in private or shared home ownership
• To contact you following an enquiry or expression of interest, or to keep you informed of current and upcoming developments
• To verify your identity in line with our legal obligations for fraud prevention
• Managing property sales, reservations, and acquisition of further percentages of joint/shared ownership properties (staircasing)
• To demonstrate to our regulators that we are meeting our legal obligations
• To demonstrate to our funders that we are meeting our legal obligations
• For the purposes outlined in the equality and diversity section of this notice
• For the purposes outlined in the surveys section of this notice
• For the prevention and detection of crime

In order to determine affordability and/or eligibility for the purchase of a shared ownership property, we may use systems which have been configured to employ pre-defined criteria to make automated decisions. You have the right to contest such decisions where they were made automatically without human review or involvement.

Who we may share your information with

We have legal obligations to share your information with the following parties:

• National House Building Council (NHBC) to administer its NHBC Buildmark warranty and insurance product (Buildmark Policy) and provide personalised details of the Buildmark policy to you as the homeowner
• Local authorities who are responsible for administering your council tax
• Relevant authorities, including HM Revenue and Customs and the Department for Work and Pensions
• Any organisation exercising a statutory function (e.g Local health authorities, Social Services)

We may also share your information with:

• Solicitors and mortgage advisors, where they have been instructed in relation to the sale or purchase of a property
• Utility companies and their representatives to ensure property addresses and billing details are accurate
• Local authorities Environmental Health departments to provide our communities with better environments

How long we will keep it

• Registrations of interest – 2 years after the sale of the property
• New Sales applications – 6 years after your offer has been accepted
• Offer Details – 6 years after your offer has been accepted
• Help to Buy applications – 6 years after your offer has been accepted
• Resales (Shared Ownership) – 6 years after your offer has been accepted
• Staircasing process documents – 12 years from completion of sale
• Completion documentation – 12 years from completion of sale
• Post purchase questionnaire/ customer feedback – 3 years from date of creation

Our purpose(s) for processing and lawful basis

Right to buy

Most Riverside tenants do not currently have the Right to Buy their property. The exception to this is that, if you were a secure council tenant and were living in your home when it was transferred from your council to Riverside, then you may have a ‘preserved’ Right to Buy. This only applies if you were living in your home when it was transferred.

Right to Acquire

You may be eligible for Right to Acquire if you have been a customer of Riverside for 3 years or more, your home was built or bought by us after 31^st March 1997 and funded through a grant provided by the Housing Corporation or local council or if it was transferred from a local council to a Riverside after 31 March 1997.

If you make an application to purchase a property under either of these schemes, we will process your information to determine your eligibility and progress your application to completion.

The legal bases which apply to the processing described above are:

• Where we need to take measures to enter into and then perform a contract we have entered into with you
• Where we need to comply with legal obligations (under the Housing Act 1985 (for Right to Buy applications) the Housing (Right to Acquire) Regulations 1997 and the Fraud Act 2006).

How we use your information

• To maintain records of those who have enquired or expressed an interest in Right to Buy or Right to Acquire home
• To contact you following an enquiry or expression of interest, or to keep you informed of alternative properties under the Right to Acquire
• To verify your identity in line with our legal obligations for fraud prevention
• To process credit checks
• To complete the sale and transfer of the property
• To demonstrate to our regulators that we are meeting our legal obligations
• To demonstrate to our funders that we are meeting our legal obligations
• For the purposes outlined in the equality and diversity section of this notice
• For the purposes outlined in the surveys section of this notice
• For the prevention and detection of crime

In order to determine affordability and/or eligibility for the purchase of a shared ownership property, we may use systems which have been configured to employ pre-defined criteria to make automated decisions. You have the right to contest such decisions where they were made automatically without human review or involvement.

Who we may share your information with

• Credit Reference Agencies – you can read the Credit Reference Agency Information Notice here
• Identify verification services
• Surveyors for property valuations
• Land Registry compliant Lease Plan providers
• Any solicitors instructed by you, or us

How long we will keep it

• Registrations of interest – 2 years after the sale of the property
• Completion documentation – 12 years from completion of sale
• Post purchase questionnaire/ customer feedback – 3 years from date of creation

Our purpose(s) for processing and lawful basis

Riverside is responsible for maintaining the standard and safety of your home and carrying out repairs on your property as needed. You should read your tenancy or license agreement for more information about what we, and you, are responsible for.

The legal bases which apply to the processing described above are:

• Where we need to take measures to enter into and then perform a contract we have entered into with you
• Where we need to comply with legal obligations (health and safety).
• Where we need to protect your vital interests or someone else’s vital interests (in the event of an emergency)

How we use your information

We will use your information:

• To manage emergency and non-emergency repairs and maintenance
• To manage programmed repairs – scheduled maintenance to continually improve your home
• To manage any identified or requested Aids or Adaptations – these are alterations or additional fittings which can be provided to assist you, or someone within your household to access the basic facilities within your home
• To ensure that you, and anyone carrying our repairs or maintenance on your property is kept safe during repairs or safety visits

We may offer you the option to use video diagnostic technology to assist us with any of the uses listed above.

Who we may share your information with

• Third parties contracted to carry out repairs and maintenance on our behalf
• Local Authorities where you have requested major aids and adaptations
• Occupational Therapists where you have requested major aids and adaptations

We may also be required to share anonymised data with our regulators and government bodies, such as the Secretary of State, if we are required to do so by law or if it is judged in the public interest to demonstrate effective solutions for managing issues such as damp and mould or other health hazards..

How long we will keep it

We keep information on our tenancy files for six years after the tenancy ends.

Our purpose(s) for processing and lawful basis

We use a number of tools and/or services to assist us in diagnosing faults and issues and utilising smart devices.

If you choose to have a Switchee thermostat in your home, you can control your heating to enable you to monitor your energy consumption. You can read Switchees Privacy Notice here.

Riverside can also use data captured to gather information about the energy performance of your property.

The legal bases which apply to the processing for Switchee are:

• Where it is necessary for yours and our legitimate interest (please see how we use your information below)

If you contact us about a repair or maintenance issue, we may offer you the option of using video diagnostic technology on your personal device to enable us to diagnose issues and faults. Video diagnostics will not collect personal information by default, but minimal personal data including your image, or those of your household, may be captured as you are in control of what can be seen using the camera on your device.

The legal bases which apply to the use of video diagnostics are:

• Where we have your consent to start the diagnostic
• Where it is necessary for yours and our legitimate interest to use the information collected (please see how we use your information below)

How we use your information

Switchee:

• For installation and customer support (your contact information)
• For screen surveys (your contact information)
• Sensor data for temperature, light, motion, air pressure and humidity will be used to allow Riverside to identify any property performance issues so that we can plan, fund, prioritise and allocate resource for responsive and non-responsive repairs, maintenance, and investment.

Switchee may also pair sensor information with local weather data to provide analytics for:

• Condensation, damp, and mould risk
• Fuel poverty risk
• Heating performance
• Appointment scheduling

Please note that although sensor data itself is not personal data, it could reveal behavioural information about your household.

Video diagnostics:

• To diagnose faults or issues before an engineer attends your property

Diagnostics will help us to increase first contact resolution for you, sometimes without requiring an engineer visit. It will also aid in improving our first-time fix by identifying the tools and parts required to fix issues on the first visit.

Who we may share your information with

Switchee:

We may communicate any information essential for the management of your home, including any health and safety issues, with managing agents operating on our behalf. We may share the same information with other landlords (or managing agents acting on their behalf) who are involved in the joint management of properties.

Where you have consented, we may share your contact details with Riverside support services or third parties offering assistance and advice on energy savings, affordable warmth, and cost of living.

Video diagnostics:

• Repairs and maintenance contractors (including Evolve)

How long we will keep it

We keep information on our tenancy files for six years after the tenancy ends

Non-personal data may be combined with personal data collected through your use of Switchee and may be anonymised and shared with Riversides insurers, our funders, our regulators, government departments and selected research and analysis providers.

Our purpose(s) for processing and lawful basis

Your safety is our top priority. This includes keeping you and your home safe in the event of a fire. As your landlord, we’re also responsible for making sure any gas appliances and pipework in your home are safe and working normally. So, we carry out annual gas safety checks in all of our properties with a gas supply.

The legal bases which apply to the processing described above are:

• Where we need to carry out a task in the public interest (to assess risk)
• Where we need to comply with legal obligations (The Gas Safety (Installation and Use) Regulations 1998, The Fire Safety (England) Regulations 2022).
• Where we need to comply with social protection responsibilities
• Where we need to protect your vital interests or someone else’s vital interests (in the event of an emergency)

How we use your information

Your information will be used by us to set up access to your property, conduct the required safety inspections, and keep a record of any communications with you on those matters.

We will use any information provided by third parties such as electricians or gas safe registered engineers (if they are not directly employed by Riverside) or the Fire and Rescue Service to identify and prioritise any actions needed for the safety of your household.

Who we may share your information with

• Repairs and maintenance contractors (including Evolve)
• Your utility providers
• Fire and Rescue Services
• Third party accommodation providers if we advise that you must vacate the property due to safety concerns
• Local authorities where required
• Government departments where required
• The Police if we have reason to suspect that a criminal act has been committed (such as tampering with meters or arson)

How long we will keep it

We keep information on our tenancy files for six years after the tenancy ends

We keep records of the gas safety check on your property for up to 2 years and 2 months.

Our purpose(s) for processing and lawful basis

Riverside provides a wide variety of care and support services offering accommodation and a range of initiatives in conjunction with local authorities and partners to deliver care and support solutions to vulnerable individuals and those at risk of homelessness. Riverside Care & Support operates in over 170 Local Authority Areas, delivering over 340 services, including:

Supported housing, care services, veteran support and housing, retirement housing, young people and families, community services and substance misuse and rehab.

We also conduct, take part in and support a variety of homelessness-related research and reporting activities.

The legal bases which apply to the processing described above are

• Where we need to take measures to enter into and then perform a contract we have entered into with you (provision of services set out in our agreements with you).
• Where we need to comply with legal obligations (e.g. as set out by the Care Quality Commission, health care, health and safety and safeguarding legislation).
• Where the processing is necessary in the public interest or for official purposes set out in legislation (e.g. where we work in partnership with local authorities and the NHS).
• Where we have your consent (e.g. provision of additional benefits and services).
• Where we need to protect your vital interests (or someone else’s vital interests).
• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. maintaining security and safety of our property, customer satisfaction surveys and market research).

Where possible we will seek your explicit consent to process sensitive personal data. In cases where consent may not be appropriate the following legal bases may apply:

• Where we need to comply with legal obligations in relation to social security and social protection (especially where we act on behalf of local authorities or the NHS including The Care Act 2014; Health and Social Care Act 2008 (regulated activities) Regulations 2014, Mental, Capacity Act 2005 and Mental Health Act 1983)
• Where we need to protect your vital interests (e.g. where your life or that of another individual is in danger and you aren’t able to give your consent).
• Safeguarding of individuals at risk (including children).
• Monitoring equality of opportunity or treatment (where the data isn’t used to make decisions on particular individuals).

To process personal data about criminal convictions or offences we must have both a lawful basis for the processing and either legal authority or official authority for the processing.

Depending on how and when we engage with you, we may also provide you with additional information or privacy notices. For instance if we offer, or you request, further support we may provide you with a privacy notice specific to that service.

How we use your information

We will use your information to:

• Be able to contact you, respond to you directly and verify your identity
• determine your eligibility for care and support services.
• Process requests and administer care and support services, including billing and payment plans.
• Identify your care and support needs and complete our assessments, in order to offer you the safest and most effective service possible.
• Update our records of your care and support needs.
• Complete individual risk assessments and investigate any issues or incidents.
• Share information about your care and support with your family or next of kin.
• Share information with other agencies where we have your agreement, are required to do so, or where doing so gives effect to our agreement with you;
• Monitor our premises and maintain a safe environment for residents and staff.
• Provide information about additional services we offer;.
• Complete consultations and conduct transactional surveys in order to monitor and improve our service and offer you the opportunity to shape current and future services
• Provide assistance to the police in the event of a Missing Person case.
• Monitor equality and diversity.
• Provide reporting to and carry out audits for local authorities and regulators.

If at any point you lack the mental capacity to make a particular decision about your information, and processing it, including sharing it, would be in your best interests, we will process it on your behalf. When we do so we will follow the Mental Capacity Act and its Code of Practice which can be found here in England and in Scotland the Adults with Incapacity (Scotland) Act 2000.

Surveillance in care and support

Care and support services use surveillance as part of service delivery to provide safe care and treatment or to help people stay safe without restricting their activities or movement.

This can be used across a whole service or on an individual need basis and examples include, but are not exhaustive to, technology such as acoustic monitoring, bed sensors and call bell systems such as Tunstall or Nurse Call, and communal CCTV.

Any surveillance that is undertaken within a care and support service, outside the use of communal CCTV usage, is individually risk assessed with each customer and consent clearly recorded.

Usage of surveillance for the provision of care and treatment is managed in line with the Health and Social Care Act, Mental Capacity Act, and guidance on using surveillance published by the Care Quality Commission (CQC) as well as data protection legislation mentioned and guidance or codes of practice issues by the Information Commissioner’s Office.

CQC do not authorise the use of hidden cameras or other hidden recording equipment within private areas of a registered residential service or customers own home. Covert surveillance may only be used in rare circumstances and for a short period of time, for example, to identify a specific allegation.

Under Sections 62 –64 of the Health and Social Care Act 2008, CQC are permitted to have access to information that has been recorded using covert or overt surveillance (or to have access to surveillance systems) where CQC consider it necessary and proportionate to do so to exercise their functions as a regulator.

Who we may share your information with

In most circumstances, we collect personal data directly from you, but we may also obtain personal data from government bodies and local authorities, third-party care and support providers, other persons, or partner organisations involved in your care.

Where authorisation is in place (e.g. Lasting Power of Attorney) we may share personal data with the authorised individuals acting on your behalf. Unless we are certain that you have appointed them or that they are acting in an official capacity, we will not disclose your personal information to anybody who makes a claim to be acting on your behalf.

In some exceptional circumstances we need to share care information with relatives/next of kin without authority or your consent.

In order to provide safe and effective services to you, we may share your data with:

• Any individuals you have nominated or authorised to act on your behalf (including friends, family, MPs and Councillors)
• Local Authorities who have commissioned our services to you under a contract
• NHS Trusts involved in your care, or where our services form part of a contract with a Trust
• Health and Social Care professionals, which may include your GP or Pharmacy
• Third parties that assist us in providing services to you, either in your home or externally (including translators and communications specialists)
• Support Services or organisations involved in your care (including charities, foundations, or other non-NHS bodies)
• Police, fire, or other rescue services
• Law enforcement agencies, or other agencies where we have a legal obligation to share data

How long we will keep it

We retain data for differing lengths of time, dependant on a number of criteria, including:

• The services you have accessed
• Any retention period specified by law, or regulation, or
• Any retention period suggested as best practice by regulators, sector specialists or professional bodies
• If no retention period is specified by law, we will keep it for as long as is reasonable for us to demonstrate we have met the conditions of our service or license agreement with you

You can contact us using the webform about the specific retention periods relating to your information.

Our purpose(s) for processing and lawful basis

Community groups or special interest groups are made up of residents who have similar interests and provide community activities. You can either create a group in your local area with help from us or join one that is already in existence. Community groups provide activities such as photography workshops, arts and crafts classes and social events for residents and their families.

Riverside also hosts or arranges community events and services across all of the regions in which we operate. We’ll inform you about these in a number of ways, including social media, on our website, and through your housing officer or tenancy/support worker. Special interest groups also get involved in helping us to shape our current and future services.

We may contact you about community events and services we offer and process your information in order to administer these events and services, and to receive feedback.

We may also ask your permission to use photographs, video recordings taken, feedback or quotes in our publications and communications.

The legal basis which applies to the processing described above is:

• Where we have your consent, or explicit consent (e.g. use of photos/videos for marketing, communications or publishing etc.)

Where the legal basis is consent, you may withdraw your consent at any time.

Where we collect information about participants in events and services to monitor and evaluate activities and the social impact of activities the legal basis will be:

• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. maintaining security of our property and assets, customer satisfaction surveys and market research)

Where our legal basis is legitimate interests, you can opt out of the processing of your information

We may process sensitive personal data in limited circumstances with your consent to identify any reasonable access requirements for events, or any dietary requirements specific to your religious or philosophical beliefs. This may include any children under the age of 16 you have legal responsibility for.

In some instances we may also ask you to provide sensitive personal data to allow us to monitor the equality and diversity of those participating in events or services, to ensure we are considering all of our residents in deigning and delivering community events.

How we use your information

We use information provided to:

• Be able to contact you and respond to you directly.
• Provide information about additional services we offer, including opportunities to participate in meetings, training, employment services, youth services and events.
• To organise and administer community events or services (including food and drink requirements)
• Deliver support for participation in groups or events to you or any member of your household.
• Share information with existing community groups or with event organisers where we have your agreement
• Comply with our safeguarding and health and safety duties.
• Complete consultations, facilitate residents’ groups and community grant applications.
• Conduct transactional surveys in order to monitor and improve our service
• Monitor equality and diversity.
• Publish photographs, feedback or quotes where we have your consent

Who we may share your information with

• Existing community groups
• Other organisations or individuals involved in the delivery of groups, events, or services
• Third parties acting under contract to gather feedback or to deliver and receive surveys

How long we will keep it

We keep information on our tenancy files for six years after the tenancy ends.

Our purpose(s) for processing and lawful basis

We understand that sometimes you might need more support and it’s important to us that people experiencing difficult circumstances or needing assistance with goods and services are given the opportunity to lead more resilient and independent lives through the housing, care, and support services we provide. That’s why we actively assist customers with schemes to provide furniture and domestic appliances and create opportunities to increase household income through our programmes of employment, affordable warmth, and money advice.

The legal bases which apply to the processing above are:

• Where we have your consent to refer you to our internal support teams, or organisations we have partnered with (including criminal convictions)
• Where it is necessary for yours and our legitimate interest to use the information collected (please see how we use your information below)
• Where we need to protect your vital interests (or someone else’s vital interests).
• Where we need to comply with social protection responsibilities (where we gather health data to ensure you receive appropriate support

How we use your information

Our Money Advice Team may use your data:

• To assist you in calculating any welfare benefits you may be entitled to claim
• To assist you in completing claim documentation
• To advise you on any decisions you intend to appeal

Our Affordable Warmth Team may use your data:

• To assist you if you have received an inaccurate or incorrect energy bill
• To assist you if you have fallen into fuel debt
• To assist you if you have no energy supply and need assistance to reconnect

Our Employment and Training Team may use your data:

• To assist you in looking for work if you have a disability
• To assist you in looking for work if you have a criminal record
• To assist you in general job searching, CV writing and interview techniques
• To assist you in identifying apprenticeships, training, and qualification opportunities
• To assist you in accessing funding to support learning or job opportunities
• To assist you in becoming self employed and/or starting your own business

Who we may share your information with

• Money Advice and Pension Service
• Department for Work and Pensions
• Any third parties advertising training and employment opportunities that you would like to be considered for
• Any third party organisations who have agreed to provide furniture or domestic appliances for the duration of your tenancy or an agreed period
• Utility providers
• Funding providers, for self-employment opportunities
• Local authorities (including Social Services where relevant)
• Health professionals acting on your behalf
• Law enforcement

How long we will keep it

We keep information on our tenancy files for six years after the tenancy ends.

Our purpose(s) for processing and lawful basis

We provide a range of means for people to contact us with general enquiries. These can be used by anybody, regardless of whether they have a contract with us or not, and include telephone, mail, and electronic communications. When you reach out to us through one of these channels, we will forward your information to the appropriate Riverside team to help you.

The legal bases which may apply to the processing described above are:

• Where we need to take measures to enter into and then perform a contract with you.
• Where we have your consent to us processing your personal information.
• Where it is necessary for your, or our, legitimate interests
• Where processing is necessary to comply with the law or a statutory obligation.
• Where we are under a legal obligation or an obligation under a contract to process/disclose the information.
• Where we need to protect the vital interests (i.e. health and safety) of you or another person.

Information collected through enquiries may be used to provide any the services listed in this Privacy Notice. You should read section relevant to those services if this is the case.

How we use your information

We will use the information you provide to respond to and manage any enquiry, including:

• To respond to requests for information regarding our services
• To contact you regarding property you have registered an interest in.
• To investigate and manage complaints or concerns
• To comply with relevant legislation and regulation.
• To respond to reports of anti-social behaviour
• To respond to reports of domestic abuse
• To investigate reports of tenancy fraud
• To investigate reports of utility fraud
• To subscribe you to newsletter or updates you have requested
• Exercising your rights under Data Protection Law

Who we may share your information with

Your personal data may be shared with third parties or companies that perform services on our behalf, such as those that provide and host our IT systems, or repairs and maintenance contractors. All third parties operate in accordance with legally binding contracts, and we will never give them more information than is necessary for them to perform the requested service

We may also need to share your data with other parties in order to respond to a request or where we have a legal obligation to do so. Where possible you will usually be notified of this before we do.

How long we will keep it

We may keep call recordings for up to 12 months unless we are required to retain them for another purpose. For all other purposes, the retention period is dependent on the reason for contact and any legal obligation we have to retain the data. Where there is no legal basis, the retention will be determined by business need.

Our purpose(s) for processing and lawful basis

We record calls into the Customer Service Centre for training and monitoring purposes, as well as for the purpose of quality control. You will normally be told before speaking to one of our advisors that our calls are being recorded. We may also need to use call recordings as evidence where concerns or issues are raised.

The legal bases which apply to the processing described above are:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where the processing is necessary for a legal obligation or in the public interest, or for official purposes, as set out in legislation (e.g. for safeguarding, anti-social behaviour)
• Where we have your consent, or explicit consent (for use of sensitive information)

How we use your information

We will only use your information collected for this purpose in order to train our staff, monitor calls and to monitor the quality of our engagement and services to you. Where calls raise concerns relating to safeguarding or anti-social behaviour, they may be processed and retained as evidence.

Call recording is automatically stopped when taking payment details and is then restarted again once payment details have been provided.

Who we may share your information with

We will not usually share your information recorded on a call with a third party, other than third party suppliers of telephony and customer services.

Where information recorded on a call is needed for evidential purposes, we may share call recordings with:

• Internal teams (e.g. safeguarding or anti-social behaviour teams)
• Law enforcement
• Health professionals

How long we will keep it

Unless we need to keep the recording as evidence for another purpose, calls to the customer service centre may be recorded and held for up to 12 months. If we are required to keep recordings for another purpose, the applicable retention period for that other purpose will then apply (e.g. 6 years for limitation of liability).

Our purpose(s) for processing and lawful basis

We will use your information to investigate and resolve complaints raised by you, our residents, or others (including Councillors and Members of Parliament).

The legal bases which apply to the processing described above are:

• Where we need to comply with legal obligations or substantial public interest set out in legislation (section 193 of the Housing and Regeneration Act 2008 and the associated Homes and Communities Agency Regulatory Standards 2017)
• Where we need to take measures to enter into, and then perform, a contract we have entered into with you (e.g. provision of services set out in a tenancy or leasehold agreement)

How we use your information

We will use your information to thoroughly investigate and respond to a complaint you make, or where we receive a complaint from another person. In order to carry out a substantive investigation, we may request additional information from third parties (as well as the complainant).

We may pass information relating to the complaint to the relevant team(s) within Riverside, or third parties providing investigation and response services on our behalf.

In some instances we may ask customer representative groups or committees to carry out an impartial and autonomous review of your complaint.

Who we may share your information with

We may share information provided as part of the complaint investigation with third parties, including contractors working on our behalf if they are the subject of the complaint. We will also sometimes need to involve external parties such as local authorities to resolve a complaint.

Where you have raised your complaint through a representative (e.g. Councillor, Member of Parliament, Mayor, local authority etc.) we will share information relating to the complaint with the representative authorised by you or their staff with your inferred consent.

On completion of the complaints process, should the complaint be escalated or appealed at your request, we may share information with relevant regulators or non-departmental public bodes such as the Housing Ombudsman Service (HOS). The HOS looks at complaints about registered providers of social housing and their service is free, independent and impartial.

How long we will keep it

We will keep the information for 6 years from when the complaint is closed unless the information is relevant to a later complaint.

Our purpose(s) for processing and lawful basis

We survey and monitor our property and buildings, including the areas directly surrounding our buildings, for the following purposes:

• For security purposes in the public interest (including national security)
• For the prevention and detection of crime
• To prevent and investigate anti-social behaviour and nuisance
• To assess property maintenance and assist with estate and property management
• To provide safe and secure places of work for employees
• For insurance purposes as required
• For internal investigations carried out by Riverside in accordance with approved policy (e.g. in response to complaints or disciplinary cases)

The legal bases which apply to the processing described above are:

• Where we need to comply with legal obligations (e.g. provide safe spaces for residents and customers to live, protect the health and safety of our employees)
• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. ensuring the security of our properties and assets, insurance purposes, carrying out internal investigations)

How we use your information

We process personal data captured through CCTV footage in line with our CCTV and surveillance policies. Unless otherwise stated, we do not carry out live CCTV surveillance. We will take a reasonable and proportionate approach to downloading and viewing of CCTV footage which balances your right to privacy, the seriousness of incident and meeting the stated purposes.

CCTV will always be accompanied by adequate signage to inform you that there is CCTV in operation.

Further information on use of CCTV and surveillance is available for our care and support services.

Who we may share your information with

We will not usually disclose CCTV footage to third parties. However, we will consider requests from the following where there is a legal basis for the disclosure and the footage is necessary for a legitimate purpose:

• The police or other law enforcement agencies, where not disclosing the CCTV footage would prejudice an investigation
• Regulatory agencies
• Insurance companies, for example when acting on behalf of Riverside or an individual affected by a crime for which Riverside holds relevant evidence. In such cases, Riverside will assess whether there is a legal basis for the disclosure and seek assurance that disclosing the CCTV footage is necessary. An administrative fee may be charged to cover costs

How long we will keep it

Typically, CCTV footage will be retained for 30 days. Footage identified as necessary for an investigation or one of the other purposes set out above will be downloaded to secure storage and retained for the retention period relevant to that purpose (e.g. 6 years under limitation of liability).

Our purpose(s) for processing and lawful basis

We will use your information to assist in the delivery of our facilities management services that support the functionality, safety, and sustainability of our buildings, grounds, infrastructure, and real estate. This helps us to ensure the safety and security of our buildings, safety of our customers, employees and visitors and facilitates access to buildings for repairs and maintenance.

The legal bases which apply to the processing described above are:

• Where we need to comply with legal obligations (e.g. provide safe spaces for residents and customers to live, protect the health and safety of our employees)
• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. ensuring the security of our properties and assets, insurance purposes, carrying out internal investigations)

Where we need to ensure the safety of our customers and employees, we may need to process your sensitive personal data. The legal basis for this is:

• Where we need to comply with legal obligations relating to employment, social security and social protection or substantial public interest set out in legislation (e.g. health and safety, safeguarding, anti-social behaviour)

How we use your information

Your information will be used by us to keep track of who visits our facilities and whether they have any health and safety requirements (e.g. for emergency purposes). We may also need to contact you to assist us in accessing areas in our facilities in order to carry out repairs and maintenance of our facilities.

Further information about how we process CCTV footage is also available.

Who we may share your information with

We may share your information with carefully selected third parties to deliver services on our behalf. If we do share data, we will only ever share the minimum amount required; and all third parties are contractually required to ensure that your data is secure and not used for any other purpose.

How long we will keep it

Registration and visitor logs recording attendance at our facilities are kept for one month.

Our purpose(s) for processing and lawful basis

We may use your personal data to better inform our ongoing internal research and analysis, using technology to identify patterns, inform decisions and train AI to improve our efficiency and your experience. We’ll always do this transparently and with your consent where required.

The legal bases for the processing described above are:

• Where it is necessary for our legitimate interest (or a third party) and your interests and fundamental rights do not override those interests (please see how we use your information below)
• Where it is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes
• Where we may use the processing to assist in meeting a legal obligation under a regulatory standard (such as the decent home standard)
• Where we are required to do so to assist in meeting statutory or government purposes (e.g where the Secretary of State requests we carry out analysis to identify and address hazards such as damp and mould)

In some instances, we may request your consent to process certain data for these purposes. Where consent is the legal basis we rely on, you have a right to withdraw that consent at any time.

How we use your information

We will use your personal data to identify patterns, inform decision and train AI to improve our service delivery and efficiency, and your experience across the following areas:

• Predict repairs and maintenance based on historical repair data (such as damp and mould)
• Assist our tenants in keeping their rental payments up to date and ensuring that they have timely access to services such as our Money and Benefit Welfare Advice Team
• Assist our tenants in ensuring that they do not fall into increased rent and/or utility related debts and fuel poverty
• Provide assistance in ensuring better standards of living for those on low incomes
• Provide a more personalised service based on your needs and circumstances
• Make better predictions for future housing needs for new and current tenants

Where any decisions are made based on AI/machine learning capabilities, we will ensure that the decision itself is made by a human. You have the right not to be subject to significant decisions based solely on automated processing.

Information which is used for research and analysis will be kept pseudonymised (individuals cannot be directly identified) where possible, and any outputs of the data will be anonymised (individuals cannot be identified at all).

Who we may share your information with

We may share your information with carefully selected third parties who partner with us to deliver system services. If we do share data, we will only ever share the minimum amount required; and all third parties are contractually required to ensure that your data is secure and not used for any other purpose.

Where you have consented, we may share relevant limited information with Riverside support services or third parties offering assistance and advice in areas such as energy savings, affordable warmth, and cost of living.

How long we will keep it

Identifiable information will be retained for up to 6 years from the end of your tenancy. We will keep anonymised data for as long as required to allow us to make informed decisions based on the research and analysis carried out.

Our purpose(s) for processing and lawful basis

The Noise App is a third-party application used to take audio recordings. We use personal data collected through The Noise App to expediate investigations regarding noise nuisance and to determine whether the noise report is anti-social behaviour, domestic living noise or a statutory nuisance.

The legal bases which apply to the processing described above are:

• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. expediating investigations into noise nuisance)

How we use your information

Use of The Noise App is optional. We will use the contact details of residents who choose to use The Noise App to contact them regarding their reports of noise nuisance.

The report/recording consists of a 30 second recording of the noise nuisance that the resident is experiencing, what type of noise it is, where the recording has taken place within the property, how much it is affecting them, and the noise source address/ location.

Once submitted, the information is passed on to the relevant team dealing with noise nuisance for further investigation. Reports and recordings may be used as evidence in investigating and managing anti-social behaviour and statutory nuisance, including where relevant for legal proceedings.

Who we may share your information with

We may share information reported/recorded through The Noise App with:

• Law enforcement
• Third party suppliers providing our systems

How long we will keep it

We retain the information for up to 2 years. However, we may need to keep it for longer in certain cases where an historic noise complaint is re-activated and/or information is needed for the purpose of legal proceedings.

Our purpose(s) for processing and lawful basis

The information we collect is used for investigating, managing and resolving anti-social behaviour (ASB) complaints. In some cases complaints may also lead to prosecution.

The legal bases which apply to the processing described above are:

• Where we need to take measures to enter into, and then perform, a contract we have entered into with you (e.g. meet obligations set out in a tenancy or leasehold agreement)
• Where we need to comply with legal obligations relating to social security and social protection or substantial public interest set out in legislation (Anti-Social Behaviour, Crime and Policing Act 2014)
• Where we need to act to protect the vital interests of an individual (e.g. where your life or that of another individual is in danger and you aren’t able to give your consent)
• Where processing is necessary for establishing, exercising, or defending legal claims

How we use your information

In order to gain evidence to aid in the investigation and resolution of ASB, we use the information provided for this reason to communicate with other teams within the organisation, residents, local governments, other housing associations, third parties, and the police..

We may need to collect information from third parties and work with external agencies in order to resolve the case.

Any information you have supplied to support a complaint you have made about someone else, such as a neighbour, may be used in court proceedings or other legal actions we take against them.. If you do not want your evidence to be used in this manner, please let us know.

Who we may share your information with

We may share your information with the following:

• Local authorities
• Law enforcement
• Other housing associations
• Courts
• Other individuals mentioned/implicated in the case

If you do not want your information shared with a third party, we will endeavour to respect your wishes; but, we are not always able to thoroughly investigate claims anonymously and may be required to act by law.

How long we will keep it

We will generally retain the information up to 6 years from close of the case. However, where information is processed for other purposes as well (e.g. safeguarding, legal claims etc.) other retention periods may apply instead.

Our purpose(s) for processing and lawful basis

In some circumstances we may process your information in the public interest to protect someone from harm, to combat crime, or for public health and/or public policy purposes. Combating crime includes preventing and reducing crime, assisting investigations and prosecutions and covers all crimes including unlawful violence, public disorder and fraud.

The legal bases which apply to the processing described above are:

• Where the processing is necessary in the public interest, or for official purposes, as set out in legislation (e.g. where we work with local authorities, central government, law enforcement agencies etc.)
• Where we need to comply with legal obligations (e.g. housing regulations, fraud investigations)

Where we need to act to protect someone from harm where possible we will do so with consent, but where we need to act without consent, the legal bases which apply are:

• Where we need to comply with legal obligations (e.g. safeguarding)
• Where there are substantial public interests set out in legislation (e.g safeguarding of individuals at risk, including children)
• Where we need to protect your vital interests or someone else’s vital interests (in the event of an emergency)

How we use your information

We will carefully analyse the facts of each instance before acting in the public interest. We must be able to demonstrate that the information was used in a specific way as a reasonable response to a pressing need or urgent requirement.

We won’t process your information to protect you from harm without your permission, unless it is an emergency, the harm amounts to a crime or you lack mental capacity.

Who we may share your information with

Where we are acting in the public interest in order to assist in preventing crime, investigations, prosecutions, we may share your information with:

• Law enforcement
• Local authorities
• Central government
• Other housing associations
• Legal representatives

Where we are acting to protect you or another individual, we may share your information with:

• NHS Trusts
• Emergency services
• General Practitioners
• Local authorities

How long we will keep it

Information collected and used for combating crime will be stored for 6 years from the close of the case. Information relating to safeguarding cases will be stored for 10 years from the close of the case, or in the case of children, until they are 25 when the retention will be reviewed.

Our purpose(s) for processing and lawful basis

We will use your contact details to communicate with you about Riverside and its activities. In some cases we are legally or contractually required to communicate with you.

Where we are legally or contractually obligated to communicate with you, the legal bases which apply are:

• Where we need to take measures to enter into, and then perform, a contract we have entered into with you (e.g. provision of services set out in a tenancy or leasehold agreement)
• Where we need to comply with legal obligations (e.g. housing regulations)

Where we communicate with you to keep you updated about Riverside’s activities and latest news and information, the legal basis which applies is:

• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. informing you of our activities etc.)

Where our legal basis is legitimate interests, you are not obligated to complete surveys and can opt out of receiving future optional communications.

Where you have indicated to us that you need reasonable adjustments made to how we communicate with you (e.g. large print, electronic only etc.) we will use relevant sensitive data about you to ensure we communicate with you in a way that meets your needs. The legal basis for this is:

• Where we have your explicit consent (where appropriate and does not conflict with legal obligation or contractual requirements)

Where the legal basis is consent, you may withdraw your consent at any time.

We may also communicate with you to tell you about community events and to offer additional services.

How we use your information

We will use your contact details to send you electronic or paper communications. We will use the current contact details on your tenancy file, and it is important that you let us know of any changes to your contact details.

For use of photographs etc. in our communications and publications, please see Community events and services

Who we may share your information with

We may share your contact data with carefully selected third parties to deliver electronic and paper communications, including translations where applicable, on our behalf. If we do share data, we will only ever share the minimum amount required; and all third parties are contractually required to ensure that your data is secure and not used for any other purpose.

How long we will keep it

Your contact details are retained on your tenancy files which are retained for six years after the tenancy ends. However, any contact details shared with third parties will only be kept for the duration of that contract.