Privacy Notice

GDPR Statement

Thrive Homes respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights under the Data Protection Act 2018.

Purpose of this Privacy Notice

This privacy notice aims to give you information on how Thrive Homes collects and processes your personal data in order to conduct normal business activities as a UK charitable housing association. Normal activities can be summarised as:

1.Providing social and other types of housing.
2.Property and grounds maintenance and repair.
3.Managing your housing, tenancy/lease and account as your landlord.

Who we are

Thrive Homes is the controller and responsible for your personal data (collectively referred to as “Thrive Homes”, “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO by using the details set out below.

Data Protection Officer
Thrive Homes
Building 3
Hatters Lane
Croxley Business Park
Watford
WD18 8YG

 

Or use our email address: enquiries@thrivehomes.org.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to your personal data

It is important that the personal data we hold about you is accurate and current. Please help us by keeping us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect, use, store and transfer different kinds of personal data about you, which include:

  • Name
  • Address
  • Contact details (Phone & email address)
  • Present, previous and forwarding addresses
  • Gender
  • Date of Birth
  • Marital Status
  • Rent payment details
  • Bank details
  • Housing benefit
  • Employment details
  • National Insurance number
  • Health and care details
  • Basic details (name and DOB) of all household residents.
  • Disabilities
  • Ethnicity, culture or religion
  • Anti-social behaviour, violence and criminal activities
  • Complaints

Our landline phone calls are recorded for training and monitoring purposes and our recordings are usually held for a period of six months.

From time to time we may operate CCTV / sound recording and / or use photography to capture evidence of breach of tenancy, alleged anti-social behaviour or crime.

We may also take photographs at our events, at our properties and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Thrive Homes does not normally process children’s information as part of a tenancy, as all tenants are adults. However, we record children’s basic information if they are resident in one of our properties, including their name and date of birth. This is required for checking the property is not overcrowded and to assess other tenancy management issues where all householders and ages are required to be known.

We may receive children’s information if we are involved in the housing and tenancy aspects of a welfare case as part of a multi-agency working solution. 

If you fail to provide personal data

If you do not provide the information we need then we may not be able to provide all our services to you, and ultimately you may not be able to hold a tenancy or lease with us, or sell or purchase a property through us.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • To provide the services you need including repairs, maintenance, rents, transfers, sales and anything to do with your tenancy and property.
  • To deal with your account(s) including payments, grants and benefits or run any other service we provide to you
  • To manage applications made by you
  • To provide a helpful and efficient response when customers ask for help and advice
  • To deal with complaints
  • 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 we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data.   We will only contact you with direct marketing communications should you consent to receive them. You have the right to withdraw consent to marketing at any time by contacting us.

Change of purpose  

We will only use your personal data for the purposes for which we collected it.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with contractors in order for them to carry out repairs or refurbishments on our behalf.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Sometimes we may have to share information for legal reasons, for example to the Police, Benefits Agency and other landlords, or if it related to anti-social behaviour, crime or fraud.

If you would like to authorise someone to access your personal data and act on your behalf, please contact us in writing.  If you wish to withdraw this permission you must also notify us in writing.

International transfers

We do not transfer your personal data outside of the EU.

Should this change in the future we will only transfer your personal data to a country outside the European Economic Area (”EEA”), provided that one of the following conditions applies:

  • The country to which your personal data is transferred ensures an adequate level of protection for your rights and freedoms.
  • We have your consent.
  • The transfer is necessary under regulation, in the performance of our contract with you, or to protect your vital interests.
  • The transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims.
  • The transfer is authorised by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our Privacy Policy which you can request from us by contacting us.

In some circumstances you can ask us to delete or remove your personal data where there is no good reason for us continuing to process it. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Our use of cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives 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 taking full advantage of the website.  We’re also using cookies to block automated spam bots leaving false comments.

Cookies which could download: (Estimated length)

  • __utmb Google Analytics (session)= 24-48 hours
  • __utmc Google Analytics = length of session
  • __utmz Google Analytics = 6 Months
  • __utma Google Analytics =2 years
  • __utmv – Facebook = 2 years
  • __qca – Facebook = 5 years
  • PREF* Expires after eight months (Youtube)
  • VSC*expires at the end of your session (Youtube)
  • VISITOR_INFO1_LIVE* expires after eight months (Youtube)
  • remote_sid* expires at the end of your session (Youtube)

You can view Google Analytics Privacy Policy

YouTube Cookies

We embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode.

Read more at YouTube’s embedding videos information page.

Session and persistent cookies

Cookies can expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) or they can be stored for longer. The Regulations apply to both types of cookies:

Session cookies – allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes such as remembering what a user has put in their shopping basket as they browse around a site. They could also be used for security when a user is accessing internet banking or to facilitate use of webmail. These session cookies expire after a browser session so would not be stored longer term. For this reason session cookies may sometimes be considered less privacy intrusive than persistent cookies.

Persistent cookies – are stored on a user’s device in between browser sessions which allows the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. Persistent cookies may be used for a variety of purposes including remembering users’ preferences and choices when using a site or to target advertising.

First and third party cookies – Whether a cookie is ‘first’ or ‘third’ party refers to the website or domain placing the cookie. First party cookies in basic terms are cookies set by a website visited by the user – the website displayed in the URL window. Third party cookies are cookies that are set by a domain other than the one being visited by the user. If a user visits a website and a separate company sets a cookie through that website this would be a third party cookie.

How do I change my cookie setting?

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Your rights

Under the GDPR you have rights regarding the personal data that Thrive Homes process and hold about you. You have the right to:

Right of access You have the right to obtain confirmation from Thrive Homes as to whether or not personal data concerning you are being processed, and, where that is the case, access to that personal data.
Right to rectification You have the right to oblige Thrive Homes to rectify inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed by providing a supplementary statement.
Right to erasure (right to be forgotten) You have the right (under certain circumstances, but not all) to oblige Thrive Homes to erase personal data concerning you.
Right to restriction of processing You have the right (under certain circumstances, but not all) to oblige Thrive Homes to restrict processing of your personal data. For example, you may request this if you are contesting the accuracy of personal data held about you.
Right to data portability You have the right (under certain circumstances, but not all) to oblige Thrive Homes to provide you with the personal data about you which you have provided to Thrive Homes in a structured, commonly used and machine-readable format.

You also have the right to oblige Thrive Homes to transmit those data to another controller.

Right to withdraw consent If the lawful basis for processing is consent, you have the right to withdraw that consent.
Right to object to direct marketing Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for marketing, which includes profiling to the extent that it is related to such direct marketing.
Rights in relation to automated decision making and profiling Thrive Homes does not perform any automated decision-making based on personal data that produces legal effects or similarly significantly affects you.

If you would like to contact us then you can email us enquiries@thrivehomes.org.uk or call us on 08700 917 6077. We will ask you to provide proof of identity before disclosing any information. It is free to use these rights, but Thrive Homes reserve the right to charge a reasonable fee if we feel there are excessive requests.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

In some circumstances we can refuse to comply, if this is the case it will be explained to you. Please note that your right to see certain information may be limited. For example, if it may affect a police investigation or a criminal prosecution then we are not permitted to disclose the information to you.

If you believe our records are inaccurate, you can write to us, asking for them to be amended. If you believe we have unfairly withheld information or unfairly refused to amend our records, you can make a complaint using our standard complaints procedure. Alternatively, you can contact the Information Commissioner’s Office.