Privacy notice - applying to be a Bromford customer
How we collect your information
When you enquire about becoming a Bromford customer we may collect your personal information in a variety of ways, including when you:
- complete one of our application forms, tenancy agreements, licences or leases. You may be asked to undergo a pre offer assessment (see below)
- call us, write to us, e-mail or meet with us
- visit our offices or some of our other properties (we operate CCTV systems at our offices and at some of our properties for the detection and prevention of crime)
Phone calls to our 0330 1234 034 number are recorded for training and monitoring purposes and our recordings are held for a period of six months.
Calls are not recorded when you give us card details to make a payment for your rent or other service.
We may receive information about you from third parties including information from:
- your council, relating to your housing needs
- your benefits office, relating to your benefits
- prior landlords and credit agencies when you apply for housing
- the help to buy service (if you are interested in one of our shared ownership homes)
- Police, welfare or support organisations who are dealing with you
- Councillors, MPs or other representatives acting on your behalf / instruction
- financial institutions when you apply for our services
If you are applying for a commercial lease for one of our shop or commercial units we may ask for references from your bank or suppliers. We may also require a business guarantor.
When you apply for a Bromford tenancy we will request proof of identity and carry out a Pre-Offer Assessment for anyone over 18 who will be living at the property. This is a way of profiling prospective customers to help ensure they can afford the property they have applied for. As part of this process we will ask you to provide three months' bank statements and proof of income. Credit checks and references will be requested.
The information you provide will be considered by us to make a decision on your application. We do not use any automated decision making.
What data do we collect?
When you apply to become a Bromford customer, we request and hold on file information necessary to assess your application. This includes:
- your full name (and proof of your identity / photo ID).
- your date of birth.
- your National Insurance number (your unique identifier).
- your contact details (phone, email or correspondence address).
- details of anyone authorised to act on your behalf (if applicable).
- basic details (name, gender and date of birth) of all household residents.
- banking details if you pay your rent by Direct Debit.
- proof of your eligibility housing and if you have any interest or equity in any other property.
Information may be provided by:
- references from other housing providers / private landlords,
- your mortgage lender (if you own/have owned your own home),
- credit reference agencies.
- We may also ask for your consent to collect special categories of data as explained below.
- If you provide us with personal information relating to members of your family or your associates we will assume that you do so with their knowledge and their consent to the collection and processing of the information.
- It is important that you notify us of any changes to your personal information.
How we use personal information and the lawful basis for processing
Most of the information we require from you is used to enter into or manage a tenancy, leasehold agreement or other contract between you and Bromford.
Please read your tenancy agreement, lease, licence or contract carefully for specific details as ‘performance of a contract’ is usually the lawful basis for processing your information as set out in data protection law.
The processing we conduct can be summarised as:
- Managing your account charges and payments, including arrears.
- Managing the repairs, maintenance and adaptations of our properties.
- Ensuring tenancy (or contract) conditions are complied with, such as dealing with anti-social behaviour or fraud.
- Complying with relevant legislation and regulation.
The other lawful basis for processing your data (as defined in data protection law) that we regularly rely on is ‘legitimate interest’ (processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject).
Our legitimate interests may include the need to:
- eliminate discrimination or advance equality of opportunity;
- prevent and detect crime including anti-social behaviour;
- conduct research and statistical analysis to help improve our business processes and the services offered to our customers;
- evaluate our performance against other benchmarks.
When your personal data or information is used for statistical or research purposes it is anonymised or pseudonymised so that you cannot be identified. Bromford conducts surveys regularly and periodically relating to our services in order to gauge satisfaction and make improvements based on feedback.
We also seek your consent to hold some information about your lifestyle.
We will always give you a ‘prefer not to answer’ option when we ask for information about your lifestyle. Please note however that this information helps us to improve services.
Other Lawful Bases
In exceptional circumstances there may be another lawful basis for processing your data for example ‘compliance with a legal obligation’ or to ‘protect the vital interests of a data subject or another person’.
Special categories of data
Under Data Protection law certain categories of personal information are classified as sensitive or special categories of data. These categories are data relating to:
- racial or ethnic origin;
- political opinions,
- religious or philosophical beliefs;
- trade union membership;
- data concerning health;
- data concerning a natural person’s sex life or sexual orientation
We minimise the use of special categories of personal data but, given the services we provide there are times when we may have a legitimate interest in processing special categories of data and therefore, we may collect and process this data.
Usually we will seek your consent to processing this data by giving you a ‘prefer not to answer’ option when we ask certain questions. Please note however that if you choose not to provide the information we may not be able to provide all our services to you.
Where we ask for data concerning your health, and this is relevant to your housing needs, the condition for processing is that this is “necessary for the purposes of carrying out the obligations and exercising specific rights of the controller (us) or of the data subject (you) in the field social protection law”.
Providing us with special categories of data helps us deliver our services when providing accommodation for disabled people (including adaptations), people with substance abuse problems or when helping someone to access care services.
Collecting special categories of data also helps us ensure that we meet the Public Sector Equality Duty. This requires Bromford, as a social housing provider, to give due regard to the need to eliminate discrimination, advance equality of opportunity and foster good relations. This mean that we may ask you for information about their ethnicity, religion or belief and so on but our responsibilities under the Public Sector Equality Duty do not over ride your right to privacy.
When we collect specific sensitive data we will notify you of how we will use it, and we will tell you who it may be shared with.
We do not process genetic or biometric data for the purpose of uniquely identifying a natural person.
We operate CCTV systems at our offices and in public areas at some of our properties. Wherever CCTV systems are operating we will place a notice showing that the scheme is in operation and controlled by Bromford.
Our CCTV systems deter crime and promote public safety by helping to identify and prosecute criminal offenders. These systems operate continuously and recordings are held for one month.
You can ask for a copy of any CCTV images taken of yourself by making a subject access request. See Your Data, Your Rights - the right of access for more details on how to make a subject access request.
We carry out an impact assessment for all locations where we use CCTV. This helps ensure that our use of CCTV is appropriate and proportionate to issues of crime and public safety we are seeking to address and minimises intrusion into individual rights to privacy.
Information we collect via our website
When you visit our website we collect standard internet log information, such as your IP address, host name, browser type and operating system.
Links to other websites
Our website may contain links to other websites of interest. If you follow a link from the Bromford website to an external site, we recommend that you check the privacy notice of that site before giving any personal details.
Complaints and enquiries
If you make a complaint or enquiry we may collect and store personal information in relation to it. We will keep your information secure and use it only for the purpose it was collected. When the complaint is resolved or the enquiry is completed, we will retain the information in accordance with our Data & Document Retention Policy and then destroy it.
How long we keep information
If you become a Bromford customer, information relating to your tenancy, lease or other contractual agreement will be kept for as long as the agreement is active or where money is owed on the account, and for a period not exceeding six years afterwards. The basic history of who occupied a property and when will be held forever.
If you do not become a Bromford customer information relating to your application will be held for up to five years after your application is withdrawn or refused.
When we dispose of information we do so securely.