Privacy Policy

1. Aim of policy1.1. In order to help provide you with the best and most appropriate service, we need you to help us by providing us with your detailed information.1.2. We begin the process of collecting information about you, and if appropriate your family, when you register with us either directly, via social media, or through one of our property portal partners.

   1.3. We aim to keep your information as up-to-date as possible so that when your needs change over time, the services we provide you can change to reflect these different needs. We will also ensure we make every possible effort to fulfil our obligations under the UK General Data Protection Regulation (GDPR).

   1.4. We will keep your personal information secure and only keep it as long as we need to, although please bear in mind we are legally obliged to keep some records for an extended period of time, such as housing benefit payment details, before it’s safely destroyed.

2. Who is responsible for your data?2.1. Our Privacy Policy applies to all the personal data that Onward Living collects and uses.2.2. References in this Privacy Policy to “we”, “us” or “our” mean Onward Living.

   2.3. Onward Living is a subsidiary of Onward Group. Colleagues are employed by Onward and will provide services to Onward Living. The information you provide is kept on Onward’s systems but it will be clear within those systems that you are a Onward Living customer.

   2.4. We control the ways your personal data are collected and the purposes for which your personal data are used by Onward Living and are the “Data Controller” for the purposes of the UK GDPR and Data Protection Act (2018).

3. What personal data do we collect about you?3.1. When using the term “personal data” in our Privacy Policy, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold.3.2. Your personal data may include, for example, your name, your contact details, or information on how you use our website and online services or how you interact with us.

   3.3. We collect some personal data from you, for example when you first use our website or contact us.

   3.4. We may collect and process the following categories of information about you, the majority of which will only be relevant if you progress to purchase:
   3.4.1. Your name and contact details for use across the organisation and by our contractors/suppliers;
   3.4.2. Detailed personal information, such as:

   a) Bank details
   b) Benefits
   c) Contact details of individuals who you want us to communicate with on your behalf
   d) Date of birth
   e) Employment details
   f) Family details
   g) Financial information (such as income, expenditure details)
   h) Lifestyle & social circumstances
   i) National identifiers (such as National Insurance Number)
   j) Nationality
   k) Relationship status
   l) Your particular needs and preferences, and how you use our services so that we can understand them better

4. How and why we use your personal data4.1. We use your personal data for the following purposes:
   4.1.1. Assessing your application to us for a property and to administer waiting lists
   4.1.2. To help you during the purchase process:a) Undertaking affordability checks;
   b) Assessing credit rating data.

   4.1.3. When we process information about you on behalf of another organisation you receive services from:

   a) We will receive the information we need to provide a service to you;
   b) We may receive information, or related information, from our partner organisations, your family, friends or neighbours, or public information sources including credit reference agencies or the criminal records bureau.

   4.1.4. To communicate with you and manage our relationship with you:

   a) We (including our contractors/suppliers) may need to contact you by telephone, email and/or SMS for administrative or operational reasons
   b) We will use your personal data if we contact you after you have sent us a request, filled in a web-form through our website or contacted us on social media;
   c) Your opinion is very important to us, so we may send you an email or SMS to seek your feedback;
   d) We will use the communications you exchange with us and the feedback you may provide in order to manage our relationship with you as our customer and to improve our services and experiences for other customers.

   4.1.5. To personalise and improve your customer service experience

   a) We may also collect information on how you use our website, which pages of our website you visit most, which online services you use, in order to understand what you like. We may use this information to tailor the content and services and, if you have agreed to receiving marketing communications, to send you relevant messages;
   b) If you are in the process of making a request under your account and you leave our website before your request has been completed, we may contact you in order to help you easily complete your request or make payment;
   c) Your name and contact details for customer satisfaction surveys, newsletters and service information;
   d) Voice recordings for quality management;
   e) With your written consent, your name, photo, video or story could be used for brochures, advertising,press releases or internal news stories;
   f) Your comments about our service.

   4.1.6. To inform you about our news and service that may be of assistance

   a) We may send you marketing communications for similar products or services, for example express an interest in a development or property, and you do not express a wish to not receive such communications;
   b) If you are happy to receive marketing communications, we will provide you with news and information such as new developments that you may be interested in;
   c) If you do not want to receive marketing communications from us, you can simply tell us so by clicking the relevant box before making your application. You can also choose to opt out from receiving marketing communications at any time, by clicking on the relevant unsubscribe link at the bottom of any marketing related email you may receive from us;
   d) If you prefer, you can also call our Customer Service team and express your preference to not receive marketing communications (Tel. 0300 555 0600) or send an email to Protection@onward.co.uk with the subject title “Unsubscribe” and details of the marketing received.

   4.1.7. To fulfil our administrative purposes and support our business interests

   a) The business purposes for which we will use your information include accounting, billing and audit, credit or other payment card verification, fraud screening, safety, security and legal purposes, statistical and marketing analysis, systems testing, maintenance and development.

   4.1.8. To comply with our legal obligations

   a) For example, our obligation to provide your information to HM Revenue and Customs (HMRC)

5. Your Privacy Rights5.1. The UK GDPR provides all UK citizens with specific privacy rights. Onward Living is committed to upholding these rights and takes its responsibilities regarding our customers privacy very seriously.5.2. These include, your rights to request that Onward Living:
   5.2.1. Responds to your Subject Access Requests and confirm what personal data we hold about you, if any, and for what purposes;
   5.2.2. Corrects any inaccurate or incomplete personal data which Onward Living holds about you;
   5.2.3. Stop processing your personal data, whilst an objection from you is being resolved;
   5.2.4. Permanently erase all your personal data promptly, and confirms this has been done, although there may be reasons why we may be unable to fulfil your request.

   5.3. If you have questions in relation to exercising any of your privacy rights, please contact the Data Protection Officer in the first instance at Protection@onward.co.uk

   5.4. If, for any reason, Onward Living does not address your request, or fails to provide you with a valid reason why it is unable to do so, you have the right to contact the Information Commissioner’s Office (ICO) to make a complaint. They can be contacted via their website www.ico.org.uk or by telephone 0303 123 1113.

6. Security of your personal data6.1. Onward Living are committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage. When you provide your personal data through our websites or online portal, this information is transmitted across the internet securely using appropriate strength encryption.6.2. As detailed in this Policy, we may in some instances disclose your personal data to third parties. Where Onward Living does disclose your personal data to a third party, we require that third party to have appropriate technical and organisational measures in place to protect your personal data; however in some instances we may be compelled by law to disclose your personal data to a third party, such as the Police, and have limited control over how it is protected by that party.

   6.3. The information that you provide us will be held in our systems, which are located on our premises or those of a contractually appointed third party. We may also allow access to your information by other third parties who act for us for the purposes described in this Privacy Policy or for other purposes approved by you. Your personal data may be accessed by and processed outside the UK – Where this occurs we require that appropriate safeguards are in place.

   6.4. We will retain your personal data for as long as we need it in order to fulfil our purposes set out in this Privacy Policy and in order to comply with appropriate laws and standards.

7. Sharing your personal data7.1. On occasions it’s in everyone’s best interests for us to share some of the information we have about our customers with other organisations. This may be to provide additional services, to fulifil a legal obligation or to ensure you get the best service possible.7.2. We may also provide some details to our contractors/suppliers, so they can contact you regarding a purchase.

   7.3. In exceptional circumstances we may feel it’s necessary to provide your details to the Police or the Local Authority Social Services Department where there has been a case of criminal activity, or we have concerns for any individuals health and safety.

   7.4. We’d like to stress that under no circumstances do we ever sell or pass on your information to business or organisations so they can get in touch with you directly either by phone, email or in writing in order to sell you their products or services.

   7.5. Listed below are the categories of third parties we may share some of your personal information with. Where required, we will ensure that any information sharing is supported by the UK GDPR compliant contract or there are appropriate information sharing protocols in place.

   7.5.1. Banks and Financial Service providers to process your application and secure payments;
   7.5.2. Contractors and suppliers who:
   a) Provide services on our behalf;
   b) Provide Technology & Telephony software, services & equipment;
   c) Provide printing and mailing services
   7.5.3. Credit Reference Agencies;
   7.5.4. External Auditors
   7.5.5. Insurance companies
   7.5.6. Solicitors
   7.5.7. Survey & Research organisations
   7.5.8. Utility companies

   7.6. In some cases we may also have a duty to disclose your information by law to:
   a) Central Government Departments
   b) Local Authorities
   c) Organisations who support crime prevention or detection, the prevention and detection of fraud, and for the purposes of the National Fraud Initiative

   7.7. Onward Living will not share or disclose your information with anyone who claims to represent you or be acting on your behalf unless we have verified you have appointed them or they are acting in some recognised official capacity.

8. Updates to our Privacy Policy8.1. We may make changes to our Privacy Policy from time to time. Any updates to the Privacy Policy will be published on our website where we will publish a new version of this Policy.
9. Contact information9.1. Any questions or requests regarding this Privacy Policy should be addressed to the Data Protection Officer at Protection@onward.co.uk