Aim of this Policy
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.
We begin the process of collecting information about you and if appropriate your family when you apply to us either directly or through one of our referral partners.
Because the information you provide us is very personal we take your privacy & confidentiality very seriously.
We aim to keep your information as up-to-date as possible and will also ensure we make every possible effort to fulfil our obligations under the General Data Protection Regulation (GDPR) which came into effect on the 25th May 2018.
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, before it’s safely destroyed.
Who is responsible for your data?
We control the ways your personal data are collected and the purposes for which your personal data are used by Onward Homes and are the “Data Controller” for the purposes of the General Data Protection Regulations (GDPR) and UK Data Protection Bill (2017).
Information we may collect from you
We collect information from you via a variety of sources, including forms, phone calls, written communication or via digital methods. In particular we may collect and process the following data about you:
- Information that you provide by filling in forms on our Site. This includes information provided when registering an interest in a property, development, location or scheme, requesting a call back or booking a viewing, or when subscribing to digital communications. We may also ask you for information when you contact us via our Site, and when you report a problem with our site. If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
We will only collect and process personal information to conduct normal business activities, which comprise:
- Helping customers to register an interest in a property, development, location or scheme request a call back or book a home viewing
- Supporting marketing and promotion activities, for customers on our database or who opt in to our e-newsletters
- Improving the online features and services we offer
Information requested can include, but is not restricted to:
- Date of birth,
- National Insurance number (your unique identifier),
- Contact details (phone, e-mail or correspondence address).
- Details of anyone authorised to act on your behalf if applicable.
- Basic details of potential household residents.
- Banking details where necessary.
- Card details if you make any payments by card (however card details are not stored).
- Proof of housing eligibility, any interest or equity in other property.
- Other personal information that will vary on a case by case basis to help us resolve potential fraud.
The above information is required for us to enter into any contract with you. Without this information we would not be able to provide our services.
Additional information may be requested including:
- Disabilities or vulnerabilities.
- Financial information to provide assistance and advice on financial matters.
- Health information when we require this for example to support funding for adaptations made to properties.
- Photo ID, bank statements, payslips or income details for processing a house sale or purchase and in particular to assess affordability and comply with the Money Laundering Act (2018).
How and why we use your personal data
We use your personal data for the following purposes:
- When you first make an enquiry to us
- To process your application to rent or buy a home from Onward.
- To help you buy part or the whole of your home, including:
- Affordability checks
- Credit rating data
- To provide security:
- We operate CCTV systems, which collects and records images, and is used in accordance with CCTV Codes of Practice.
- When we process information about you on behalf of another organisation you receive services from
- We will receive the information we need to provide a service to you;
- We may get the information, or related information, from you or our partner organisations, your family, friends or neighbours, our staff or public information sources including credit reference agencies or the criminal records bureau;
- We may also record factual information whenever you contact us or use our services, so we have a record of what happened.
- To communicate with you and manage our relationship with you
- We may need to contact you by telephone, email and/or SMS for administrative or operational reasons;
- These communications are not made for marketing purposes and as such, you will continue to receive them even if you opt-out from receiving marketing communications;
- 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;
- Your opinion is very important to us, so we may send you an email or SMS to seek your feedback;
- 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.
- To personalise and improve your customer service experience
- We may use your personal data in order to tailor our services to your needs and preferences, and to provide you with a personalised customer experience e.g. if you inform us about your disabilities;
- 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;
- 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;
- You may choose to provide details of your friends, relatives or neighbours who you trust to contact us on your behalf;
- Your name and contact details for customer satisfaction surveys, newsletters and service information;
- With your consent, your name, photo, video or story could be used for brochures, advertising or press releases;
- Details about complaints about our service or other individuals, accidents or incidents involving you or your home;
- Your comments about our service or our suppliers’ services.
- To inform you about our news and service that you may like
- We may send you marketing communications, if you have indicated that you are happy to receive these, for example when you create an account on our website or apply for a property, and you do not express a wish to not receive such communications;
- If you are happy to receive marketing communications, we will provide you with news from us such as new developments that you may be interested in. In addition, if you are happy to receive marketing communications, we may send you communications promoting our partners’ products and services;
- Please note that we do not share your contact details and other personal data with other companies for marketing purposes, unless we have obtained your explicit consent to do so;
- If you do not want to receive marketing communications from us, you can simply tell us so. 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;
- 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 Data.Protection@onward.co.uk with the subject title “Unsubscribe”.
- To fulfil our administrative purposes and protect our business interests
- 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.
- To comply with our legal obligations
- For example, our obligation to provide your information to the Department for Works & Pensions & HMRC
What processing we do with information collected
The information we require from you is used to manage our services for you or any contract between us.
The processing activities we conduct can be summarised as:
- Helping customers to request a call back or book a home viewing
- Processing a house sale or purchase
- Supporting marketing and promotion activities
- Improving the online features and services we offer
We conduct surveys regularly and periodically relating to our services in order to gauge satisfaction and make improvements based on feedback.
Your Privacy Rights
The introduction of GDPR provides all UK citizens new and enhanced privacy rights, which Onward Homes are committed to upholding and takes its responsibilities regarding our customers privacy rights very seriously.
These include your rights to request that Onward Homes:
- Responds to your Subject Access Requests and confirm what personal data we hold about you, if any, and for what purposes;
- Changes the consent which you have provided in relation to your sensitive personal data, however you should be aware that by withdrawing consent Onward Homes may no longer be able to provide you with services that relate to the sensitive information you are no longer consenting to us processing;
- Corrects any inaccurate or incomplete personal data which Onward Homes holds about you;
- Provides you with a copy of your personal data for you to move elsewhere;
- Stop processing your personal data, whilst an objection from you is being resolved;
- 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;
- Responds to your objections about any automated decisions made about you using the personal data you’ve provided.
If you have questions in relation to exercising any of your Privacy Rights, please contact Onward Homes Data Protection Officer in the first instance at Data.Protection@onward.co.uk
If, for any reason, Onward Homes 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 to make a complaint. They can be contacted via their website or by telephone 0303 123 1113.
Security of your personal data
Onward Homes 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.
As detailed in this Policy, we may in some instances disclose your personal data to third parties. Where Onward Homes 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.
How we will communicate with you
Onward Homes needs to communicate with our customers and this will usually be in writing or by telephone, but is more commonly becoming electronic and paperless. We also operate an opt-in mechanism for receiving direct marketing. You may remove your consent to receive direct marketing or object about direct marketing to Data.Protection@onward.co.uk
What we will not do
- Send you unsolicited marketing material
- Sell your personal data on to third parties
- Pass on your personal data to unrelated third parties unless we are allowed or required to do so by law or we have your explicit permission to do that
- Transfer or store your personal data outside of Europe (the European Economic Area) outside of the control of the UK / European regulations
Third party links
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.