Clarion Housing Association Privacy Notice

We will only collect personal information when we need this. The type of information we need from you will vary depending on our relationship with you. When we ask you for information, we will make it clear why we need it. We will also make it clear when you do not have to provide us with information and any consequences of not providing this

Most information we hold will be collected from you but depending on your needs we may also obtain this from third parties such as:

• the local authority,
• your doctor (or other health professional),
• previous landlords,
• property agents
• solicitors and legal representatives
• financial advisers, mortgage advisers
• or other relevant community partner.

At times, we will also obtain information from publicly accessible sources or engage the service of market research organisations to validate, or where appropriate, enhance the information that we hold.

We collect information from you (as applicable):

To prioritise and assess housing applications, service eligibility and complete tenancy sign-ups:

• we will need your name and contact details (including telephone numbers, email addresses and details of anyone you may choose to represent you) for use across the organisation and by our contractors, suppliers and partners.
• we will collect detailed personal information about you and other household members*, including age, sex, date of birth, ethnicity, income, National Insurance number, income and benefits details, employment status, gender identity, relationship status, any disabilities, any communication and accessibility requirements, religion, sexuality, nationality, caring responsibilities, access to financial services such as banks and credit unions, bank details, benefits, council tax, medical information, details of any unspent criminal convictions.
  
  * When you provide information about household members we assume that you do so with their full knowledge and authority.
  
  Provision of the personal information requested by us is part of a ‘Contractual Requirement’. Without this information, we will be unable to accept an application for services. For example, we cannot see if you are eligible for a Tenancy or check that an application is not fraudulent without being able to verify your identity. Please speak to us with any concerns.
  
  Where enquiries relate to household members, it is in our legitimate interests to know who will be living in our premises to, check that accommodation offered is adequate for current and near future needs of the household, to check that household members’ needs are being met and to ensure that the local community will have quiet enjoyment of their homes.

To manage your tenancy or lease:

• we require up-to-date contact details (telephone number and email address) so we can reach you when we need to discuss issues pertaining to your tenancy or lease, e.g. income collection, essential servicing, access for maintenance and improvements, if we need to arrange a home visit or to contact you in the event of an emergency or to enforce the terms of your tenancy/lease.
• we will also use your contact information to tell you about changes to Clarion, for example our organisational structure and governance arrangements, and to resolve or investigate complaints or housing management issues such as anti-social behaviour.
• we require details of any change in circumstances (e.g. if you have a medical need that means your housing requirements need to be re-assessed we would ask you for supporting information about your change in health needs) or to effect any changes to your tenancy (e.g. if you want to change your name on our records we’ll ask you for a copy of your marriage or deed poll certificate).
• we will hold records of all our contact with you, your contact with us, and any contact from third parties representing you or about you. This may include call recordings.
• we will keep financial records about the amount of money you have paid us, any amount(s) outstanding and associated recovery action. Depending on your method of payment, we will hold your bank account details.
• where relevant we will hold information about your history, for example regarding credit status or offences, if we need it to look after our staff, business or anyone else.
• we will collect details relating to the repair, maintenance and servicing requirements of your home (although this information will not necessarily constitute your personal data).
• we will process your information if you choose to sign up for an online account in order for us to manage your account and provide you with a personalised online service.

Provision of the personal information is a ‘Contractual Requirement’. Without this information, we are unlikely to be able to manage your services. For example, we cannot consult with you about changes to your service if we do not hold your contact details. Please speak to us with any concerns.

Where enquiries relate to household members, it is in our legitimate interests to know who is living in the premises, to check that accommodation remains adequate for current and near future needs of the household, to check that household members’ needs are being met and to ensure that the local community has quiet enjoyment of their homes.

To meet your needs in our service delivery:

• to ensure our services are accessible, that we take account of any support needs in our dealings with you and to improve our communications with you. For example, if you are involved with a carer, social worker or other advocate, if there are considerations we need to apply when we visit you at home, if you need large print or translated text.
• when profiling you for services and to target our resources.
  
  At times, where processing information about you or your household members, we will have a legal or contractual obligation to process this information for example to provide inclusive services.
  
  It is also in our legitimate interests to ensure that service delivery meets the needs of you and your household.

To prevent fraud and illegal sub-letting and to confirm eligibility for housing:

• We will verify your identity and, dependent on your type of housing, we will ask for proof of ID and take your photograph from time to time, e.g. Tenancy Sign-ups or subsequent Tenancy Audits, when the housing composition changes or a reasonable period of time has passed (this applies to all household members over the age of 18). Depending on your service/needs, we will also require proof of bank details and/or source of funds.
  
  Processing for the purpose of fraud prevention is required in order to meet our legal obligations. Therefore if we are unable to verify your identity we will not be able to provide services to you.

To assist with personal security and prevention and detection of crime:

• we will capture your image on our CCTV systems if you visit an estate, office or community facility which is covered by this facility.
  
  It is a legitimate interest of the organisation to process this data to protect its property, assist with police with their investigations and to safeguard the health and safety of staff and visitors.

To manage the legal process if you apply to buy your home, purchase a further percentage in your Shared Ownership property or want to access another home ownership route:

• Provision of information requested for this purpose is required in preparation for entering into ‘contractual relations’. Without this information, we will be unable to manage this legal process.
  
  Where the processing of information concerns household members, it is in our legitimate interests to do this. E.g. to ensure we understand all legal effects that a process may have.

To facilitate your participation in local or Government schemes as applicable:

• For example, if you participated in the Voluntary Right to Buy Midlands Pilot, which enabled eligible tenants to apply to purchase their homes, relevant information was shared with the Department for Levelling Up, Housing and Communities (DLUHC) and processed in line with their privacy notice.
  
  Provision and sharing of this information, should you chose to apply, is necessary for the performance of a task carried out in the public interest to meet a function of the Crown, a Minister of the Crown or a government department.

When you engage with our or our group companies' additional guidance, advice and support services: (Please remember, other privacy notices may apply)

• For example if you engage with Clarion Futures, Clarion Futures will hold information about you as set out in its privacy notice.
• If you ask us for support, we will hold detailed information about your needs and your family’s needs and where relevant, records of payments for the services provided to you. This may form part of a 'Contractual Requirement' if we require the information in order to provide services to you or it may be in our legitimate interest to ensure that we are holding information about you which enables us to offer you services to meet the support you need. We will make it clear at the point of data collection whether the information is voluntary
• We may occasionally write to you about the support we and our group companies can offer to you and your household members. Where we do so, this will be in line with our legal obligation under the Regulator of Social Housing's consumer standards which require that we provide you with information about how to access services that we offer.

To understand how we’re performing:

• we undertake call recordings for training and quality monitoring purposes.
• we use your contact details to carry out market research and customer satisfaction surveys to help us to monitor our performance and to improve our services to our customers. When we collect your data through research and surveys, we may anonymise this. At this time, many of our surveys are carried out by The Leadership Factor (TLF). We also use Trustpilot to request feedback following different types of customer contact to enable us to monitor and improve services. This means we will share your name and email address with Trustpilot for this purpose. You can see their Privacy Notice here. If you choose to provide a review, we may also use such reviews in promotional material and media for our advertising and promotional purposes.
• in managing and analysing complaints.
• to monitor and understand the success of our email communications to see if our messages are getting through and help us improve how we communicate with our customers.
• to manage our website and monitor our website usage so we can make our website better.
• for statistical analysis.
  
  It is in our legitimate interests to understand how we are performing so we can meet our Group purpose and mission.
  
  At times, there is also legal obligation for us to process the information or to demonstrate to our regulator that we are fulfilling our obligations, for example around anti-discrimination laws or in line with the consumer standards set by the Regulator of Social Housing.

We also use your personal information in the following ways:

• We will place customers into segments based on information we know about you (such as your age, tenancy type, household makeup, account balance, and whether you are in receipt of benefits ), and use learning that we have gathered from research and surveys, to help target our resources and prioritise services. We do so based upon our legitimate interests in ensuring that we are providing you with targeted support, assistance and communications.
• Keeping in touch with you, understanding your needs, telling you about Clarion news, performance and services that you may benefit from, informing you of relevant opportunities (for example to purchase your home or purchase additional shares of a shared ownership home), and inviting you to events.
  
  It is in our legitimate interests to communicate with you and keep you up to date with news and events in order to meet our objectives around social inclusion and helping to build communities. Communicating with you about support that Clarion and its group companies can offer you can also be in line with our legal obligations set by the Regulator of Social Housing in its consumer standards. We will let you know if you have the option to opt out of receiving communications.
• Meeting our legal obligations including the requirements of our funders or regulators.
  
  This is a legal obligation on Clarion.
  
  Where relevant we also process confidential data about you including bank account information and property access codes.

Automated decision-making and profiling

There are some occasions where our computer systems are set up to use pre-programmed criteria to make automated decisions about you, for example determining your position on a housing waiting list, eligibility for a mutual exchange or assessing your affordability and/or eligibility for the purchase of a shared ownership home. Where there is no human intervention (no staff involvement in the decision process) and this has a legal or significant effect on you, you have a right to challenge the validity of any decisions made in this way and / or to ask us not to process your information in this way. Please contact us for more detailed information or to find out if you meet the criteria to opt out.

Clarion also use profiling to segment our customers into groups of people with similar characteristics using information that we know, along with learning from anonymous surveys in order to help us target resources and improve services. We have strict rules in place around how segmentation can be used and are committed to only using this in a way that positively benefits our customers and the organisation. However, if you would like to opt out, you can contact us at CustomerServices@myclarionhousing.comto do so.

Clarion sometimes processes special category personal data about you. Special categories of personal data are: racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a person's sex life or sexual orientation. Criminal Offence data is information that relates to criminal convictions or offences including cautions.

Where Clarion processes this type of data about you, it will do so:

• With your consent;
• Where we need to protect the vital interests (i.e. the health and safety) of you or another person;
• Where you have already made your personal information public;
• Where we or another person needs to bring or defend legal claims; and/or
• Substantial public interest grounds.

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.

We use this special category data to ensure services are delivered appropriately and to monitor equality, diversity and inclusion. In the case of certain health information, this will be needed for health and safety purposes and/or social protection.

We will apply additional security and confidentiality measures when processing your special category and criminal offence data.

Where provision of this information is optional, we will make this clear at the point of collection and we will ask for your specific informed consent at the time of collecting this type of data.

Where you provide consent for us to process sensitive personal information, you have the right to withdraw this consent at any time.

There will be times when we will not need your consent to process (including sharing) this type of data. This will apply where we are permitted or required to do so by law, for example under Health and Safety Legislation or where processing of this data is necessary in order for us to carry out our obligations under Social Protection Law.

We will apply appropriate technical and organisational measures to protect your personal information. For example, we have systems in place to ensure that access to personal information is restricted to authorised individuals on a strictly need-to-know basis.

When we need to share personal data with our contractors, third party suppliers and business partners, our relationships are governed by our contracts with them which include strict data sharing and confidentiality protocols.

To help us ensure confidentiality of your personal information we will ask you (and any of your representatives) security questions to confirm your identity when you call us and as may be necessary when we call you. Apart from where the law permits or requires us to do so, we will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so, there is a court appointed deputyship or Power of Attorney or where we have received a clear verbal instruction from you (as a one-off circumstance).

Sometimes we need to share personal information we hold about you with other organisations that we work with or who provide services on our behalf. When sharing information, we will comply with all aspects of data protection law.

Where ‘sharing’ is in our legitimate interests, we will share your information with:

• Our contractors to facilitate repairs, maintenance or improvement works.
• Other organisations in the Clarion Housing Group.
• Debt and money management advisers.
• Local authority teams such as housing, social services, environmental health and benefit agencies.
• Utility companies (and their representatives) and Council Tax Departments, to ensure billing details are correct.
• Independent mortgage advisers and solicitors.
• Third parties providing services on our behalf. For example, a mailing company distributing our newsletter; a research company such as ‘The Leadership Factor’ (TLF) carrying out a customer satisfaction survey, or a debt collection agency pursuing former tenant arrears.

We are also legally permitted to share your information with organisations such as:

• Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative. More information can be found on the work undertaken by the Cabinet Office.
• Police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime, the apprehension of offenders or the collection of tax or duty.
• Other statutory organisations e.g. social services, health authorities, Homes England, the Greater London Authority (GLA), the National Housing Federation, as necessary for exercising statutory functions.
• The Housing Ombudsman.
• Council Tax Departments to ensure billing details are correct.

We also share information when required by law, for example, where ordered by the Court or to protect an individual from immediate harm.

There will be occasions where we need to process your information outside the European Economic Area (EEA), for example, where we use a third-party computer system supported by employees in the USA. Where we do this, we will take all necessary steps to ensure that your information remains secure. You can ask us for more information about how our International Processing arrangements affect you by using the contact details above.

Clarion only holds records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations including resolving any follow-up issues between us.

We have a document retention schedule which sets out how long we keep different types of information for. This is based on National Housing Federation guidance, legal requirements and best practice. Please contact us if you would like any more information.

Clarion only holds records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations including resolving any follow-up issues between us.

Generally we will remove all personal information from your account 6 months after your account remains untouched unless you have asked us to delete your information prior to this date. If you go on to purchase a property we will retain relevant information and you will be re-issued with a new Clarion Housing Group Privacy Notice which will explain how we will process and store your information.

Clarion is committed to upholding your rights in respect of your personal data.

The right to be informed

Through the provision of our suite of privacy notices, we will be open and transparent about how and why we use your personal information.

The right of access

You have a right to ask us what personal information we hold about you and to request a copy of your information. This is known as a ‘subject access request’ (SAR).

The best way to do this is to put your request in writing or ask us for a copy of our template form. When a Subject Access request is made, we will take reasonable steps to verify your identity before we can proceed so you may wish to submit a copy of your photo ID with your request to save time.

If you are seeking to obtain specific information (e.g. about a particular matter or from a particular time period), it helps if you clarify the details of what you would like to receive in your request. Very broad requests are likely to require clarification so we can make sure we know what information you require.

If someone is requesting information on your behalf, they will need written confirmation from you to evidence your authority for us to release this and proof of ID (both yours and theirs).

Where you are unable to put your request in writing, you can contact the Data Protection Team to arrange for your request to be documented on your behalf.

If you choose to make a verbal SAR request, please contact the Contact Centre and request a call back from the Data Protection Team. We aim to contact you within 2 working days and will then send you a copy of the request to verify and attach ID before we start processing your request.

We have 1 calendar month to provide you with the information you’ve asked for, unless your request meets the criteria for extension (although we will try to provide this to you as promptly as possible). In response to SARs, we will provide you with a copy of the information we hold that relates to you.

Property information such as details of contractor visits, surveys, or general property maintenance information is unlikely to constitute your ‘personal information’. If you ONLY require property-related information, you do not need to submit a SAR – you can just contact our Contact Centre.

The right to rectification

You can ask us to rectify your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by keeping us informed if your details change.

The right to erasure

The right to erasure is also known as ‘the right to be forgotten’. In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for its continued processing. This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data. Our response will also be guided by the provisions of our retention schedule.

The right to restrict processing

In some circumstances, you can ask us to restrict processing, for example:

• if you disagree with the accuracy of personal data
• if we’re processing your data on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate interests override those of yours.

The right to data portability

If the situation arises where it would be helpful for you to move, copy or transfer personal data we hold about you, across different services, you may be able to ask us to do this. Please contact us to discuss.

The right to object

You can tell us if you object to our processing of your personal data:

• based on legitimate interests (including profiling) or for the purpose of historical research purposes. This is not an absolute right and we will need to consider your objection.
• for the purpose of direct marketing (including profiling).

Rights in relation to automated decision-making and profiling

Where a decision which has legal or significant effect on you is made solely by way of automated means (i.e. there is no human intervention in a computer’s decision) you have the right to object to this and depending on the reason for processing, either ask that we stop doing this or we show that we have implemented suitable measures to protect you, for example by explaining how the decision has been made and checking that the system is set up and functioning correctly.

If you’d like to talk to us about your rights, you can contact us at dataprotection@clarionhg.com. Alternatively, if you want to raise a complaint about our processing of your data or would like to seek an independent view, you can contact the Information Commissioner using the contact details provided at the start of this notice.

As a website user, we will collect:

• Information about your computer and about your visits to and use of this website (including your IP address, your cookie preferences, geographical location, browser type, referral source, length of visit and number of page views);
• Information relating to any transactions carried out between you and us on or in relation to this website;
• Information that you provide to us for the purpose of registering with us or subscribing to our website services including name, address, email, telephone number and, where relevant, the type of property you are looking for;
• Any other information that you choose to send to us.

We will use this to:

• Administer the website and improve your browsing experience by personalizing the website;
• Provide relevant website services, for example, raising a request for us to contact you, to report a complaint and to make payments;
• Monitor the usage of the website to help us improve our services;
• Produce anonymous statistical information about our website users to help us develop our website and services;
• Deliver tailored advertising to you, on and off our website.

If at any time you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the permission you grant to us.

We also use third-party cookies and where necessary will share information about your use of our site with our trusted advertising, analytics, and social media partners.

Clarion is not responsible for the privacy policies or practices of third-party websites accessed through links on our site.

Cookies are small text files that are sent by websites that you visit for a number of purposes, including to make those websites work, or work more efficiently, and to recognize who you are when you return there. The files are stored on your computer’s hard drive and are read by your web browser. For more specific information on the cookies used on our website and the easiest way to manage these, please click on ‘Cookie Policy’ or ‘Manage Cookies’ in the footer of our website (www.myclarionhousing.com).

Alternatively, you can set your browser so that it will not accept and store any cookie, or if you have a little more time and knowledge, you are able to allow only certain ‘trusted’ sites to store cookies on your computer.

For further general information, visit: allaboutcookies.org or aboutcookies.org.

At Clarion Housing Group, we are committed to the highest standards of quality, probity, openness and accountability. As part of this commitment, we expect honesty and integrity from our staff, contractors and suppliers. We encourage people with concerns about any aspect of our work to come forward and report them.

Concerns that should be raised under our whistleblowing process include:

• Criminal offences
• Breaches of any legal obligation
• Miscarriages of justice
• Danger to the health and safety of any individual
• Damage to the environment
• The deliberate concealing of information about any of the above

If you wish to raise a concern, you can do so by emailing us at whistleblowing@clarionhg.com or by calling 0300 345 9012. You can do this anonymously if you prefer.

If you prefer to write to us with your concerns, please use the following address marked "for the attention of the Whistleblowing Officer":

Clarion Housing Group
5th Floor
Greater London House
Hampstead Road
London NW1 7QX

All concerns will be treated fairly and properly, and any disclosures will be treated in a confidential and sensitive manner.

Please note, if your report is not related to whistleblowing, or is related to tenancy fraud, you should instead contact customerservices@myclarionhousing.com or use one of the alternative ways of contacting us. We will be unable to provide any updates regarding reports that are not about whistleblowing, but we will forward any such reports to the appropriate team for handling.

We will only collect personal information when we need (this). The type of information we need from you will vary depending on our relationship with you. When we ask you for information, we will make it clear why we need it. We will also make it clear when you do not have to provide us with information and any consequences of not providing this.

Most information we hold will be collected from you, but we may also obtain this from third parties such as the local authority, your doctor (or other health professional), a previous landlord or other relevant community partner. This will generally be as a result of a discussion that we have with you. In addition, we may also obtain information from publicly accessible sources or engage the service of market research organisations to validate, or where appropriate, enhance the information that we hold.

We collect information from you (as applicable):

To prioritise and assess applications for services and to check for eligibility:

• we will need your name, address, and contact details (including telephone numbers, email addresses and details of anyone you may choose to represent you) for use by Clarion Futures and our partners.
• as required we will collect detailed personal information about you and other household members*, including age, sex, date of birth, ethnicity, income and expenditure, National Insurance number, income and benefits details, employment status, gender identity, relationship status, any disabilities, any communication and accessibility requirements, religion, sexuality, nationality, caring responsibilities, access to financial services such as banks and credit unions, bank details, benefits, council tax, medical information, details of any unspent criminal convictions.

* When you provide information about household members, we assume that you do so with their full knowledge and consent.

Provision of information is voluntary (with the exception of Government mandated programmes such as ‘The Work Programme’ where the Government require participation and therefore the provision of relevant information), however without this information, we may not be able to provide this service. We will make it clear at the point of data collection whether the information is optional. For example, we cannot provide services to you if you do not give us your contact details. Please speak to us with any concerns.

Where enquiries relate to household members, it is in our legitimate interests to check that support offered to you is adequate for current and near future needs of the household and to check that household members’ needs are being met.

To manage your service:

• we require up-to-date contact details (telephone number and email address) so we can reach you when we need to discuss issues pertaining to your service or tenancy, e.g. to offer you advice, request further information, tell you about other support options open to you directly linked to your needs, follow up on the progress of a service or if we need to arrange a home visit.
• we may require information relating to ongoing support requirements which could include your employment, health or finances, for example.
• we will also use your contact information to tell you about changes to Clarion Futures and Clarion Housing Group, for example our organisational structure and governance arrangements, and to resolve or investigate complaints.
• we require details of any change in circumstances (e.g. if you move house and are in a location dependant service that means your service requirements need to be re-assessed).
• we will hold records of all our contact with you, your contact with us, and any contact from third parties representing you or about you. This may include call recordings.
• we may hold information about your history, for example regarding credit status or offences, if we need it to look after our staff, business, or anyone else or if this is relevant to advice or services offered.

Provision of information requested by us is voluntary (with the exception of ‘The Work Programme’ where the Government require participation and therefore the provision of relevant information); however, without this information we may not be able to provide this service. We will make it clear at the point of data collection whether the information is optional. For example, we would be unable to support you with an application for charitable support if you do not provide details of the benefits you are in receipt of. Please speak to us with any concerns.

Where enquiries relate to household members, it is in our legitimate interests to check that support offered to you is adequate, as explained above.

• To meet your needs in our service delivery
• to ensure our services are accessible, that we take account of any support needs in our dealings with you, and to improve our communications with you. For example, if you are involved with a carer, social worker or other advocate, if there are considerations we need to apply when we visit you at home, if you need large print or translated text.
• when profiling you for services and to target our resources.

Where processing information about you or your household members, we may have a legal or contractual obligation to process this information, for example to provide inclusive services.

It is also in our legitimate interests to ensure that service delivery meets the needs of our service user and their household.

• To prevent fraud and confirm eligibility for certain services
• we will ask for proof of ID and supporting information.

Processing for the purpose of fraud prevention is required in order to meet our legal obligations. Therefore, if we are unable to verify your identity, we may not be able to provide services to you.

• To assist with personal security and prevention and detection of crime, we may capture your image on our CCTV systems if you visit an estate, office, or community facility which is covered by this facility.

Processing of this information may be required to meet our legal obligations and our legitimate business interests around health and safety and crime prevention.

To understand how we are performing:

• we may undertake call recordings for training and quality monitoring purposes.
• we may use your contact details to carry out market research and customer satisfaction surveys to help us to monitor our performance and to improve our services to our customers.
• to segment customers to help target our resources and prioritise services.
• in managing and analysing complaints.
• for statistical analysis.

It is in our legitimate interests to understand how we are performing so we can meet our mission statement and objectives.

There may also be a legal obligation for us to process the information or to demonstrate to our regulator that we are fulfilling our obligations, for example around anti-discrimination laws.

We also use your personal information in the following ways:

• Keeping in touch with you, understanding your needs, and inviting you to events.

It is in our legitimate interests to communicate with you and keep you up to date with news and events in order to meet our Group objectives around social inclusion and helping to build communities.

• Prevention and detection of crime, and quality management.

We do this to meet our legal obligations.

• Meeting our legal obligations, including the requirements of our funders or regulators.

This is a legal obligation on Clarion.

Automated decision-making and profiling

We do not undertake automated decision-making or profiling which has legal or similarly significant effect on you (where a computer system makes a decision about you without human intervention, e.g. deciding if you are eligible for a loan). We do use software tools, but any decisions about you are made by our staff rather than ‘automated’. Should this change in the future, we will inform you and explain your rights relating to this, for example that you have the right to challenge the validity of any decisions made in this way or object to automated decision-making and ask us not to use this method of processing.

As well as personal information (such as your name, address and data of birth) we may collect sensitive personal information (also known as special categories of data) of which may include:

• Racial or Ethnic origin
• Religious or Philosophical Beliefs
• Sexual Orientation
• Health information

We use this data to ensure services are delivered appropriately and to monitor Equality, Diversity and Inclusion.

We will apply additional security and confidentiality measures when processing special categories of data.

We will ask for your specific informed consent to process this data at the time of collection (unless we permitted or required to do so by law, for example under Health and Safety Legislation).

Where you provide consent for us to process sensitive personal information, you have the right to withdraw this consent at any time.

We may also process confidential data about you including bank and / or financial account information.

We will apply appropriate technical and organisational measures to ensure your personal information is secure. For example, we have systems in place to ensure that access to personal information is restricted to authorised individuals on a strictly need-to-know basis.

When we need to share personal data with our contractors and third party suppliers, our relationships are governed by our contracts with them which include strict data sharing and confidentiality protocols. Where we are working in partnership, we will ensure that Information Sharing Agreements govern the sharing of data.

To help us ensure confidentiality of your personal information we will ask you (and any of your representatives) security questions to confirm your identity when you call us and as may be necessary when we call you. We will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so, where we have received a clear verbal instruction from you (as a one-off circumstance) or where there is a legal order in place such as a Power of Attorney.

Sometimes we need to share personal information we hold about you with other organisations that we work with or who provide services on our behalf. When sharing information we will comply with all aspects of data protection legislation.

Where the information is of a sensitive nature, for example about your health, we will obtain consent from you prior to sharing this information, unless we are required or permitted to share this by law.

Where ‘sharing’ is in our ‘legitimate business interests’, we may share your information without seeking your consent first. This may be with:

• Other organisations in the Clarion Housing Group and contracted delivery partners
• Debt and money management advisers.
• Local authority teams such as social services, environmental health and benefit agencies.
• Utility companies (and their representatives) and Council Tax Departments to ensure billing details are correct.
• Third parties providing services on our behalf. For example, a mailing company distributing our newsletter; a research company carrying out a customer satisfaction survey, or a debt collection agency pursuing former tenant arrears.
• Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative. More information can be found on the work undertaken by the Cabinet Office at: https://www.gov.uk/government/collections/national-fraud-initiative
• Police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime, the apprehension of offenders or the collection of tax or duty.
• Other statutory organisations e.g. social services and health authorities as necessary for exercising statutory functions.

We may also share information when required by law, for example where ordered by the Court or to protect an individual from immediate harm.

There may be occasions where we need to process your information outside the European Economic Area (EEA), for example where we use a third party computer system supported by employees in the USA. Where we do this, we will take all necessary steps to ensure that your information remains secure. You can ask us for more information about how our International Processing arrangements affect you by using the contact details above.

We will routinely use your contact details to send you relevant information and communicate with you about the Clarion Futures service as a whole. This is to ensure that you don’t miss out on any of the offerings which Clarion Futures provides because one area of support is often associated with another. For example, receiving digital support may lead to training opportunities. As a customer, we will also tell you about events in your area. During our work with you, we may establish other areas of support that one of our partners could deliver. We will talk to you about this and send you relevant communications about these as appropriate.

We would also like to keep you updated with information about other products and services (of ours and other reputable companies we work with) which do not form part of our core services but that we think may be of interest to you and where this will assist us in meeting our Group objectives to transform lives and communities. This could include information about events run by Clarion Housing Association. It’s a legitimate business interest for us to send you postal communications (from time to time) which may comprise information about all these areas of our work. You can object to receiving this type of content from us in the post. Before sending electronic communications of this nature, we will follow the law and guidance which requires us to seek your consent. You can change your mind at any time. Please just contact us or follow the ‘unsubscribe’ instructions that will be available on all of our promotional publications.

Neither Clarion Futures, nor Clarion Housing Group will ever sell your personal data to 3rd party organisations for marketing purposes.

Clarion Futures only holds records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations, including resolving any follow-up issues between us. This is currently set at 2 years, after which we will delete your personal information unless our contracts with funders require us to keep this longer. You can contact us to see if this applies.

Clarion Futures is committed to upholding your rights in respect of your personal data.

The right to be informed

Through the provision of our suite of privacy notices, we will be open and transparent about how and why we use your personal information.

The right of access

You have a right to ask us what personal information we hold about you and to request a copy of your information. This is known as a ‘subject access request’ (SAR).

The best way to do this is to put your request in writing or ask us for a copy of our template form. When a Subject Access request is made, we will take reasonable steps to verify your identity before we can proceed so you may wish to submit a copy of your photo ID with your request to save time.

If you are seeking to obtain specific information (e.g. about a particular matter or from a particular time period), it helps if you clarify the details of what you would like to receive in your request. Very broad requests are likely to require clarification so we can make sure we know what information you require.

If someone is requesting information on your behalf they will need written confirmation from you to evidence your authority for us to release this and proof of ID (both yours and theirs).

Where you are unable to put your request in writing, you can contact the Data Protection Team to arrange for your request to be documented on your behalf.

If you choose to make a verbal SAR request, please contact the Contact Centre and request a call back from the Data Protection Team. We aim to contact you within 2 working days and will then send you a copy of the request to verify and attach ID before we start processing your request.

We have 1 calendar month to provide you with the information you’ve asked for (although we will try to provide this to you as promptly as possible). In response to SARs, we will provide you with a copy of the information we hold that relates to you.

The right to rectification

You can ask us to rectify your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by keeping us informed if your details change.

The right to erasure

The right to erasure is also known as ‘the right to be forgotten’. In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for its continued processing. This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data. Our response will also be guided by the provisions of our retention schedule.

The right to restrict processing

In some circumstances you can ask us to restrict processing, for example

• if you disagree with the accuracy of personal data
• if we’re processing your data on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate interests override those of yours.

The right to data portability

If the situation arises where it would be helpful for you to move, copy or transfer personal data we hold about you, across different services, you may be able to ask us to do this. Please contact us to discuss.

The right to object

You can tell us if you object to our processing of your personal data:

• based on legitimate interests (including profiling) or for the purpose of historical research purposes. This is not an absolute right and we will need to consider your objection.
• for the purpose of direct marketing (including profiling);

Rights in relation to automated decision-making and profiling

Where a decision which has legal or significant effect on you is made solely by way of automated means (i.e. there is no human intervention in a computer’s decision) you have the right to object to this and depending on the reason for processing, either ask that we stop doing this or we show that we have implemented suitable measures to protect you, for example by explaining how the decision has been made and checking that the system is set up and functioning correctly.

If you’d like to talk to us about your rights, you can contact us at dataprotection@clarionhg.com. Alternatively, if you want to raise a complaint about our processing of your data or would like to seek an independent view, you can contact the Information Commissioner using the contact details provided at the start of this notice.