Sanctuary Supported Living owns buildings which are run and managed by other agencies. This privacy statement is for customers and applicants using these agency-managed services, detailing how we collect, process and use your information.
1. Purpose of our privacy statement
1.1 Under the Data Protection Act 2018 and the UK GDPR, we are required to explain to you why we are asking for this information about you, how we intend to use the information you provide and whether we will share this with anyone else.
2. Who are we?
2.1 We are Sanctuary Supported Living, a trading name of Sanctuary Housing Association and Sanctuary Affordable Housing Limited, both a part of Sanctuary Group (“Sanctuary”). We are one of the UK's leading providers of housing, care and commercial services. Our address is Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ
3. Our Data Protection Officer
3.1 Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
3.2 If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing dataprotection@sanctuary.co.uk.
4. Why are we collecting your information?
4.1 The majority of the information we collect is made up of the information provided to us by the managing agent of our properties. This information will usually be provided to us to assist in the management of your tenancy or license with us and to enable us to monitor the managing agent’s performance by:
- maintaining our accounts of rents and other payments you make;
- managing and approving any proceedings for possession or breach of your tenancy or license taken on our behalf;
- being aware of major incidents and accidents that occur in our properties;
- being aware of complaints and reports of anti-social behavior;
- retaining copies of your tenancy or license documents; and
- being made aware of requests for aids and adaptations in our properties.
4.2 We will also collect a limited amount of information that you provide directly to us. For example, if you make a complaint to us, we will use this information to respond to your complaints, in-line with our complaints process.
4.3 Some of the information we collect will also be special categories of personal data (also known as ‘sensitive personal data’), which includes information about your health and wellbeing.
5. What information are we collecting?
5.1 We will collect information from your managing agent for the purposes set out above in Section 4. Examples of this information are:
- your name, on copies of tenancy or license-related, adaptation-related and rent-related documents;
- relevant details of your needs in relation to assessing aids and adaptations requests and occupational therapists’ letters sent to us by the managing agent;
- financial records about payments relating to your tenancy, any outstanding amounts and associated recovery action;
- information on any proceedings taken for possession, or for breach of your tenancy or license with us;
- information provided to us in relation to complaints or anti-social behaviour that is relevant to your tenancy or license; and
- information about any repairs and maintenance requirements you have during your tenancy or license with us.
5.2 We collect the information you provide to us directly by:
- your contact with us in person;
- by telephone; and
- in electronic and written communications between us.
5.3 We have CCTV in operation at some of our locations; if there is CCTV in operation, there will be signs clearly visible to indicate that this type of recording is taking place. CCTV is only used in public areas.
6. What we are going to do with your information
6.1 The information provided to us will be used for the following purposes:
6.1.1 It will be collected and used by us fairly and openly for the purpose of monitoring the performance of our managing agent and to enable us to assist in the management of your tenancy or license with us; and
6.1.2 it will be stored and used by us in accordance with this privacy statement and also in accordance with your rights under the Data Protection Act 2018 and the UK GDPR.
7. What is the legal basis for using your information?
7.1 In accordance with the data protection laws, we need a "legal basis" for collecting and using information about you. There are a variety of different legal basis for processing personal data which are set out in the data protection laws.
7.2 The legal basis on which we rely on in order to use the information which we collect will be:
7.2.1 that it is necessary for us to take steps prior to entering into a tenancy or licence agreement with you, and to perform our contracts with you and with the managing agent once entered into; and
7.2.2 that it is necessary for us to comply with a legal obligation to which we are subject.
7.3 The legal basis on which we rely in order to use the sensitive information which we collect about you is:
7.3.1 for information about your health and any disability you may have, that it is necessary for us to assess your particular housing needs, so that we can comply with our obligations under social protection law and as a registered social landlord; and
7.3.2 that it is necessary to use that information to protect someone’s vital interests (which will usually be a ‘life or death’ situation).
8. Sharing your information
Members of Sanctuary Group
8.1 Sanctuary Group is made up of a number of related companies. We will share your information with other members of Sanctuary Group where necessary in order to best provide the services to you in accordance with the contract between us.
8.2 Your information will only be accessed by other companies in the Group where it is necessary to do so in order to provide services to you in accordance with our contract. The obligations which are set out in this notice shall apply to the other members of the Group to the same extent that they apply to us.
8.3 For more information on which companies make up Sanctuary Group, please go to www.sanctuary.co.uk.
Contractors and sub-contractors
8.4 It may be necessary to share information about you with our contractors and sub-contractors in order to provide you with housing services in accordance with the tenancy or licence agreement in place between us. We will only share your information about you with contractors and sub-contractors where it is relevant and necessary to address your individual needs. Our contractors and sub-contractors shall be contractually required to ensure that they adhere to the security requirements imposed by the Data Protection Act 2018 and / or the UK GDPR.
8.5 Our contractors and sub-contractors will not share your information with any other parties and will only be able to use the information when completing work on our behalf.
Regulators and other legal obligations
8.6 We may also be required to share your information with our regulators who are permitted access to this information by law and with other organisations where we have a legal obligation to share the information with them, for example, the Regulator of Social Housing.
Other organisations
8.7 We may from time to time share your information with other organisations, such as:
8.7.1 organisations with a function of auditing and/ or administering public funds for the purpose of detection and prevention of fraud;
8.7.2 the police for the purpose of detection and prevention of crime; and
8.7.3 local authority teams where this is necessary in relation to our responsibilities to you as a landlord, such as environmental health.
9. Transferring your information abroad
9.1 We will not transfer the information you provide to us outside of the UK.
10. Security of your information
10.1 The information that you provide will be uploaded, stored securely on our systems and the form that you complete will be shredded. Our security measures and procedures reflect the seriousness with which we approach security and the value we attach to your information.
10.2 Only relevant members of staff will access the information you provide to us and all staff are subject to duties of confidentiality.
11. Can we use your information for any other purpose?
11.1 In limited circumstances, we may use your information for a purpose other than those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.
12. Storing your information and deleting it
12.1 We will hold your information securely during the period of your tenancy or license and for a set period afterwards in line with legal requirements, best practice and any follow up that may be necessary. For example, we will retain your tenancy or license documents for six years after your tenancy end date, in-line with the Limitation Act 1980.
12.2 The exact periods that we hold your information for will depend on the type of information, as set out in our Group retention schedule.
12.3 Once the relevant set period set out in our retention schedule has come to an end, unless there is another identifiable reason for which it necessary to hold on to your information, we will delete your information.
13. Your rights
13.1 In relation to the information which we hold about you, you are entitled to:
13.1.1 ask us for access to the information;
13.1.2 ask us to rectify the information where it is inaccurate or is incomplete;
13.1.3 ask us to erase the information that is used on the basis of your consent and take steps to ask others who we have shared your information with to also erase it;
13.1.4 ask us to limit what we do with your information;
13.1.5 object to our use of your information and ask us to stop that use; and
13.1.6 instruct us to provide you with the information we hold about you in a structured and commonly used format or transmit that information directly to another organisation (for example, if you want the information to be sent to another housing provider or support provider).
13.2 Our obligations to comply with the above rights are subject to certain exemptions.
13.3 Where we are using your information because you have provided your consent to that use, you are entitled to withdraw your consent at any time. The lawfulness of our use of your information before consent was withdrawn is not affected.
13.4 To exercise any of the rights referred to above, you should contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing dataprotection@sanctuary.co.uk.
13.5 You also have the right to complain to the Information Commissioner's Office (ICO) if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.