Privacy statement for customer involvement

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 Sanctuary Supported Living is a trading names of Sanctuary Housing Association, Sanctuary Affordable Housing Limited and Sanctuary Home Care Limited.

2.2 We are a part of Sanctuary Group (“Sanctuary”) 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 We will use your information, feedback and opinions in order to shape and scrutinise our services.

4.2 This information is completely voluntary and is not required by us in order to provide our core housing, care and support planning services.

4.3 The information that we use for resident involvement is the information collected:

• in the course of your resident scrutiny panel or community of interest interview;
• by telephone;
• by email;
• in your other electronic and written communications with us; and
• in the course of face-to-face contact with you.

4.4 If you are a resident or client, we will also use relevant personal information already stored by us in relation to our core services. When we do this, it is to avoid duplicating the collection of your personal information for the purposes of resident involvement.

5. What information are we collecting?

5.1 In the course of your application and recruitment to the resident scrutiny panel or a community of interest, we will collect the following information:

• relevant details of your skills and past experience; and
• relevant details which may affect your eligibility to participate in the resident scrutiny panel or community of interest, for example, relating to your tenancy or the services you receive from us.

5.2 In addition, we will use the following information for resident involvement which is already stored for the purposes of providing our core housing, care and support services:

• your name, address, date of birth and personal contact details;
• your self-identified gender, your self-described ethnicity and your religious beliefs in order to monitor the equality and diversity of our resident involvement; and
• your communication and language preferences.

5.3 Should you participate formally in the resident scrutiny panel or a community of interest, in addition to the information collected at interview and recruitment stage, we will collect:

• details of your participation in the resident scrutiny panel or a community of interest, such as the dates your involvement starts or the positions you hold;
• agendas and minutes of your contribution to panel or community of interest meetings;
• details of your contact and interactions with us in person, by telephone, by email and in your other electronic and written communications; and
• your bank account details, so we can reimburse you for expenses incurred in relation to your participation in resident involvement.

5.4 If you provide it to us, some of the information which we collect will be special categories of personal data (also called sensitive personal data), which might include information about your health and wellbeing.

6. What we are going to do with your information

6.1 Your information 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.

6.2 The information you provide to us will be used for the following purposes:

6.2.1 it will be collected and used by us fairly and openly for the purposes of involving  you in the scrutiny and shaping of our services in the following ways:

• recruiting you to our resident scrutiny panel or a community of interest; and
• through your participation in our resident scrutiny panel or a community of interest, and associated activities;

6.2.2 it may be published in minutes of resident scrutiny panel or community of interest meetings;

6.2.3 relevant details of your name, address, and contact details may be shared with the Housing Quality Network for the purpose of informing them about and accrediting the scrutiny-related activities in which you participate; and

6.2.4 it will allow us to make contact with you in the most appropriate way. For example, we can provide literature in large print if you have difficulty reading smaller print; or provide documents in an alternative language if English is not your preferred language.

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 in order to use the information which we collect about you for the purposes set out in this notice will be:

7.2.1 (for both non-sensitive and sensitive personal data) that you have provided explicit consent to our use of your information in this way; and

7.2.2 that using your information is necessary for us to comply with a legal obligation to which we are subject.

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 scrutinise and shape our future services.

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. 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, for example an external survey company,  in order to carry out our service review and scrutiny activities.   We will only share your information with contractors and sub-contractors where it is relevant and necessary to address your individual needs. Our contractors and sub-contractors are 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 your 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 Care Quality Commission or 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 the police for the purpose of detection and prevention of crime; and

8.7.2 organisations with a function of auditing and/ or administering public funds for the purpose of detection and prevention of fraud.

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 and 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 If your recruitment to our resident scrutiny groups and activities is not pursued further, we will delete and securely dispose of any personal information collected for this purpose immediately.

12.2 Should you participate in our resident scrutiny panel, communities of interests or associated activities, we will store your information for the period of your participation. After your participation ends, we will delete and securely dispose of your personal information which has been collected for the purposes of participation.

12.3 Any information you have provided in relation to the housing or care and support services you receive from us will be stored and deleted when no longer required, and our use of your information for our core services will be governed by a separate privacy statement.

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 provided 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;

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).

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.