This privacy notice covers the consented use of your photo and/or video image and/or personal information to be used by Sanctuary and its subsidiaries* in a variety of publicity materials and shared with staff and partners. This includes, but is not limited to:
- Press releases and website content e.g. news stories, resident stories, staff stories
- Social media content and videos e.g. Facebook, Twitter, LinkedIn and YouTube
- Staff and stakeholder communications e.g. emails, intranet, newsletters
- Printed and digital literature e.g. newsletters, leaflets, brochures, posters, pull up displays, advertisements
- Awards submissions
You are entitled to withdraw your consent for use of your information and/or image at any time. Residents who no longer live at a Sanctuary property, and staff who leave the company do not automatically have content deleted. To withdraw your consent, or opt out, email PR@sanctuary-housing.co.uk and provide your name and contact details, or call Sanctuary’s PR team on 01905 334596.
*Sanctuary, Sanctuary Care, Sanctuary Supported Living, Sanctuary Students, Sanctuary Scotland and Beech Grove Homes.
1. Purpose of our privacy statement
1.1 Under the Data Protection Act 2018 and the General Data Protection Regulation, 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 Housing Association 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 information that you provide to us on email or verbally over the phone or in person, is completely voluntary and not required by Sanctuary in order to provide our basic services to you.
5. What information are we collecting?
5.1 The only information which we are collecting about you is the information which you provide to us by email, over the phone or in person.
5.2 It is possible that some of the information which we collect will be special categories of personal data (also called sensitive personal data), which includes information about your health and racial or ethnic origin.
6. What we are going to do with your information
6.1 The information you provide to us will be used for the following purposes:
6.1.1 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 1998 and the General Data Protection Regulation;
6.1.2 It will be collected and used by us fairly and openly for the purpose of communications material promoting our services. This includes press releases, case studies, corporate documents such as Sanctuary’s value report, on social media channels and the Group’s website.
6.1.3 It will allow us to provide services which are tailored to your needs;
6.1.4 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 first language.
6.2 An understanding of your personal situation and individual needs will allow us to provide a tailored service that meets any physical, cultural or financial needs that you may have.
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 lawful 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 You have provided consent to our use of your information;
7.3 The lawful basis on which we rely in order to use your special categories of personal data which we collect about you will be that you have provided your explicit consent to our use of your information.
8. Sharing your information
Members of Sanctuary
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/about-sanctuary.
8.4 It may be necessary to share information about you with our contractors and sub-contractors in order to provide you with the services in accordance with the with the contract between us. We will only share information about you with the contractors and sub-contractors which is relevant and necessary to address your individual needs. The contractors and sub-contractors shall be contractually required to ensure that they adhere to the security requirements imposed by the Data Protection Act 1998 and / or the General Data Protection Regulation (as applicable).
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 behalf of us. 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.
Other organisations
8.7 We may from time to time share your information with other organisations, such as community partners, development contractors;
8.7.1 The police for the purpose of detection and prevention of crime;
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 European Economic Area.
10. Security of your information
10.1 The information that you provide will be stored securely on our systems. Any emails, written notes or hard copies of forms you complete with personal data will be stored securely before deleting or shredding after three years. 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.
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 store the personal data which you provide to us for a maximum period of three years unless you contact us to advise you want it to be removed.
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 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 (the “ICO”) if you are not satisfied with the way we use your information. You can contact the ICO by writing to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.