Privacy statement - Supported Housing

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 Supported Living, a trading name of Sanctuary Housing Association, Sanctuary Affordable Housing Limited and Sanctuary Home Care Limited, each 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 data.protection@sanctuary-housing.co.uk.

4. Why are we collecting your information?

4.1 At application stage, we will use information provided to us in order to assess the suitability of our service for you and to understand your needs.

4.1.1 The information that is used at application stage is the information provided to us:

  • on an application form
  • on other supplementary information forms if needed;
  • during initial meetings with us;
  • by telephone; and
  • in your electronic and written communications.

4.2 Should you become a client of ours, we will use your personal information to provide you with personalised services in relation to:

  • your care and/or support;
  • risk management; and
  • management of your tenancy or license with us. 

4.2.1 The information that is used should you become a client of ours is the information provided during the application stage and information provided during on-going:

  • face-to-face meetings and interactions;
  • telephone calls; and
  • electronic and written communications.

5. What information are we collecting?

5.1 During your application for our services, we will collect the following information:

  • your name, date of birth and personal contact details;
  • your National Insurance number;
  • your language preferences and communication needs;
  • the gender you identify as;
  • the ethnicity you describe yourself as belonging to;
  • your religious beliefs;
  • whether anyone acts on your behalf and you whether you have capacity.
  • your income and financial health;
  • any cautions or unspent convictions you may have.
  • your housing history, including any arrears or debts you may owe;
  • relevant details of your family, including your marital status, whether you have any children or whether you are pregnant;
  • details in relation to your health; and
  • relevant details of your personal life and any care or support requirements you may have.

5.2 Should you become a client of ours and receive services from us, we will use the information provided during your application in order to provide you with our services. We will also collect the following information to support you in managing your tenancy or license and to provide you with our care, support and action planning services:

  • the contact details of next of kin, relatives and other named contacts;
  • images of you to assist us to co-ordinate and personalise your care and support;
  • details in relation to your care and/or support requirements, including progress against your personalised outcomes;
  • details in relation to your well-being, physical, and mental health;
  • details of your contact and interactions with us in person, by telephone and in electronic and written communications;
  • information provided by third parties in relation to complaints or anti-social behaviour that is relevant to your care and support, risk management or tenancy support;
  • financial records about payments relating to the housing and services you receive from us, any outstanding amounts and associated recovery action; and
  • information about any repairs and maintenance requirements you have during your tenancy with 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 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 1998 and the General Data Protection Regulation.

6.2 At application stage, the information provided 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 purpose of assessing the suitability of our services for you and understanding your care and/or support requirements; and

6.2.2 it will be used to ensure that our services are fair and accessible to all.

6.3 Should you become a client of ours, the information provided to us will be used for the following purposes:

6.3.1 collected and used by us fairly and openly to support you in managing your tenancy with us and to provide you with care and/or support services; and

6.3.2 used to understand your personal situation and individual requirements so we can provide a tailored service that meets any cultural, financial, learning, mental or physical needs that you may have. It will also be used to improve the services you receive from us.

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 bases for processing personal data which are set out in the data protection laws.

7.2 The lawful bases on which we rely in order to use the information which we collect about you to at application stage and should you become a client of ours are:

7.2.1 using special categories of information about your health, personal life and any care or support needs you may have is necessary in relation to providing health or social care;

7.2.2 using your information in this way is necessary for us to take steps at your request prior to entering into a contract and to perform the contract between us;

7.2.3 you have provided explicit consent to our use of your information. There is a limited amount of special category information that we use on the basis of your consent. We will inform you prior to collecting or processing your information based on consent and keep a record of your consent;

7.2.4 using your information is necessary for us to comply with a legal obligation to which we are subject; and

7.2.5 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-group.co.uk/about-us.

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 the services in accordance 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. For example, the Regulator of Social Housing and, in our registered services, the Care Quality Commission.

Other organisations

8.7 We may from time to time share your information with other organisations, such as:

8.7.1 utility companies so they can provide services to you and contact you in respect of utility charges, if you are a resident of a Sanctuary property;

8.7.2 the police for the purpose of detection and prevention of crime;

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

8.7.4 local authority teams such as social services, environmental health, council tax departments and benefit agencies.

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 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.

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 our relationship and for a set period afterwards in line with legal requirements, best practice and any follow up that may be necessary.

12.2 At application stage, if you decide not to take your application any further hold your personal information for 6 months after your last contact with us.

12.3 Should you become a client of ours, we will hold the information collected at application stage and while you are a client during the period of our relationship and for set periods of time afterwards. For example, normally, we will retain your support and service user records for six years after our relationship ends in-line with the Limitation Act 1980 and NHS Code of Practice.

12.3.1 The exact periods that we hold your information for will depend on the type of information, as set out in our Group retention schedule.

12.4 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 data.protection@sanctuary-housing.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 Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

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Sanctuary Supported Living is a trading name of Sanctuary Housing Association and Sanctuary Home Care Limited, both exempt charities. Images used on our website and literature may be representative and are for illustration purposes only.

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