1. Who are we?
We are Merlin Housing Society Limited (operating as Bromford) a charitable registered society with registration number 30012R. Registered with the Regulator for Social Housing with registration number L4485. Registered office: Building 1, Riverside Court, Chipping Sodbury, BS37 6JX.
Merlin Housing Society Limited is a subsidiary of Bromford Housing Group Limited, registered society with registration number 29996R. Registered with the Regulator for Social Housing with registration number L4449. Registered office: 1 Exchange Court, Brabourne Avenue, Wolverhampton Business Park, Wolverhampton, WV10 6AU.
This website is for tenants who originally signed their tenancy agreement with Severn Vale Housing, before they merged with Merlin Housing Society Limited on 2nd Jan 2019. All businesses operate as Bromford.
2. Purpose of our privacy statement
Under the Data Protection Act 2018 and the General Data Protection Regulation (GDPR), we are required to explain to you why we ask for information about you, how we intend to use the information you provide and whether we will share this with anyone else.
Bromford is defined as a data controller under the GDPR and Data Protection Act 2018 and is registered with the Information Commissioner’s Office (ICO). Bromford only collects or uses personal information for those purposes indicated in our notification with the Information Commissioner’s Office.
3. Our data protection officer
Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
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, Bromford, Shannon Way, Ashchurch, Tewkesbury, Gloucestershire GL20 8ND or emailing firstname.lastname@example.org
4. Information we may collect from you
The only information which we are collecting about you is the information which you provide to us on your form(s) and during the application process and ongoing tenancy.
Some of the information which we collect will be special categories of personal data (also called sensitive personal data), which includes information about your medical circumstances as requested on the form(s).
We may collect and process data including but not limited to;
a. When you first come to see us
• Your name and contact details for use across Bromford and by our suppliers and partners
• Detailed personal information (including sensitive personal information) such as age, sex, date of birth, ethnicity, particular needs or preferences so that we can understand our customers and their needs better
b. For housing management purposes
• Your housing needs, so we can ensure your nominated property suits you
• Bank details, direct debit information and card details to make payments such as rent or service charges.
o NB We only exchange details with the account holder and the third party (AllPay) who facilitates all payments, therefore we will not store any of your card details.
• Benefit and council tax information to verify your circumstances
• Details relating to the repair and maintenance of your home
• Information that you provide through the Contact Centre
• Information that you provide to other Bromford colleagues
• Feedback from our contractors, about their appointments with you
• Voice and video recordings for safety, crime reduction and quality management
• Image of you for fraud prevention, and future verification of identity
c. To enhance your experience with Bromford
• You can give us details of your friends, relatives or neighbours who you trust to contact us on your behalf e.g. to arrange one of our services for you
• You can give us details of anyone whom you have given a Power of Attorney to contact us on your behalf
• Any information about complaints about our service or other individuals, or accidents or incidents involving you or your home
• Your comments about services from us or our suppliers
d. If you ask for additional Bromford services:
• If you access our sheltered housing service then we will hold slightly more detailed medical and wellbeing data to allow us to provide this service.
• We will hold records of payments for the services
• If you contact us about money problems we will hold detailed information about your income and debts; we keep this separate from our other information about you
• If you access our Helpline Alarm service then we will ask for emergency contact and medical information to allow us to provide this service
e. In addition
• We may hold information about your history e.g. regarding credit, or offences, if we need it to look after our colleagues, business or anyone else
• If you make a complaint we will keep the details separate from our other information about you
We may get the information, or related information, from you or our partner organisations, your family, friends or neighbours, our colleagues or public information sources including credit reference agencies or the Criminal Records Bureau.
We will also record factual information whenever you contact us or use our services and of other actions we take, so we have a record of what happened to help provide our ongoing services.
5. Where we store your personal information
We are committed to holding your personal information securely. This means only those of our colleagues and contractors that need to see it have access.
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 General Data Protection Regulation
If we can we will store your personal information solely on computers, however there will be cases where we have paper copies instead, or as well. We have procedures in place to ensure this paper data is stored and maintained in a secure way.
Our computer system is at our offices but we do use computers (including laptops and tablets) outside our offices that are secure and under our control. When dealing with customer data we have technology in place to mitigate the risks of that data being accesses by others.
Sometimes we will also use Cloud services to facilitate our ability to deliver a service to you. When this is the case we endeavour to ensure your data remains in the EU, or with companies certified by the EU-U.S. Privacy Shield. (https://ico.org.uk/concerns/eu-us-privacy-shield/)
6. Why are we collecting your information?
The information that you provide to us is required by Bromford in order for us to assess your need for housing, and deliver our services. Without this information, we will not be able to enter into a contract with you. Our aim is that by further understanding your individual needs, we will be able to provide an improved service.
a. What we use your information for
• Keeping in touch with you to call out the services you have requested from us, understanding your needs and preferences, inviting you to events and offering and booking appointments with you
• Meeting your housing management needs and requirements including (but not limited to) repairs, maintenance, relocation, exchange or purchase and routine inspection
• Telling you about changes to Bromford and its services
• Managing payments from you or to you or on your account and for accounting purposes
• Providing additional services, where available, at your request including helplines, adaptations, commercial repairs and every day support services
• Prevention, detection and prosecution of crime
• Quality management
• Informing our staff, contractors or others (as appropriate) about past incidents e.g. anti-social behaviour, for their protection, in line with our policies
• Meeting our legal obligations including our funders or regulators
• Us or your other suppliers exercising legal rights, including under contract with you
• Other purposes.
We may anonymise your information so that it cannot be linked to you. In that case we may use the data for any purpose
b. What is the legal basis for using your information?
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.
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 that we have a contract to carry out services as part of your tenancy or for some tasks a legal obligation.
Using your information in this way is necessary for us to assess your housing application prior to entering into a contract.
Where these legal basis don’t apply we will always gain consent before collecting or using your data.
7. Who else we may pass on your information to
Normally, only Bromford will be able to access your personal information. However there may be times when we disclose your details to others, as follows:
• Our suppliers who enable us to provide our services to you, or who provide services on our behalf
o Housing contractors e.g. to undertake repairs or improvements to your home
o IT providers who own or manage the computers, phones or systems we use
o Our contractors who handle your out of hours service calls for us
o Banks e.g. to carry out payments through a secure system
o Companies that assist us in mailing out our letters, leaflets and newsletters
o Additional staff resources, such as consultants or agency staff
o Our professional advisors and providers of financial services
• Our partner organisations whose purposes dovetail with ours
o Training providers or learning institutions
o Other housing associations
o External assistance where you have agreed to the referral, for example to do with money problems or domestic abuse such as GreenSquare.
o Local authorities and Government departments who provide relevant services for you, including benefits
o Credit reference agencies; to help assess your applications, manage your tenancy, verify your identity and undertake checks to prevent or detect crime
o Public Trustee in relation to the termination of a tenancy where there is no next of kin or Executor;
o court services in relation to formal tenancy enforcement action;
o The police, fire services, health authorities or medical staff who provide services for you
• Others who may request information from us for their own purposes
o Utility companies
o Debt collection agencies acting for others
o For crime prevention or detection, risk assessment, resolution of complaints or other issues
o Local authorities, Safeguarding Boards, regulators, Government departments and other public authorities, such as for preventing payment errors or fraud
o The police, fire service, health authorities or medical practitioners
We may sometimes be obliged to disclose your personal data by law such as by a regulator with appropriate power (e.g. the Regulator for Social Housing) or court order.
We do not give anyone else access to your information, in return for payment, for their marketing or commercial purposes.
If you use credit or debit cards to make a payment we will not usually retain your payment details, as this is facilitated by a third party (allpay). They will store card and payment information to allow for facilitating refunds, reoccurring card payments and to enable quicker payments in the future. All this information is held by allpay, and only basic information about transactions can be access by Bromford.
We will not share your personal information with anyone who claims to represent you unless we are satisfied that you have appointed them or they act in some recognised official capacity. There may be a delay to us dealing with requests whilst we confirm the caller’s identity, or check that we have your approval to deal with them.
a. Rental Exchange
We share some of your personal data, including your rental payment history, with Experian a consumer credit reporting agency as part of their rental exchange programme.. The rental exchange is an initiative between Experian and the Big Issue that aims to tackle financial, digital and social exclusion challenges that rented households face compared to Homeowners. By sharing rent data with the rental exchange your rent payments are seen in the same way mortgage payment data is. This can unlock a range of benefits including online proof of identity and can build a positive credit history which will help when applying for goods, services and access to mainstream credit. Please note however, that failing to keep up with your regular payments could affect your credit rating.
The legal basis we rely on when we share your rental payment history with Experian is legitimate interest. In data protection law “legitimate interest” is defined as processing that is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject).
You can opt out of the Rental Exchange Programme at any time by contacting us.
If you would like more information you can visit www.experian.co.uk/rental-exchange or call Experian on 0115 9410888 and ask for a copy of the Rental Exchange Programme.
8. Security of your information
The information that you provide will be stored securely on our systems and where practical paper copies will be processes and then scanned in or input and then shredded. Our security measures and procedures reflect the seriousness with which we approach security and the value we attach to your information.
Internal procedure are in place to ensure that only relevant members of staff will access the information you provide to us.
a. Can we use your information for any other purpose?
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.
If required we may contact you to inform you of the change, or if needed ask for consent.
b. Storing your information and deleting it
Should you enter into a contract with Bromford, we will store the personal data which you provide to us for as long we provide a service to you (or there is outstanding issues with that service). We have a retention schedule in place which details how long we will keep different types of data for. For a tenancy we will delete your records 6 years after the termination of your dealing with us. Should your application not be successful, we will store the personal data which you provide to us for a period of six months and then it will be deleted.
9. Your rights
In relation to the information which we hold about you, you are entitled to:
• Ask us for access to the information;
• Ask us to rectify the information where it is inaccurate or is incomplete;
• Ask us to erase the information, and take steps to ask others with whom we have shared your information, to erase it;
• Ask us to limit what we do with your information;
• Object to our use of your information and ask us to stop that use;
• 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).
Our obligations to comply with the above rights are subject to certain exemptions.
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.
To exercise any of the rights referred to above, you should contact our Data Protection Officer by writing to The Data Protection Officer, Bromford, Shannon Way, Ashchurch, Tewkesbury, Glos GL208ND or emailing email@example.com
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.
a. Accessing the information we have about you
You have a legal right to access information that we hold about you. You can ask any of our Customer Support Officers in the Contact Centre or email us on firstname.lastname@example.org. We will normally give a full response within one month.
In most cases we will be able to comply with your request, however we may not be able to fulfil your request if your personal information contains details about another person. As part of your request we may contact you to clarify details, or update you on progress if needed.
b. rectify the information where it is inaccurate or is incomplete
We work hard to keep your information up to date, but this is now always possible. In a bid to be more transparent we provide a self service facility, which you can use to view and update some of the data we store.
a. Direct marketing
If you opt in to receive marketing information, we will collect your name and contact details (such as your email address, phone number or address) in order to send you information. We will only collect this directly from you, and will always ask for your consent to do this.
Once you have opted-in, you retain the right to opt-out of receiving future marketing information. You may exercise the right at any time by contacting us at: email@example.com. If we send you any marketing emails we will always provide an unsubscribe option to allow you to opt-out of any further marketing emails and a way for you to easily change your details. If you opt-out your details will be removed from our mailing list and we will not send you further marketing information. To receive these emails again after cancelling, you will need to opt in again from our subscription form.
When unsubscribing from any postal marketing, you may initially still receive some content which has already been printed or sent, but we will remove you from any future campaigns. We may still need to contact you for administrative or operational reasons but we will make sure that those communications do not include direct marketing.
We will retain your details on our marketing list until you opt-out at which point your personal data will be deleted.
b. Publicity information
As a business we are keen to tell others of the work we do, and services we provide. To that end we may approach you and ask for things like you name, photos, video or interview/story for things such as brochures, advertising or press releases. If we do we will always explain how we plan to use your data, for what purpose and ask for consent.
We will never use your data in this way without consent.
c. Sharing your data for marketing
We never share your name or contact details with third parties for marketing purposes.
We do use third party service providers to send out our marketing material but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to comply with the data protection legislation.
11. Google Analytics
We use Google Analytics on many of our web services such as our website and self service portal for understanding usage, and to inform areas to improve. You can opt-out of Google Analytics and disable tracking using the Google Analytics Opt-Out Browser Add-on. We use the data provided by Google Analytics Demographics to develop our website and content in line with our users’ interests.
12. Links and IP addresses
Our websites contain links to various third party websites. We are not responsible for the content or privacy practices of any external websites that are linked from our sites.
We use IP addresses in order to assess patterns, gather broad demographic information for aggregate use, track visitors to the website’s movements, and to manage our website. We do not link the IP addresses with any identifiable personal information.
We operate CCTV at our head office and some of our properties which may record you and your activities. We display notices to make it clear what areas are subject to surveillance. We will only release footage where there is a legal obligation, to protect the vital interests of the data subject or other person. Processing is necessary for the purposes of our legitimate interests pursued by us or by a third party.
CCTV recordings are kept for a period of one month in respect of the ground and first floor of our premises CCTV coverage and for three months in respect of the second floor CCTV coverage.
Not only will we be able to work with you more closely to manage your existing tenancy agreement, your track record as a tenant will enable Experian to use the information supplied to them to assist other landlords and organisations to:
- assess and manage any new tenancy agreements you may enter into;
- assess your financial standing to provide you with suitable products and services;
- manage any accounts that you may already hold, for example reviewing suitable products or adjusting your product in light of your current circumstances;
- contact you in relation to any accounts you may have and recovering debts that you may owe;
- verifying your identity, age and address, to help other organisations make decisions about the services they offer;
- help to prevent crime, fraud and money laundering;
- screen marketing offers to make sure they are appropriate to your circumstances;
- for Experian to undertake statistical analysis, analytics and profiling,
- and for Experian to conduct system and product testing and database processing activities, such as data loading, data matching and data linkage.
If you would like to see more information on these, and to understand how the credit reference agencies each use and share rental data as bureau data (including the legitimate interests each pursues) this information is provided in this link: www.experian.co.uk/crain (Credit Reference Agency Information Notice (CRAIN)). (For a paper copy, please get in touch with us or with Experian using the contact details in this letter).
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “last updated” date at the bottom of this page.