Our customer privacy notice
Who we are
PA Housing is the trading name of Paragon Asra Housing Limited, a charitable Community Benefit Society registered under the Co-operative and Community Benefit Societies Act 2014, No. 7536. We are also registered with the Homes and Communities Agency, No. 4849.
Our address is:
PA Housing Ltd
85-89 High Street
0300 123 2221
Purpose of this notice
We aim to provide you with the best quality service that we can, to focus on the wellbeing of the people we serve and to help our neighbourhoods thrive. To do this, we must keep records about you and the housing services we provide for you.
Most housing records are held electronically with some on paper. We have a legal duty and are committed to keeping these confidential, accurate and secure always in line with Data Protection legislation.
We have published this notice to tell you:
- what personal data we may collect
- why we need to process it
- how we store your personal data, how we control it and for how long we keep it
- what to do if you think that the personal data we are holding is incorrect
- what we use your personal data for
- who has access to it
- who (if anyone) we pass it to and how they use it
- how our website operates in respect of personal data
- your rights in respect of your personal data.
What is personal data?
Personal data is any information that identifies a living person or relates to an identifiable living person the 'data subject'. Personal data includes name, financial information, education, employment, health and genetic details (amongst others).
‘Special categories’ of personal data
Certain types of personal data are categorised as being sensitive in nature. These include racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data and health or data concerning a person's sex life or sexual orientation.
PA Housing only collects minimal categories of personal data – which is relevant to providing housing services, and to provide regulatory and legal returns.
What information is collected about me?
When you first come to see us:
- To take steps (at your request) to enter into a contract, we process personal data including your name, address and contact details.
- To meet your housing needs and so that we can find a property that suits you, we process detailed personal data such as age, sex, date of birth, ethnicity, whether you have a disability and any other particular needs or preferences. We also process the above data for other members of the household.
- To ensure our records are up to date and for the prevention, detection, and prosecution of crime, including social housing and benefit fraud, we will from time to time use credit reference agencies. Any information we receive will not be passed on to third parties and will not be used for any inappropriate purposes.
For housing management purposes, we require:
- your housing needs, so we can find a suitable property
- bank details and direct debit information, so you can make payments to us – please note, if you pay us using your payment card we do not store the details
- benefit and council tax information to verify your circumstances
- information that you provide to our officers in conversations or correspondence
- feedback from our contractors about their appointments with you
- photographs for proof of identity and fraud prevention
- telephone call recordings for training, quality and safety management
- CCTV and video recordings for safety management and crime reduction.
To enhance your experience with us, we may ask for:
- details of your friends, relatives or neighbours who you trust to contact us on your behalf, for example to arrange one of our services for you (we also use advocates – people nominated by you, such as Solicitors or someone with your Power of Attorney – to send correspondence to)
- your name and contact details for customer satisfaction surveys, newsletters and service information
- your name, photo, video or story for brochures, advertising or press releases or use by the media (with your consent)
- any information about complaints relating to our service or other individuals, or accidents or incidents involving you or your home.
- information with which to offer you additional housing services (with your consent).
If you ask for additional services from us:
- we may hold detailed information about your needs and your family’s needs; we may also send correspondence to representatives you may have nominated
- we will hold records of payments for services
- we will hold detailed information about your income and debts if you contact us about money problems, but we keep this separate from our other information about you.
- we may hold information about your history, eg. regarding credit or criminal offences
- if you make a complaint, we will keep the details separate from our other information about you.
Whenever you communicate with us, we may need to obtain personal details about you to enable us to perform any required actions. We will only request personal data that is appropriate for delivering services to you and to meet our legal obligations.
You may refuse to provide information if you deem any requests to be inappropriate, although that might mean that we are unable to carry out requested or essential work. We may also obtain your personal details from organisations you have dealt with, such as referral agencies, councils, and past landlords.
Why do you need to process my personal data?
We need to process your personal data for a variety of purposes. The legal basis for the processing of data will depend upon the purpose.
- We process information about household members in our legitimate interests of knowing who the resident is at our properties and to ensure that the property is appropriate to the needs of the household and its location.
- Because we have a contract with our tenants, we also process personal data to fulfil that contract.
- As a landlord, we have a legal obligation concerning fraud prevention and gas inspection.
- We must complete statutory, legal and regulatory returns which are dependent upon your data.
- Some of our services require us to process special categories of personal data, in which case processing will only be carried out with the explicit consent of the data subject.
Where do you store my personal data?
We are committed to holding your personal data securely. This means colleagues and contractors will only have access to it if necessary.
If we can store your personal data solely on computers we will, however there will be cases where we have paper copies instead, or as well.
Our computer systems are located at our offices. Sometimes we also use computing services which are owned or managed by a third party, who are contracted to ensure that their computers are secure and protected.
How long do you keep my information for?
Information is typically held for six years beyond the end of your tenancy. We will only retain your personal data for as long as necessary to fulfil the purpose we originally collected it for. However, there may be some instances where information may need to be retained for longer periods i:e to comply with the law, adhere to industry regulations, in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you, due to safeguarding or care issues or under legislation in relation to Right to Buy and/or health and safety or otherwise. Where we can do so we will anonymise your data so that identification is no longer possible This may be for research or statistical purposes, in which case we may use this information indefinitely without further notice to you
How do you control my personal data?
We are committed to ensuring that your privacy is protected.
- PA Housing will process (collect, store and use) the information you provide in a manner that complies with Data Protection legislation.
- We will endeavour to keep your information accurate and up to date and not keep it for longer than is necessary. In some instances the law sets the length of time that information has to be kept, and in other cases this is governed by housing sector regulation.
- Our aim is not to be intrusive, and we try not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
- When you provide us with your contact details on a website form, we will include a box for you to tick to give consent to use your information for marketing purposes
- We will not sell, distribute or lease any personal data you provide to third parties unless we are required by law to do so or to deliver our services. With your consent we may use your personal data to send you promotional information about third parties which we think you may find interesting.
- If you have previously agreed to us using your personal data for direct marketing purposes, you may change your mind at any time by writing to or emailing us.
- If you believe that any information we are holding about you is incorrect or incomplete, if any of your information changes, or if you want to see your information, please write to or email us using the details below. We will promptly correct any information found to be incorrect.
PA Housing Ltd
3 Bede Island Road
0300 123 2221
How will you use my information?
Information collected about you is used to:
- provide you with a home and tenancy
- maintain our records and provide a quality housing service
- contact you about your rent account
- manage and enforce the tenancy conditions you have agreed to
- do repairs and maintenance work to your home
- support and help you live independently
- support any claims you make for benefits or grants
- help improve and shape our services
- conduct surveys and record statistics about residents in order to improve services and to provide summary information to regulatory agencies
- enable us to comply with our legal and regulatory obligations
- Closed Circuit Television (CCTV) is used for maintaining the security of property and premises and for preventing and investigating crime.
- Data matching (comparing computer records held by one body against other computer records held by the same or another body), which allows potentially fraudulent claims and payments to be identified.
If we need to use your personal data for any reason beyond those stated above, we will discuss this with you and you have the right to object. However, there are exceptions to this such as:
- when we have a legal duty, for example through court orders
- when the public interest has greater importance, e.g. if a serious crime has been committed
- if there are risks to the public or our staff
- to protect vulnerable children or adults.
Who has access to my information?
Our staff are trained to handle your information correctly and protect your privacy. We aim to maintain high standards, adopt best practice for our record keeping and regularly check and report on how we are doing.
Your information is never sold on to any third parties and is not processed overseas.
Sometimes PA Housing’s services may be provided by our business partners, in which case appropriate members of their staff will have access to your information in order to deliver services to you.
Recipients of personal data and data sharing
Only PA Housing staff who have an operational need to see your personal data will be allowed access to it.
We never sell your data. We may pass your personal data on to our service providers who are contracted to PA Housing and who may deal with you. Our contractors are obliged to keep your details securely, and use them only to maintain our properties. Once your service need has been satisfied or the case has been closed, they will dispose of the details in line with PA Housing’s procedures.
There may be situations where it is necessary for us to share some of your information with others and where this is the case, we will only make such disclosures when they are in line with our legal obligations or legitimate interests. All individuals or organisations receiving the information will be validated as being genuine in both nature and need to receive it. Information around this is also available within your tenancy agreements.
We have data sharing agreements with a number of organisations (typically in the public sector) who sign up to a code of how data will be exchanged and used. Organisations that we may share data with are as follows:
- housing benefits departments and benefits offices
- local authorities
- electricity/water/gas companies
- organisations that we contract/partner with to provide services on our behalf
- the National Housing Federation
- the Housing Associations Regulator.
Typical reasons that we may share information include:
- the prevention or detection of crime and fraud
- legal proceedings
- the physical or mental health of an individual where disclosure is required to protect them or others from serious harm
- making a safeguarding alert where there is concern regarding the safety of a child or vulnerable adult
- the collection of unpaid rents
- research and statistical purposes
- contractual obligations
- third parties obligations; so they can carry out duties or services on our behalf
- protecting the health and safety of our staff
- compliance with the law.
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to personalise the content you receive, your needs, likes and dislikes by remembering your preferential information.
We use traffic log cookies to identify which pages are being used on our website. This helps us to analyse web page traffic data and improve our site so it meets customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. Our cookies do not enable us to identify you as a person.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Alternatively, you may wish to visit aboutcookies.org which contains comprehensive information on how to modify your cookies on a wide variety of browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies.
Our website uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of the website and compile reports for us on activity on the site. Google stores the information collected by the cookie on servers in the United States of America where the data is protected by Privacy Shield, a recognised data protection safeguarding protocol. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.
Google will not associate your Internet (IP) address with any other data held by Google. By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
Links to other websites
Our website may contain links to other websites of interest. Once you have used these links we have no control over any other website and therefore, we cannot be responsible for the protection and privacy of any information which you provide. Such sites are not governed by this privacy notice and you should exercise caution and look at the privacy notice or statement applicable to the website in question.
By using our website, you agree to the collection and use of your personal data as described in this notice. This privacy notice is regularly reviewed. This is to make sure that we continue to meet the highest standards and to protect your privacy. We reserve the right, at all times, to update, modify or amend this notice. We suggest that you review this notice from time to time to ensure that you are aware of any changes we may have made. We will ensure if any changes are made, we always post the up-to-date version on our website.
Data Protection legislation defines profiling as any form of automated processing intended to evaluate certain personal aspects of an individual, to analyse or predict characteristics. This includes personal and professional interests, contact preferences, and experience of our services, including feedback and survey responses.
PA Housing will from time-to-time use profiling as a method to engage with you where it is necessary for our legitimate interests or those of a third party, and where your interests and fundamental rights do not override those interests. It is in our legitimate interest to understand how we are performing so we can meet our objectives. In order to do this we need to communicate with you and keep you up to date with news and events in order to meet our goals around service delivery, social inclusion and to help build communities.
You can contact us if you wish to opt-out of this kind of service.
Data Protection legislation gives individuals rights in respect of the personal data that we hold about you. These include:
- to be informed why, where and how we use your information
- to ask for access to your information
- to ask for your information to be corrected if it is inaccurate or incomplete
- to ask for your information to be deleted or removed where there is no need for us to continue processing it
- to ask us to restrict the use of your information
- to object to how your information is used
- to challenge any decisions made without human intervention (automated decision making).
We strive to help you exercise these rights by publishing our Data Protection Policy and providing you with our Fair Processing Notice. You can access your information by making a Subject Access Request. Should you wish your information to be corrected/deleted, its use restricted or to make an objection then you can do so by contacting our Data Protection Officer.
PA Housing does not make decisions about you automatically.
If you have further queries or need to complain
Should you have any further queries on the uses of your information or if you want to make a complaint about the use of your information, please speak to our Data Protection Officer.
The Data Protection Officer
PA Housing Ltd
3 Bede Island Road
Telephone: 0116 257 6857
Email: [email protected]
If you are still unhappy with the outcome of your enquiry you can contact The Information Commissioner (ICO)
Please see their contact page for ways of contacting the ICO.