We are a data controller under the data protection law as we collect and process personal information about you in order to provide housing services and meet our contractual and legal obligations.
Our data protection policy and procedures are governed by the Data Protection Act 2018 and, from 25th May 2018, the EU General Data Protection Regulation. The law in this area is changing rapidly and we anticipate this statement may be revised in line with guidance from the Information Commissioner’s office.
We are committed to protecting and respecting your privacy. Through this Privacy Notice we have sought to be as transparent as possible to fully explain how your personal data is held and processed.
This Privacy Notice explains when and why we collect personal information about people who engage or come into contact with us, whether via applying or receiving our services, living in our accommodations or visiting our website. This notice also explains how we collect, use and share your information and how long we keep it, and how we keep it secure.
We need to process personal data in order to deliver our services to you:
- To provide, manage and develop affordable housing
- To provide property management & property maintenance services
- In the provision and management of care and support services
We are committed to protecting your personal information when you use our services. We collect, store and make use of any personal information that you give us, in accordance with the Data Protection Act 2018. This privacy notice applies to the data collected by A2Dominion Group and its subsidiary companies. For a full list of our subsidiaries, please read our Group structure.
This Privacy Notice outlines our obligations and your rights when using our services. It tells you how we collect your personal information and how we safeguard your privacy. It is important for you to read this policy in full to understand what information we hold about you, how we may use it and your rights in relation to your data.
1. Why we need your information
We need your personal data in order to provide you with housing services that you apply for or receive from us and also for where we are required to use information in order to meet our legal obligations or public tasks. We will only collect personal data that is absolutely necessary and any information we collect about you will be strictly in accordance with the Data Protection legislation and other legal obligations which we are bound by.
We will collect, use and store personal information about you and other household members* so that we can provide the services you need, including repairs and maintenance, rents, transfers, sales and anything to do with your tenancy.
By doing this, we can also:
- Make sure the information we hold about you is correct and up to date.
- Provide services that are fair, equal and in line with the Equality Act 2010.
- Support the health, safety and safeguarding of our customers and employees.
- Improve the services we provide to you.
- Provide you with information about A2Dominion Group that may be of interest to you.
In all cases, we will only collect information we need to provide you with the service(s) you have requested and to meet our legal obligations.
* When you provide information about household members we assume that you do so with their full knowledge and consent.
2. How we collect your information
We may ask you to fill in print or online questionnaires, surveys and feedback forms. You are able to browse our website without telling us any of your personal information.
We receive information from your web browser about how you use our website, including which web pages you visit. This information includes your IP address (a unique identifier assigned to your computer) but does not identify you personally.
We use this information to review and make improvements to our website. By giving us your details, such as your name, email address, postal address, phone number, date of birth etc., you allow A2Dominion and our subsidiaries to provide you with the service(s) you request.
We may ask you to register on or log into certain areas of our website in order to provide you with a personalised experience of our website, i.e. provide you with helpful information based on the details you have given us.
We do not store your friends’ and contacts’ email addresses when you use the ‘email a friend’ tool. Users aged 16 and under must get consent from parents or guardians before giving us personal information.
If you have used our website to register or subscribe to mailing lists, please read those particular web pages or the emails you have received to find details about how to edit your information or unsubscribe from that particular mailing list. If you are an A2Dominion customer and have a contract with us, we may not be able to remove your details or stop contacting you altogether.
3. The information we hold about you and how we will use it
We may collect various types of personal data about individuals depending on the services you receive and your contact with us. The information we hold about you is usually information you have given us or information related to your history with A2Dominion. This is likely to include:
- Names and dates of birth of people in your household to keep our records up to date and help prevent tenancy fraud and illegal subletting.
- Contact details, such as telephone numbers and email addresses, so that we can communicate with you and keep you informed about other services which may be useful to you.
- Transaction history, such as payments of your rent or invoices, and your bank account details.
- proof of identity
- IP address and information regarding what pages are accessed and when
- Information related to your health or support services. If you ask us for care and support requirements we will hold detailed information about your needs and your family’s needs. This may also be to provide you with information relating to products or services from A2Dominion or from trustworthy companies we work with to provide, for example, training or employment opportunities.
- Financial assessments on your household income and expenditure to help you to improve you financial circumstances.
- Recordings of your telephone calls to us, as some of our calls are recorded for training and monitoring purposes so that we make sure we are providing you with a good service.
- We may capture your image on CCTV systems if you visit one of our estates or offices. We use CCTV systems for safeguarding purposes and to prevent and detect crime.
- We may hold information provided by third parties where it is relevant to your circumstances, for example, information from social workers or health professionals.
There are some occasions where our computer systems are set up to use pre-programmed criteria to make automated decisions about you, for example determining your position on a housing waiting list or eligibility for a mutual exchange. You have a right to challenge the validity of any decisions made in this way. You may also ask us not to process your information in this way. Please contact us for more detailed information or to find out if you meet the criteria to opt out.
When you provide information about household members we assume that you do so with their full knowledge and consent. Where enquiries relate to household members, it is in our legitimate interests to know who will be living in our premises to check that accommodation offered is adequate for current and near future needs of the household and to check that household members’ needs are being met.
Provision of the information is a ‘Contractual Requirement’ and we may have a legal or contractual obligation to process this information. Without this information, we may be unable to manage your services. For example, we cannot consult with you about changes to your service if we do not hold your contact details. It is also in our legitimate interests to ensure that service delivery meets the needs of our service user and their household. Please speak to us with any concerns.
4. Special categories of personal data
As well as personal information (such as your name, address and data of birth) we may also collect sensitive personal information (also known as special categories of data) that may include:
- Racial or Ethnic origin
- Religious Beliefs or other beliefs of a similar nature
- Gender and sexual orientation
- Physical or Mental Health details
- Offences (including alleged offences)
We use this data to ensure services are delivered appropriately and to monitor Equality, Diversity and Inclusion. We will apply additional security and confidentiality measures when processing your sensitive personal information.
We may also process confidential data about you including bank account information and property access codes.
5. Who your information may be shared with
We have legal obligations to collect, process and share personal or sensitive personal information without consent, with central government, such as DWP, HMRC, and law enforcement agencies such as the police.
There may be situations where it is necessary for us to share some of your information with others. Where this is the case, we will only share this information when we are required to do so by the law and in line with our obligations under the Data Protection Act. Examples include situations involving the prevention and detection of crime and to safeguard customers where they may be at risk. Some of the organisations that we may share data with include:
- The police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime, the apprehension of offenders or the collection of tax or duty
- Local authorities, to assist with any applications or matters related to your housing, such as Council Tax
- Government departments related to Housing Benefit, with regard to changes in rent or to discuss important matters on your behalf
- The Ministry for Housing, Communities and Local Government in relation to social housing lettings and sales (PDF) via CORE for statistical purposes (please see pages 10 to 14)
- Utility companies and their representatives such as gas, electricity or water companies to ensure billing details are correct and to pursue any outstanding revenues
- Regulators, such as the Regulator of Social Housing and Care Quality Commission
- Organisations that we contract or partner with to provide services to our customers, such as repairs contractors
- Other statutory organisations e.g. social services and health authorities as necessary for exercising statutory functions
- Debt and money management advisors
- Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative.
We may also share information when required by law for example where ordered by the Court or to protect an individual from immediate harm. We may also share your information with third party service providers working on our behalf for the purposes of completing tasks and providing services to you on our behalf.
However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure, as required by the Data Protection Act 2018 and General Data Protection Regulation 2016 (GDPR), and not to use it for any other purposes.
We will not pass your details onto a third party for marketing purposes without your permission.
6. National Fraud Initiative
A2Dominion is required by law to protect the public funds it administers. A2Dominion may share information with other bodies responsible for auditing or administering public funds, in order to prevent and detect fraud.
A2Dominion routinely participates in the National Fraud Initiative (NFI) data matching exercise carried out by the Cabinet Office. Our participation in the NFI will assist in the prevention and detection of fraud against A2Dominion (and other companies within A2Dominion Housing Group) and organisations within the public sector. We will participate on a voluntary basis and provide the Cabinet Office with particular sets of data in the autumn for matching as set out in the Cabinet Office’s guidance.
The Cabinet Office conducts data matching exercises to assist in the prevention and detection of fraud.
Data matching involves comparing sets of data, such as the tenancy, payroll or benefits records of a body, against other records held by the same or another body to see how far they match. The data is usually personal information. The data matching allows potentially fraudulent sub-letting, benefit claims and payments to be identified. Where a match is found it may indicate that there is an inconsistency that requires further investigation. No assumption can be made as to whether there is fraud, error or other explanation until an investigation is carried out.
The processing of data by the Cabinet Office in a data matching exercise is carried out with statutory authority under its powers in Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the Data Protection Act 1998.
Data matching by the Cabinet Office is subject to a Code of Practice.
7. How we protect your information
Any information held by us about individuals is held securely and in compliance with the Data Protection Act 2018 and GDPR.
We are committed to protecting our service user’s personal data. We have put measures in place to ensure that our staff, service providers, partners and suppliers all protect your information in line with good practice and the law.
The information security measures we've put in place include:
- following good governance practice and the law when it comes to collecting, handling and giving access to information
- training staff in their data protection responsibilities
- putting processes in place to ensure good governance practices for information we collect, hold or handle in both manual and electronic forms
- access to your information is only given to those who need to know and where it is necessary
- information will not be held for longer than required beyond statutory and policy requirements and will be disposed of securely
- we encrypt all our electronic devices and sensitive information that is transmitted.
To help us ensure confidentiality of your personal information we will ask you (and any of your representatives) security questions to confirm your identity when you call us and as may be necessary when we call you. We will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so.
8. Your rights in relation to your data
In line with the Data Protection Act 2018 and GDPR, you are able to find out what information we hold about you and correct any information which you believe is incorrect.
The right to be informed
Through the provision of our privacy notices, we will be open and transparent about how and why we use your personal information.
The right of access to personal data
You have a right to ask us what personal information we hold about you and to request a copy of your information. This is known as a ‘subject access request’ (SAR).
Subject Access Requests need to be made in writing (we have a subject access form you can use for this purpose), and we ask that your written request is accompanied by proof of your address and identify. If you would like a copy of the personal information we hold about you, please complete the subject access request form and email it to email@example.com. We will tell you as soon as possible if we require more information from you. If we are unable to meet your request, we will explain why.
Alternatively, you can make a request in writing to: Group Company Secretary, A2Dominion Group, The Point, 37 North Wharf Road, London, W2 1BD. If you are seeking to obtain specific information (e.g. about a particular matter or from a particular time period), it helps if you clarify the details of what you would like to receive in your written request.
The right to rectification
You can ask us to rectify your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by keeping us informed if your details change.
The right to erasure
The right to erasure is also known as ‘the right to be forgotten’. In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for its continued processing. This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data. Our response will also be guided by the provisions of our retention schedule.
The right to restrict processing
In some circumstances you can ask us to restrict processing, for example:
- If you disagree with the accuracy of personal data
- If we’re processing your data on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate grounds override those of yours.
The right to data portability
If the situation arises where it would be helpful for you to move, copy or transfer personal data we hold about you, across different services, you may be able to ask us to do this. Please contact us to discuss.
The right to object to marketing
You can tell us if you object to our processing of your personal data:
- based on legitimate interests
- for the purpose of direct marketing (including profiling);
Rights in relation to automated decision making and profiling.
You can ask us to review any decisions that are determined by automated means. You can also object to our use of your personal data for profiling.
We want to make sure that your personal information is correct and up-to-date. If you think information we hold about you is incorrect, you can ask us to correct or remove it.
If you’d like to talk to us about your rights, you can contact us at firstname.lastname@example.org. Alternatively if, for any reason, you are not happy with our response, you are able to contact the regulatory body: Information Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire, CK9 5AF.
9. Promotion of our services
If you are asked to provide information when applying for, or using, specific A2Dominion Group services, e.g. My Account, we will describe how we use and protect this information on the web page on which you enter this information.
We will routinely use your contact details to send you information and communicate with you about your tenancy/lease/service. As a customer, we will also tell you about events in your area. If you have a preferred method of contact, you can make this known to us, but we will use all means of contact available should we need to contact you in the event of an emergency or to enforce the terms of your tenancy/lease.
If you are currently receiving marketing communications from A2Dominion Group and no longer wish to do so, you can choose to opt-out.
We will not send you unwanted email messages and your details will not be provided to any organisation other than A2Dominion Group, our affiliates and subsidiaries, our business partners and our agents, for marketing purposes, unless you have explicitly allowed us to. We may, however, send you emails about our services, such as responses to enquiries you make about our services. These service emails are not to be confused with marketing emails and there is no option to opt out from receiving them.
When you use social media platforms, and if you have opted in to receive our marketing, you may receive advertising that is specifically tailored to your needs. This is known as ‘targeted advertising’ and will relate to A2Dominion services only. You will not receive any other types of targeted advertising because we will not pass your information on to any other social media groups. If you want to stop receiving notifications about A2Dominion services via social media platforms, please visit the security settings within the specific platform to amend your settings.
10. How long we keep your data
We review our retention periods of the information we hold about you on a regular basis. We are legally required to hold some types of information to fulfil our legal obligations.
We have a document retention schedule which sets out how long we keep different types of information for. This is based on National Housing Federation guidance, legal requirements and best practice. Please contact us if you would like any more information.
We will hold your personal information on our systems for as long as it is necessary for the relevant activity or service that we provide to you, or as required by law.
11. Cookies – what they are and how we use them
Cookies are data that is stored on your computer or other device when you use a website. Cookies allow our computer servers to collect information from your computer or device about how you interact with our website.
12. Changes to our Privacy Notice
We have the right to update our Privacy Notice if there are changes in the law or A2Dominion Group’s policies, and to reflect changes or developments made on our website.
If you have any questions about our Privacy Notice please contact: Group Company Secretary, A2Dominion Group, The Point, 37 North Wharf Road, London, W2 1BD.
13. Useful links
14. Data protection registration numbers
- A2Dominion Housing Group Limited: Z4843307
- A2Dominion Homes Limited: Z9799978
- A2Dominion South Limited: Z7835340
- A2Dominion Housing Options Limited: Z5412073
- A2Dominion Residential Limited: Z3391351
- A2Dominion Developments Limited: ZA103931
- Pyramid Plus London LLP: Z3594227
- Pyramid Plus South LLP: Z3594230