This Privacy Notice is a public document available to anyone and applies to customers of bdht ltd. (Bromsgrove District Housing Trust Ltd.) to explain how the organisation collects and processes personal information in order to conduct normal business activities as a UK charitable housing association.
We are a Registered Social Landlord (RSL) regulated by the Homes and Communities Agency (HCA), providing social and other types of housing, and associated services.
2.0 About bdht
bdht is registered with the Information Commissioners Office as a Data Controller. Our Head Office is located at Buntsford Court, Buntsford Gate, Bromsgrove, Worcs. B60 3DJ. Tel 0800 0850 160.
We own around 4,000 properties in Worcestershire and surrounding areas, and employ around 130 staff, mostly based at our head office.
3.0 How we collect data about you
bdht collects information from you via a variety of sources, including when you apply for one of our properties or services, complete one of our forms, when you call, write, e-mail or meet with us or respond to a survey. We may collect information when you use our social media sites, websites or self-service portal ‘mybdht’.
Calls to and from our office phone calls are recorded for training and monitoring purposes and our recordings are usually held for a period of twelve months.
We operate a CCTV system at our office premises for monitoring purposes, including for the prevention and detection of crime. It operates continuously and recordings are held for one month.
We may also take photographs at our events, at our properties and in our communities to use for general marketing and publicity. Photographs of individuals are taken at the point of signing a new tenancy and will be held on our Housing Management System, will only be used these for other purposes with your consent.
We may receive information about you from third parties including:
- Your council or benefits office relating to your housing.
- Prior landlords and credit agencies when you apply for housing.
- Police, welfare or support organisations dealing with you.
- Councillors, MPs, relatives or other representatives acting on your behalf/instruction.
- Financial institutions when you apply for our services
4.0 What information do we hold about you
The information we require from you, the tenant(s) or leaseholder(s), includes:
- Full name (and proof of your identity / photo ID).
- Date of birth.
- National Insurance number (your unique identifier).
- Contact details (phone, e-mail or correspondence address).
- Details of anyone authorised to act on your behalf if applicable.
- Basic details (name, DOB and relationships) of all household residents.
- Banking details if you pay your rent by Direct Debit.
- Card details if you pay by card (however card details are not stored).
- Proof of housing eligibility, any interest or equity in other property.
- Other personal information that will vary on a case by case basis to help us resolve breach of tenancy, alleged anti-social behaviour or fraud.
The information we may collect from you includes:
- Disabilities or vulnerabilities. We use this information to tailor our service to better meet your particular circumstances and needs. We may use this information for safeguarding of staff.
- Financial information. We may use this to help resolve arrears payments and optionally to provide welfare, benefits and debt advice as a free service to help you budget and pay your bills. We may use this to apply for funding on your behalf.
- Health information when we require this to support funding for adaptations made to the property you are living in. More specific details are provided if you use this service.
- Photo ID, bank statements, payslips or income details when we require this information for processing a house sale or purchase.
- If you do not provide the information we need then we may not be able to provide all our services to you, and ultimately you may not be able to hold a tenancy or lease with us, or sell or purchase a property through us.
5.0 How do we process the information we hold about you?
The information we require from you is used to manage your tenancy or leasehold agreement or other contract between you and bdht ltd. Please read your tenancy agreement, lease or any other contract carefully for specific details regarding processing your information and carrying out our activities.
The processing activities we conduct can be summarised as:
- Managing your account charges and payments, including arrears.
- Managing the repairs, maintenance, improvements and adaptations of our properties.
- Ensuring tenancy (or contract) conditions are complied with, such as dealing with anti-social behaviour or fraud.
- Complying with relevant legislation and regulation.
- Conducting surveys and questionnaires
- Completing regulatory returns
- Bdht operates a range of information and communications systems and technologies for efficient operation of the business. Personal information is stored and managed within those systems. We hold information in IT systems which may be copied for testing, backup, archiving and disaster recovery purposes. All data is held within the UK.
6.0 Information relating to children
bdht ltd. does not normally process children’s information as part of a tenancy, as all tenants are adults. However, we record children’s basic information if they are resident in one of our properties, including their name and date of birth.
This is required for checking the property is not overcrowded and to assess other tenancy management issues where all householders and ages are required to be known.
We may receive children’s information if we are involved in the housing and tenancy aspects of a welfare case as part of a multi-agency working solution.
7.0 Information relating to properties
Much of the data we use relates to our properties and their maintenance and repair. We do not consider property information used in conjunction with the property address to be your personal information.
For example, the age of the kitchen, results from an asbestos survey, planning to replace windows or a repair to a tap. We are usually happy to provide you with answers to questions you may have about the property you are living in and work done to it.
As soon as your name, contact details or other personal information is used in conjunction with property information, such as to complete a property repair visit, then this is treated as personal information.
8.0 How we communicate with you
bdht ltd. needs to communicate with our customers and this will usually be in writing or by telephone, but is more commonly becoming electronic and paperless, including messaging and email We are moving many of our services on-line as this is usually more convenient for you and more efficient for us.
Our secure on-line tenant service is called mybdht. If you use this service it is important that you keep your user number and password secure and do not share your details with any other person.
The privacy of your information, as with any on-line service, depends on you keeping your account username and password details to yourself, as well as setting a suitably complex password that cannot be guessed or calculated.
In the case of a joint tenancy both parties have their own mybdht account.
We are required by our regulator to send all tenants the annual Tenant Report, and this is now done via the website, with an email notification. Otherwise, bdht will operate an opt-in mechanism for receiving direct marketing. You may remove your consent to receive direct marketing or object about direct marketing.
All social media activity will imply opt-in by you, and can be terminated at any time.
We will only discuss or communicate your tenancy or lease details with those named on the agreement or those authorised (temporarily or permanently) by you. You can authorise someone temporarily verbally over the phone or permanently in writing.
9.0 Who we share information with
bdht Ltd. shares limited personal data with our contractors who are carrying out services on our behalf. Our contractors are required to comply with the law and our own Data Processing Agreement to ensure data is managed appropriately and for specified purposes, including to run our out-of-hours telephone service or to complete emergency, responsive or planned property repairs.
We may share your information with a language translation service if it is necessary to translate any information into or from a foreign language for you.
We may need to share personal information with government departments and agencies, with our regulator and auditors, with utility companies or with other organisations and agencies where we are legally allowed to do so.
Information relating to a tenancy or lease agreement will be kept for as long as the agreement is active or where money is owed on the account, and for a period not exceeding three years afterwards. The basic history of who held a tenancy at which property and when will be held forever. We may need to share information with solicitors, agents, mortgage brokers, financial advisors, court agents, surveyors and valuers relating to a property sale.
We will share information with law enforcement agencies if it is related to the detection or prevention of crime.
10.0 What we will not do
We will not send you unsolicited marketing material.
We will not sell your personal data on to third parties.
We will not pass on your personal data to unrelated third parties unless we are allowed or
required to do so by law or we have your explicit permission to do that.
We will not transfer or store your personal data outside of Europe (the European Economic Area) outside of the control of the UK / European regulations.
11.0 Your rights
You have the right to request a copy of the data we hold about you. Please contact us through ‘mybdht’ or email email@example.com if you wish to request access to any of your personal data and we will always endeavour to answer your questions as part of our friendly, helpful and transparent service.
We will not charge for this service and will respond within one month of receiving your request form which will help us identify what information you would like to have a copy of.
It will always help if you can be as specific about what personal data you want to see, what it relates to and within what timeframe, as that will assist our search. You have the right to correct information that we hold.
You may withdraw your consent to use any information that was previously provided with your consent.
You also have other rights which can be seen by visiting the Information Commissioner’s Office (ICO) website and reading about Data Protection law at https://ico.org.uk/.
You have the right to complain about any matter relating to our service, including how we use your personal data:
- In the first instance please contact us on us through ‘mybdht’ or call 0800 0850 160
- If you are still not happy with our service you may complain to the Housing Ombudsman Service at http://www.housing-ombudsman.org.uk/.
- If you wish to complain about our use of your personal data you may complain to the UK Information Commissioner’s Office (ICO) at https://ico.org.uk.
This policy will be reviewed annually. Up until 25th May 2018, this policy refers to The Data Protection Act (DPA). After this date, it refers to the General Data Protection Regulations (GDPR).
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Please check back here to see which cookies are in use at any given time.
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