Privacy Notice

As a charitable landlord and managing agent, Ocean Housing is committed to providing our customers with the highest possible standards of privacy and data security in accordance with data protection law. This Notice explains how Ocean Housing uses any information you give to us, or which we obtain about you from other sources, and the ways in which we protect your privacy. It applies to information about applicants, residents and other service users. We may also make further information available in the context of specific uses of your information.

This Notice was last updated December 2022. You may want to download a copy for your records, and check back for updates.

1. Who we are and how to contact us

Ocean Housing Limited is a controller of personal information for the purposes of data protection law. Our contact details (and those of other parts of our group of companies) for these purposes are as follows:

Ocean Housing,
Stennack House,
Stennack Road,
Holmbush,
St Austell,
Cornwall
PL25 3SW

01726 874450
dataprotection@oceanhousing.com

The individual responsible for data protection compliance at Ocean Housing is the Data Protection Officer. They are contactable using the above contact details.

2. Why do we collect and store personal information?

Ocean Housing needs to collect, process and store personal information about you and other household members (when you provide information about household members we assume that you do so with their knowledge) in order to operate as a registered provider of housing and/or managing agent and deliver efficient and effective services and other landlord/property management related functions. This includes:

To assess your housing application and manage our contract with you/your tenancy arrangements with another landlord where we are acting as managing agent

We use the information we hold about you to manage your tenancy. We need this to deliver our housing services to you. We collect most of this information because it is necessary in the performance of a contract, or to enter into a contract with you, or to manage the tenancy contract you have in place with another landlord where we are acting as managing agent.

We may pass on your details to contractors that provide services on our behalf, so that they can contact you to carry out services and repairs related to your property, or to help us manage our business and deliver services. We do this because it is necessary in the performance of a contract, or in our ‘legitimate interests’/the legitimate interests of your landlord. We may use your contact details (including telephone numbers and email addresses) to get in touch with you about issues relating to your tenancy and to deal with any matters arising from it. This includes rent collection, complaints and housing management issues, in the event of an emergency, or to enforce the terms of your tenancy.

To promote safer communities

This can include information about anti-social behaviour, criminal activity and convictions which you report to us or we are told about. We process this information because it is in our/your landlord’s legitimate interests to do so, to prevent and detect unlawful acts, to manage our tenancies, and keep our staff and others safe. This includes our use of CCTV and call recordings, as well as records of people that have been aggressive towards our staff or others. It may also include handling safeguarding information.

To seek to ensure our services and properties meet any specific needs you have

We may process personal data that relates to health and social care, to help us make any reasonable changes to our properties and services to make them more accessible. We may also gather information about health or welfare needs to make sure we are protecting vulnerable individuals. We process information about safeguarding individuals, to fulfil our legal obligations, for housing purposes and because there is a substantial public interest for us to do so.

To ensure that Ocean runs its business appropriately

We also process some of your data because it is in our legitimate interests to do so. We consider that we have a legitimate interest in:

• Ensuring that our services/properties meet the needs of our customers, including by obtaining feedback and conducting surveys about our services.
• Letting people know in the event of emergencies and to carry out essential repairs.
• Communicating with residents to meet our business objectives and building stronger communities.
• Promoting our business. Photographs of tenants and quotes from customers may be taken for marketing and publicity purposes. These are taken at various events and at tenancy properties. Photographs and quotes are taken and used only with the agreement of the individual.
• Making sure we are paid for the services we provide, and that we are not left with debts that are others' responsibilities - for instance, this means we may share details with utility providers when a tenant moves out but hasn't paid their bills.
• Making the most efficient use of our resources, understanding how we are performing and planning appropriately for the future. We work to improve the homes and communities of our residents. We are a long term business and need to manage assets, such as the homes we own or manage, over their lifespan. The lifespan of a building like a house or flat is likely to be more than 100 years. We therefore use data about our tenancies, homes and the profiles of our residents to help us ensure that the homes we own and build meet the changing needs of people in the communities we serve.
• To tell you about how we are doing, and other ways we can help you. We are required to tell you about how we are performing, and we may also use your contact details to update you about events or other services we provide, such as learning and training opportunities, energy efficiency, housing options events, and financial advice. It is in our legitimate interests to use your contact details this way, but you can ask us to stop sending you this additional information.

To promote equality and diversity

We are committed to providing equal opportunities to all when allocating properties, in line with our legal and regulatory obligations, our obligations as a landlord in the provision of social housing and/or where there is a substantial public interest in us doing so. In order to ensure we are doing this, we may ask to collect sensitive information about you, such as your race, ethnicity, age, sexuality, religious beliefs, physical disability or information about your mental health. We will take extra steps to keep this information secure and only allow access to those who need it as part of their job role.

3. Where do we get your personal data from, and who is your personal data shared with?

Where do we get information about you from?

We get information about you from:

• you yourself;
• your family members and neighbours (if they interact with us about you);
• our staff and systems, and records of your interactions with us;
• your landlord if we are managing your property on their behalf;
• Cornwall Council and central government departments, such as the Department for Work and Pensions, for information about your benefits;
• the police, courts, other landlords and other local authorities, such as in relation to background checks following a housing application;
• credit reference agencies, such as for credit checks, debt recovery purposes and fraud investigations; and
• agencies, contractors and service providers we work with.

We record telephone calls and utilise CCTV at our offices and at some of our housing, so as to create records of facts, to ascertain and demonstrate compliance with legal, regulatory and internal requirements, to prevent and detect crime, and to establish, exercise and defend legal rights.

We also maintain records about our buildings which may include some personal data (for instance, if we have installed a new boiler at a property which includes a warranty, this may include information about when it was installed and the tenant who was living in the property at the time).

Who do we share information with?

Ocean may make information available to its staff, contractors and advisors where necessary so that they can do their job. We have a strong culture of tenant involvement and some of our work may mean that volunteers get to see personal information as part of this. All our staff and volunteers are subject to obligations of confidentiality and receive data protection training, and our contractors are subject to data protection obligations in our contracts with them.

Ocean may need or want to share aspects of your personal data with various third party organisations from time to time. We do this to meet and comply with our contractual obligations, to discharge our responsibilities, and where necessary, in our legitimate interests.

Sharing of personal data relating to tenants, customers and their families may include:

• Sharing information with your landlord, where we are acting as managing agent on their behalf, further to your tenancy agreement with them, their legal obligations and/or their legitimate interests in running their business.
• Sharing information with contractors and sub-contractors who carry out maintenance, building management and professional services on our behalf. We will likely provide them with information about the job they need to complete (which will include your address and contact details) and other information they need to do the job safely and effectively.
• With utility companies. We share details of new tenants to set up utilities, as well as details and forwarding addresses of former tenants who have left with arrears.
• Details of tenants who have left with rent arrears will be shared with our own debt collection agencies.
• Personal data may be shared with government departments, local authorities, with our regulators and auditors, and other legal entities where there is a legal obligation to share your personal data - for instance in relation to homelessness prevention.
• We may share information with the police for crime prevention and detection purposes, and with other agencies (for instance, local safeguarding arrangements) as part of our partnership working with those agencies.
• Personal data may be shared with solicitors, our insurers and financial advisers as part of establishing, exercising and defending our legal rights.
• Sharing data with credit check agencies for identification of fraud, and in order for us to gain access to credit reports and profiles for us to recover monies owed.
• Personal data may be shared with the Ministry of Housing, Communities and Local Government (MHCLG), Continuous Recording of Social Housing lettings and Sales (CORE) for research and statistical purposes.
• Gilbert and Goode is a subsidiary of Ocean Housing which is involved in developing, constructing and selling our homes. As such we share certain limited data with them to allow us to operate effectively. On certain developments, Gilbert and Goode work with external estate agents to market our new homes.  If you provide your details to Gilbert and Goode as part of your interest in developments we are marketing, the estate agent we are working with on that development may contact you to understand more about what you are looking for, and tell you more about the homes we are building.
• Other organisations involved in the sale, transfer or merger of our business, properties or services.

We do not sell or trade your personal information. We work to ensure that only limited and necessary information is shared with external organisations with governance controls in place.

4. What categories of personal data does Ocean collect?

We collect demographic information, like your name, current address and previous address history and date of birth. We will normally also collect your contact details (telephone number and email address) and emergency contact details. We may obtain certain sensitive information about you; your gender, disabilities, medical conditions and history, ethnicity, cultural or religious beliefs, sexual orientation.

We may need to know about your employment status and welfare benefit entitlements, as well as your financial details (bank details, debt history etc.).

We may collect information about tenants in relation to their criminal convictions/history. We also collect grievance and complaints information, such as reports about anti-social behaviour and complaints made by or against your neighbours.

We collect information about how you have interacted with us and made use of your home and other services Ocean provides. This includes your responses to customer satisfaction surveys, information you give us when you contact us, and for instance, information your neighbours may provide.

We may also collect images of you, such as through our use of CCTV, and for marketing and publicity purposes (with your consent).

5. What is our legal basis for processing your personal information?

The lawful basis for processing personal data is normally because we want or need to use the information:

• For the performance of a contract - for instance our/your landlord’s tenancy agreements with you.
• In our legitimate interests or the legitimate interests of a third party - for instance in ensuring Ocean Housing provides efficient and effective services, and in ensuring the efficient running of the properties we manage for other landlords.
• As a result of a legal obligation or our public tasks - for instance to meet the requirements of our regulators, such as the Regulator of Social Housing.

Some of our activities will use personal data in the public interest - for instance in relation to crime prevention or detection or safeguarding activities.

We do not normally rely on your ‘consent’ to process data about you, but if we do so in relation to any specific activities, such as through the use of photographs of you in our marketing material, you have the right to withdraw your consent to future processing.

We may make use of certain data which the law considers is more sensitive ("special category data"). Where we make use of this, our legal basis for doing so is normally:

• As part of exercising our functions under housing law;
• To prevent or detect unlawful acts;
• To establish exercise or defend our legal rights or to comply with legal obligations we are under;
• As part of our safeguarding obligations; or
• For equalities monitoring purposes.

6. How we manage your data

We will treat your personal information fairly and lawfully and we will ensure that information is:

• Processed for limited purposes;
• Kept up-to-date, accurate, relevant and not excessive;
• Not kept longer than is necessary;
• Kept secure.

Access to personal information is restricted to authorised individuals on a ‘need to know’ basis.

We are committed to keeping your personal details up to date, and we encourage you to inform us about any changes needed to ensure your details are accurate.

If you want us to routinely share your information with someone acting on your behalf (such as a family member), giving us written authorisation to do so will make this process easier.

We store data in the UK, mainly on our internal systems and in our offices. We may make use of certain online services which means your data will transfer internationally as part of the delivery of that service. Where international transfers occur we ensure that there are legal safeguards in place to protect your data.

We do not generally undertake "automated processing" or “profiling”, which means handling your data or making decisions without any human involvement.

7. How long do we keep information for?

We will only hold your records during the period of our relationship with you and for a set retention period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us. The specific retention period will depend on the circumstances, and the normal retention periods we apply are set out in our Data Retention Policy which is available on the Ocean Housing website at www.oceanhousing.com/policy-and-procedures/

8. Your rights, and if you aren’t happy about how we are handling your information

Under data protection law you have a number of legal rights as it relates to your personal data held by us. The rights available to you will depend on our reason for processing your information.

The rights that may be available to you include the following:

• Your right to make a subject access request: This always applies. You can ask us for more information about how we use your personal data and receive a copy of personal data we hold about you.

If you make a request, we will normally aim to respond within one month. Because this right can be wide ranging, we have found that if you can be specific about what information you are interested in obtaining (for instance, if you are only interested in information about a specific time period) you are more likely to get what you are interested in more quickly.

In responding to your subject access request, we will normally ask you to confirm your identity, typically by providing a copy of a passport or driving licence. If we do hold information about you, we will also provide you with a description of the data and provide you with a copy of the requested personal data in a legible form or a commonly used electronic form.

In certain circumstances we may not be able to provide you with all of the information requested, for instance if the data sought relates to a third party. You can read more about this right here.

• Rectification: You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies but there are circumstances in which we can refuse to comply. You can read more about this right here.
• Your right to erasure: You have the right to ask us to consider erasing your personal information in certain circumstances. You can read more about this right here.
• Your right to restriction of processing: You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about this right here.
• Your right to object to processing: You have the right to object to processing if we are processing your information as part of our public tasks, or in our legitimate interests, such as when we are marketing or advertising services. You can read more about this right here.
• Your right to data portability: This only applies to information you have given us and we are processing by automated means (i.e. excluding hard copy files). You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about, entering into a contract with you.  You can read more about this right here.
• Your right to be informed of how and why we are processing your personal data. You have a right to be informed that we are processing your information, and the details of how are included in this Notice. You can read more about this right here.
• Your right to be informed about decisions being made without human intervention. When decisions are made about you without people being involved, this is called ‘automated individual decision-making and profiling’ or ‘automated processing’, for short. You can find out more about this right here.

Your right to raise a concern. You have the right to raise a concern about the way Ocean are processing your data. You can find more about this right here. If you would like to exercise any of the above rights, please contact us. The best way to do this is by writing to:

Data Protection Officer, Ocean Housing, Stennack House, Stennack Road, Holmbush, St Austell, Cornwall, PL25 3SW or alternatively, email your request to dataprotection@oceanhousing.co.uk or help@oceanhousing.com.

You can also call us on 01726 874450.

You may make a complaint to the Information Commissioner's Office about how we process and collect your data. You can do so by contacting their office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone 03031 231 113 or 01625 545 745. www.ico.org.uk