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As a housing association Phoenix holds lots of personal information about our residents and other people who use our services. We use this information to manage tenancies and leases and to deliver other services that benefit our wider community.
We want everyone to understand what information we collect, how we use it and what you can do if you have any questions.
Full information and details of our privacy notice, recruitment privacy notice, website privacy notice and data protection policy and retention guidelines are available on this page.
This privacy statement sets out how Phoenix Community Housing collects and processes personal information about visitors to our website.
The cookies we use and why
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You can read Google's overview of privacy and safeguarding data here.
To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
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|We embed videos from our official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally-identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode.
You can read more at YouTube’s embedding videos information page here. http://www.google.com/support/youtube/bin/answer.py?hl=en-GB&answer=171780
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|We embed a Twitter widget into our website to show you the latest Tweets from the official Phoenix Community Housing Twitter feed. We embed this feed using Twitter’s privacy guidelines, and you can find out what information Twitter collects and how it uses that information here.
How do I change my cookie settings?
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.
You can also find out how to manage cookies on most popular browsers:
To find information relating to other browsers, visit the browser developer's website.
You can access most of the pages on the Phoenix Community Housing website without supplying any personal information. However, you will need to supply personal information when completing certain forms.
We will use your personal information to respond to your enquiry. The personal information you provide will be stored and retained securely and treated in accordance with our Data Protection Policy, the General Data Protection Regulation and any succeeding acts. Our data protection policy and privacy notices are available on our website and on request by calling 0800 0285 700.
We may produce reports on the use of forms on our website to enable us to monitor and develop them. These reports will be based on anonymous data, which means that individuals will not be identified in the reports.
My Phoenix - Self Service Portal
Phoenix tenants can register to use our ‘MyPhoenix’ self service portal. When you sign up to the service, we will use the information you provide to confirm your identity as a Phoenix tenant and to set up an account for you.
The information you provide will be used to set up your account and to ensure the safety and security of your account. We will also use the information you provide to update your contact details on our secure housing management database. The information you provide will be stored and retained securely and treated in accordance with our Data Protection Policy, the General Data Protection Regulation and any succeeding acts.
Phoenix Community Housing Association Bellingham and Downham LTD (“Phoenix Community Housing”, “Phoenix”, “We”, “us”) is a Community Benefit Society (registration number 30057) with registered office at The Green Man, 355 Bromley Road, London, SE6 2RP.
Phoenix Community Housing is the parent of a wholly owned subsidiary Phoenix Agency Services LTD (Trading as Phoenix Repairs Service), registration number 8436155.
Data Protection People Limited have been appointed to act as our Data Protection Officer.
Registration with the Information Commissioner’s Office
Phoenix Community Housing is registered with the Information Commissioners Office with registration number Z1309257
Phoenix Repairs Service is registered with the Information Commissioners Office with registration number ZA249958
Aim of this notice
Your information is protected by law. Data Protection law allows us to collect and use your personal information if we have a lawful reason to do so. This privacy notice is to let you know how we handle your personal data under the Data Protection Act, General Data Protection Regulation (GDPR) and any acts or legislation that supersede them.
What is personal data?
Personal Data means any information relating to an identified or identifiable natural person. It includes name address, location data an on line identifier or one or more factors specific to the physical physiological, genetic, mental economic cultural or social identity of that natural person.
Our Privacy Promise
Phoenix Community Housing Association promises:
What information do we collect?
We collect information about you when you make an application to us or a request is made by you for one of our services. We also collect information when you voluntarily complete customer surveys, provide feedback or where there is general correspondence and communication. Further information may be collected during the course of your tenancy, lease or during the period we provide services to you.
The table below sets out what personal data we process, our purpose for doing so and the lawful purpose for processing it.
|What personal data we process||Our reason for doing so||Our lawful justification|
|Applications for housing and updated details (if you have a tenancy or lease with us, our active housing application) about you and your children, including name, date of birth, address, contact details, identification (including National Insurance number employment details, details of any disabilities in your household related to your housing needs), other documents provided to us||Allocating homes, delivering and managing our services as set out in your tenancy or lease, identifying you are who you say you are.
For the prevention and detection of crime.
|Performance of a contract, Legitimate Interest
|Details about you including name, date of birth, address, contact details, identification (including National Insurance number), current and past employment details, welfare benefits. Number of children, disability.||To provide you with services at our Job Club.
To provide you with financial inclusion support
|Details about your home, household and your housing needs and tenancy agreement.||Allocating homes, delivering and managing our services as set out in your tenancy or lease||Performance of a contract|
|Welfare benefit referrals, Housing benefit and Department of Work and Pensions notifications, rent and service charge statements||Delivering and managing our services as set out in your tenancy or lease||Performance of a contract Legal obligation|
|Applications for the Right to Buy and Right to Acquire and supporting documents||To process your application
For the prevention and detection of crime.
|Performance of a contract
|Rent and service charge information, including details of any arrears.||Allocating homes, delivering and managing our services, making financial arrangements related to your home (setting up council tax payments), informing relevant local authority departments and the Department of Work and Pensions to enable you to claim benefits||Performance of a contract, Legitimate interest|
|Financial information, including any credit checks, income details, bank details, housing benefit information and any guarantor details.||To make financial arrangements related to your home, such as to enable automatic rent payment through direct debit, housing benefit payments, benefits direct from the Department of Work and Pensions and set up your council tax payments
To set up arrangements relating to your home, such as informing the Local Authority departments of your tenancy arrangements for council tax and housing benefit purposes
To help other people or companies to provide services or utilities to your home or to contact you. This may include where they need to contact you when you first move in to set up payments or about any unpaid bills while you live at your home and/or after you leave your home.
|Performance of a contract, Legal Obligation, Legitimate Interest|
|References received about you (e.g. from your employer or previous landlord).||Allocating homes, managing our services, administration||Performance of a contract|
|Medical information & emergency contact details, next of kin & any advocate, Information about any accidents or incidents which involve you or your home.
(Any medical information shared will be limited to a need to know basis)
|To provide information to our staff to enable them to provide services to you to meet your needs when managing and delivering the services set out in your tenancy or lease and to train and protect them where necessary
To deal with any medical or other emergencies and to carry out your wishes or Requirement’s such as any religious or cultural wishes;
To act in someone’s best interests such as where we have concerns about a person’s health or welfare and may need to involve agencies such as Social Services or the police.
Social Protection Law or Protecting Vital Interests in extreme circumstances.
|Information about any complaints made by you or which relate to you.||To handle any complaints.
Delivering and managing our services as set out in your tenancy or lease
|Performance of a contract
|The way in which you conduct your tenancy if you are in breach of your tenancy conditions
If we deem there to be a risk to the safety of individuals, we may place a flag over your tenancy. When we do so, we will inform you and ensure that these flags are regularly reviewed.
|Delivering and managing our services as set out in your tenancy or lease.
Delivering and managing our services
|Performance of a contract
|Information regarding your marketing preferences.||To deliver marketing materials such as information about our Job Club||Consent|
|Any photographs taken of you or your property.||Monitoring defects, assessing any health & safety risks, managing and delivering services as set out in your tenancy or lease. Checking you are who you say you are||Performance of a contract
|Any marketing materials / photos of you and or your children taken at events.||To promote our services.||Your children|
|Ethnicity data, Sexual Orientation and Religious Beliefs||To ensure fair and equal access for all to our services;
To help us put together statistics to give to our regulator or other government organisations, (in this instance your details will be anonymised)
|Your consent for Equal Opportunities Monitoring|
|Convictions, proceedings and criminal acts||To respond to legal claims, to deliver our services, safeguarding, The apprehension or prosecution of offenders.
To meet Social Protection Law, Legal obligation, Employment law, Prevention and detection of crime
|Performance of a contract,
|Call Recordings||To investigate complaints related to services we provide as set out in your tenancy agreement or lease.
To improve our services.
|Performance of a contract,
(this will be anonymised as soon as possible)
|To check on and improve our services as set out in your tenancy agreement or lease.
To check on and improve our services
|Performance of a contract,
|CCTV footage||For the prevention and detection of crime.||Legitimate interest|
Applying for a job
If you apply to work for Phoenix, we will use your personal information to process your application and to produce and monitor recruitment statistics. We will not take up references without your prior permission. We will not share or disclose your information when you have applied for a job, unless you have given us your consent or we are required to by law. Where we are required to carry out a Disclosure and Barring Service (DBS) check we will comply with the law and your rights when carrying out these checks.
Please see our separate recruitment privacy notice.
What are Legitimate Interests?
A wide range of interests may be legitimate interests. They can be Phoenix’s interests or the interests of residents, third parties or commercial interests as well as wider societal benefits. When we rely on any legitimate interest, we will ensure that we take a balanced approach and have appropriate safeguards in line with your expectations. If we rely on any legitimate interest, we will tell you what that is.
Our legitimate interests include:
We have data retention guidance which sets out how long we will keep personal data and in what circumstances. This is available on our website www.phoenixch.org.uk , by emailing firstname.lastname@example.org or by calling us on 08000285700.
How will we collect this information?
Information will be collected from you personally when you enter into an agreement / contract with us. This will be in the form of applications and any other forms which may be completed in order to apply for one of our properties or to update your details.
It is possible that we will receive referrals containing your information from public bodies or voluntary organisations, but this should be done with your consent and knowledge of why they are making the referral to our services.
We may generate further personal data regarding our tenants during the course of the tenancy. This could be in the form of general correspondence, or this may need to be generated to satisfy our statutory obligations.
Who will we share it with?
Where information is used for the reasons listed above, we may need to share the information about you and the people you live with other organisations. This will include:
|Who we share your information with||The purpose for sharing it||Our justification for sharing|
|Companies which provide services or utilities to your home (such as the gas or electric companies) and the relevant Council Tax Department.||Payment of these services||
|People who provide services on our behalf, such as a managing agent or contractors carrying out any repairs.||Delivering Services in your tenancy agreement or lease||Performance of a contract|
|A credit reference agency, your bank and mortgage company or other financial institutions and (where necessary) a debt collection and/or tracing agency.||Allocating and managing properties and your tenancy or lease.||Performance of a contract.
Where debt collection agencies are involved, this will be in our legitimate interest.
|An agency who will add your rent payment history into your credit report||To treat homeowners and tenants equally by including payment history to inform your credit reference.||Consent|
|The Housing Benefit department and other Government departments which provide funding for your housing services. In particular, we may be legally required to give information about any changes in your financial circumstances to the Housing Benefit department.||Legal requirement.||Legal obligation.|
|Resident Panel Members, Designated Officer, the Housing Ombudsman
involved in the final stage of our complaints process.
|Delivering Services in your tenancy agreement or lease||Consent
Performance of a contract
|A doctor, hospital, paramedic or health worker.||Where you require medical attention and are unable to provide the information yourself.||Your consent, in line with Social Protection Laws, Amendment 85|
|Our legal advisors, the courts and the police. This may include information about antisocial behaviour.||Reducing ASB and fraud, the prevention and detection of crime.||Handling legal claims|
|People or agencies who provide services to you or who work with us to provide services to you, such as your care/support provider.||To deliver services||Consent|
|The bodies involved with your care/support such as the relevant Local Authority departments, or Social Services and any alarm call centre.||When the information is requested||Explicit Consent|
|Our regulator or other bodies which look at how we provide services as your landlord & other people where we are legally required to provide information to them.
(Your details will be anonymised)
|Legally required||Legal obligation|
|Your next of kin or other people acting on your behalf in an emergency and a member of your church or religious leader, where you have requested this.||When the information is requested||Consent|
|To another landlord or housing association where you are looking to move or exchange your property (e.g. where they request your details &/or a reference from us).||When the information is requested||Consent|
|Relevant Local Authority departments (including housing benefit, council tax, elections, adult services, fraud teams, fire brigade etc.)||Legal requirement||Legal obligation|
|To relevant people and authorities such as the police, adult and child protection and social services.||Social Protection, Prevention and Detection of Crime.||Social Protection law, Prevention and Detection of Crime.|
|Companies who process information on our behalf such as an external mailing company (who send out our newsletter), our archiving company, our confidential waste disposal company. Providers of our information technology services or software, companies doing surveys or research on our behalf||To enhance and deliver our services, maintaining records.||Legitimate Interest.
Performance of a contract
Phoenix contracts organisations to process personal data under written contracts or service level agreements which defines that they must meet our data privacy requirements. These organisations include but are not limited to:
Phoenix will not transfer your information outside of the European Economic Area without adequate safeguards. Phoenix does not transfer any personal data internationally, besides information transferred to SurveyMonkey and Campaign Monitor, which are both covered by the Privacy Shield.
If we did decide to transfer any personal data internationally, this will be in line with our internal procedure and the terms in this privacy notice will be updated.
Keeping your information secure
We store personal information both electronically and in paper form.
We implement security processes and technical security solutions to protect the personal information we hold from:
When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, support workers, solicitors) act on your behalf we will take steps to ensure that you have agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.
Employees and third parties who have access to, or are associated with the processing of your personal information, are also required to make reasonable efforts to safeguard it.
Automated Decision Making and Profiling
We do not make any decisions about you using automated means and we do not envisage this changing in the near future. If the situation does change, we will notify you in writing.
Phoenix does carry out profiling in the form of Rent Sense by Mobysoft in order to help facilitate rent payments and assist in the performance of the contract. To quote the RentSense website:
“RentSense is a series of complex algorithms that analyse a housing organisation’s tenants’ transactional history, which is coupled with a predictive analytical application that then predicts which tenants will and won’t pay their rent. It then produces a list of tenants, in priority order, that need contacting that week regarding their rent.”
We ask for people’s consent to market information. Further direct marketing may be conducted by post or by telephone under our legitimate interests.
If you do not wish to receive marketing material, or you would like to edit your preferences, please contact us. Unsubscribe options will also be offered.
Please note, opting out of marketing does not remove the ability for Phoenix to contact you regarding the delivery of services related to your tenancy or lease.
Visiting our websites
When you visit one of our websites, we collect standard internet log information for statistical purposes.
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.
Access to your information and correction
You have the following rights regarding your personal data:
|Rights available||Description of rights|
|Right to be informed||Individuals have the right to be informed about the collection and use of their personal data.|
|Right of access||You have the right to obtain confirmation from Phoenix as to whether or not personal data concerning you are being processed, and, where that is the case, access to that personal data.|
|Right to rectification||You have the right to oblige Phoenix to rectify inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed by providing a supplementary statement.|
|Right to erasure (right to be forgotten)||You have the right (under certain circumstances, but not all) to oblige Phoenix to erase personal data concerning you. This will never include current tenancy or lease details necessary to fulfil our contractual obligations, or any information we are required to process under law.|
|Right to restriction of processing||You have the right (under certain circumstances, but not all) to oblige Phoenix to restrict processing of your personal data. For example, you may request this if you are contesting the accuracy of personal data held about you.|
|Right to data portability||You have the right (under certain circumstances, but not all) to oblige Phoenix to provide you with the personal data about you which you have been provided in a structured, commonly used and machine-readable format.
You also have the right to oblige Phoenix to transmit that data to another controller.
|Right to withdraw consent||If the lawful basis for processing is consent, you have the right to withdraw that consent. If you wish to withdraw your consent, contact us immediately.|
|Right to object to direct marketing||Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for marketing, which includes profiling to the extent that it is related to such direct marketing.|
|Rights in relation to automated decision making and profiling||Phoenix does not perform any automated decision-making based on personal data that produces legal effects or similarly significantly affects you.|
Phoenix is not a scheduled body under the Freedom of Information Act and therefore does not have to respond to any requests under the Act.
For more information about any of your rights, please visit: https://ico.org.uk/for-organisations/guide-to-the-general-data-protectio...
Please contact us if you have any questions in relation with this notice or the information we hold about you:
The Green Man,
355 Bromley Road, London,
0800 0285 700
If you are not satisfied with the response you receive you have the right to lodge a complaint with the supervisory authority and the right to judicial remedy. In the United Kingdom this is:
Information Commissioner's Office
(t) 0303 123 1113
Other relevant documents
Staff Privacy Notice
Recruitment Privacy Notice
Data Protection Policy
Website Privacy Notice
Terms and Conditions of Gold Membership Scheme
This notice explains how Phoenix Community Housing Association (referred to in this notice as we, us or our) collects and uses information during the recruitment and selection process. This notice covers the following:
The table at the end of this notice provides an overview of the data that we collect, the purposes for which we use that data, the legal basis which permits us to use your information and the rights that you have in relation to your information.
We may update this notice from time to time.
Personal data is any information that tells us something about you. This could include information such as your name, contact details, date of birth, and references.
We collect personal data about you from various sources including:
We collect the following categories of information about you:
We use your information for the following purposes:
Under data protection legislation we are only permitted to use your personal data if we have a legal basis for doing so as set out in the data protection legislation. We rely on the following legal bases to use your information for employment/engagement related purposes:
The table at the end of this notice provides more detail about the information that we use, the legal basis that we rely on in each case and your rights.
Some information is classified as "special" data under data protection legislation. This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions, sexual orientation and trade union membership.
This information is more sensitive and we need to have further justifications for collecting, storing and using this type of personal data. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data.
We may process special categories of personal data and criminal conviction information in limited circumstances with your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent.
We share your personal data in the following ways:
Where we share your personal data with third parties we ensure that we have appropriate measures in place to safeguard your personal data and to ensure that it is solely used for legitimate purposes in line with this privacy notice.
Your personal data is kept securely in restricted folders. We will ensure access to personal data is restricted to employees working within our group on a need to know basis. Training will be provided to any employees working within the group who need access to your personal data to ensure it is secured at all times.
As a general rule we keep personal data about candidates for the duration of the recruitment and selection process and for a period of six months after candidates have been notified whether their application has been successful. However, where we have statutory obligations to keep personal data for a longer period or where we may need your information for a longer period in case of a legal claim, then the retention period may be longer.
You have a number of rights in relation to your personal data, these include the right to:
If you would like to exercise any of your rights or find out more, please contact us at email@example.com
The Table at the end of this notice provides more detail about the information that we use, the legal basis that we rely on in each case and your rights.
If you have any complaints about the way we use your personal data please contact People Services who will try to resolve the issue. If we cannot resolve your complaint, you have the right to complain to the Information Commissioner.
|Purpose||Data used||Legal basis||Which rights apply?|
|Personal contact details, national insurance number, recruitment information, employment/engagement records, and compensation history.||Legitimate interests. It is in our legitimate interests to evaluate whether you have the necessary skills and qualities to perform the relevant role.||The generally applicable rights plus the right to object.|
Right to work checks
|Information relating to your right to work status, national insurance number, passport number, nationality, tax status information, and personal contact details.||
Legitimate interest. It is in our interests to ensure that those who work for us have the right to work in the UK as well as to establish the statutory excuse to avoid liability for the civil penalty for employing someone without the right to undertake the work for which they are employed.
|The generally applicable rights plus the right to object.|
|Fraud and crime prevention||
Information about criminal convictions and offences committed by you. Identity verification information.
Public interest and legitimate interest. It is in our interests as well as the interest of our candidates/ employees/ workers/ contractors to ensure the prevention of fraud and crime is monitored. This will ensure a safe workplace for all.
|The generally applicable rights plus the right to object.|
|Diversity monitoring||Gender, marital status and dependents and information about your race or ethnicity, religious beliefs, health, sexual orientation.||Public interest.||The generally applicable rights plus the right to object.|
|To deal with legal disputes||
Personal contact details, references, information submitted as part of the selection process and interview notes.
Legitimate interest. It is in our interests to process personal data to make and defend legal claims to ensure that our legal rights are protected.
|The generally applicable rights plus the right to object.|
*The following generally applicable rights always apply: right to be informed, right of access, right to rectification, right to erasure, right to restriction and rights in relation to automated decision making.
Our data retention guidelines set out the timescales for which documents should be held for.
Under Data Protection Regulations you have the right to know whether we hold information about you. This means that you can ask for a description of the personal data which we hold, what purposes we use it for and who that data may be disclosed to. You are also entitled to a copy of your personal data.
You can make a subject access request in person, on the phone and by completing and returning this form. You should receive a written response and a copy of any appropriate documents within one calendar month of us receiving this form.
Please be aware that requests may be refused where;
• The information may cause harm to your mental or physical condition;
• Your identity has not been confirmed;
• Where requests are manifestly unfounded or excessive.