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Privacy Notice

We are committed to ensuring that the personal data of our tenants (current, former, and future) is handled in accordance with the principles set out in the UK General Data Protection Regulation (GDPR) and The Data Protection Act (DPA) 2018. This Privacy Notice tells you what to expect when EPIC Housing collects personal information about you. It applies to applicants for housing, tenants and members of their household, former tenants, visitors to our properties and schemes, and visitors to the EPIC Housing website.

Please read this notice carefully and make sure that you understand your rights and responsibilities.

From time to time, as our organisation evolves and develops, we may update and make changes to this privacy notice.

Who We Are

Empowering People Inspiring Communities (referred to as EPIC Housing) is committed to protecting and respecting your privacy whilst remaining compliant with the General Data Protection Regulation (EU GDPR) and the Data Protection Act (DPA). This statement sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Empowering People Inspiring Communities is the Data Controller and has an appointed Data Protection Lead who can be contacted via:

Registered Office – 131-141 Ubberley Road, Bentilee, Stoke-on-Trent, ST2 0EF Telephone: 01782 252575

Email: dpo@epichousing.co.uk

We keep this privacy statement under regular review, and this notice was last updated on 21 June 2024.
Application

Our Privacy Notice applies to all the personal data EPIC collects and uses. It applies to all our staff and partners.

We hold a range of data relating to individuals and tenants; this data can be known as personal data or personal information. This data is collected for the purposes of supplying services and discharging our legal obligations.
The type of personal information we collect

We may collect and process the following data about you:

Information that you provide by filling in forms on our website (www.epichousing.co.uk) or by corresponding with us by phone, email or otherwise. The information you give us may include:
- Name and Company Name
- Email address
- Telephone numbers
- Date of Birth
- Gender
- Nationality
- Current and former addresses
- National Insurance number
- Current and former landlords
- Personal details of people to be housed with you
- Details of your income from employment, tax credits and welfare benefits
- Details of savings over a specified amount
- Details of any current or previous property you own either in the UK or abroad
- Details of convictions that are relevant to your housing application and have not been spent under the terms of the Rehabilitation of Offenders Act 1974
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them
- Details of your visits to our website and the resources that you access
In some cases, we may collect more sensitive information, which may include:
- Race, ethnicity, nationality, sexuality, and disability information to make sure the services we provide meet the needs of our diverse tenant groups and help to highlight any additional service opportunities
- Financial information to help us provide welfare and benefits advice to you to help you budget and pay your bills
- Health information when we need this to support adaptations to be made to the property you are living in or because of additional support
- Particular needs or preferences so that services can be better tailored to your requirements
So that we have an accurate picture of the people within our properties, we will also capture information for all people living within a property, including children. This helps us to understand and support our tenants to sustain their tenancies as well as inform future decision-making.

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.
Special category data

We routinely process the health data of housing applicants, tenants, and residents where it is relevant to their housing needs and the provision of our services. We rely on GDPR Article 9 2(b), and the Data Protection Act (DPA) 2018 Schedule 1, Part 1 (1) (social security and social protection).

When we deal with antisocial behaviour complaints, we will process special category data under Substantial Public Interest (GDPR Article 9 (g)) and the DPA 2018 Schedule 1, Part 2 (10) (Preventing or detecting unlawful acts).

We also collect faith, race, and sexual orientation data to monitor equality, diversity, and inclusion to help ensure our services are delivered fairly. The lawful basis we rely on to process this information is Consent and the DPA 2018, Schedule 1, Part 2 (8) (Equality of opportunity and treatment).

We collect information that you provide about criminal convictions and offences so that we can safeguard our employees and the communities where we are the landlord. The lawful basis we rely on to process this information is the Employment and Social Protection Law (GDPR Article 9 2(b)) and the DPA 2018, Schedule 1, Part 1 (Employment, Social Security and Social Protection).

The DPA 2018 requires us to have an Appropriate Policy Document (APD) for certain conditions of processing special category and criminal offence data. Our APD is our Data Protection Policy, and this sets out and explains our procedures for securing compliance with the principles of GDPR and policies regarding the retention and erasure of such personal data.
How we get personal information and why we have it
Housing Applications
To assess housing applications, eligibility, and complete tenancy sign-ups. The lawful basis we rely on for processing the following personal data is Article 6(1)(b) of the GDPR, processing necessary to Perform a Contract or to take steps at your request, before entering a contract.

We will need your name and contact details (including telephone numbers, email addresses and details of anyone you may choose to represent you) for use across the organisation and by our contractors, suppliers, and partners. We will collect detailed personal information about you and other household members, including previous addresses, age, date of birth, National Insurance number, income and benefits details, employment status, relationship status, nationality, caring responsibilities, and bank details.

We will also collect information about any disabilities, any communication and accessibility requirements and medical information relevant to your housing needs. Please see the section above headed Special Category Data for more information.

We process data about criminal convictions and offences with your consent under Article 10 of the GDPR and the DPA 2018, Schedule 1, Part 2 and Part 3.

Managing Tenancies
To manage your tenancy, we continue to rely on the lawful basis of the processing being necessary for the Performance of a Contract, Article 6(1)(b).

We need up-to-date contact details (telephone number and email address) so we can reach you when we need to discuss issues pertaining to your tenancy, e.g. rent collection, access for maintenance, repairs and improvements, if we need to arrange a home visit or to contact you in the event of an emergency or to enforce the terms of your tenancy. We keep details relating to the repair, maintenance, and servicing such as gas & electricity inspections of your home (although this information will not necessarily constitute your personal data).

Financial records about the amount of money you have paid us, any amount(s) outstanding and associated recovery action. Depending on the method of payment, we may hold your bank account details.

We would like to keep records of your circumstances up to date and ask that you help us to do this (e.g. if you have a medical need that means your housing requirements need to be re-assessed we would ask for supporting information about your change in health needs) or to effect any changes to your tenancy (e.g. if you want to change your name on our records we ask for a copy of your marriage or deed poll certificate).

We carry out the following processing because it is in our Legitimate Interest (Article 6(1)(f)) to provide the best service we are able.

We will use your contact information to tell you about changes at EPIC Housing that affect you. We will hold records of all our contact with you and any contact from third parties representing you or about you.

We are under a Legal Obligation, Article 6(1)(c) and there is often a public interest in carrying out a Public Task, Article 6(1) (e) of the GDPR, to carry out the following processing.

To prevent fraud and illegal sub-letting and to confirm your ongoing eligibility for housing. To investigate and resolve complaints or housing management issues such as Anti-Social Behaviour which may result in us collecting relevant To investigate and resolve complaints or housing management issues such as Anti-Social Behaviour which may result in us collecting relevant information about you.

Right to Buy/Right to Acquire
If you approach us regarding your Right to Buy or Right to Acquire entitlement the lawful basis we rely on for processing your personal data is Article 6(1)(b) of the GDPR, which relates to processing necessary to Perform a Contract or to take steps at your request, before entering a contract.

Resident Involvement
As a tenant, we may approach you to take part in our resident involvement activities. We further process your information in relation to this as a Legitimate Interest to improve our services, Article 6(1)(f). Your participation will be for a specified period, and you may withdraw your consent at any time.

Security
We operate CCTV for the prevention of crime at our office premises in Ubberley Road, Stoke-on-Trent (both outside and inside).

We carry out the above processing because it is in our Legitimate Interest (Article 6(1)(f)) to secure our properties and it is in the Public Interest (Article 6(1)(e)) to prevent crime and anti-social behaviour.

Marketing
If you consent to us sending emails when you sign up for your tenancy, through our website or at an event or meeting, we will send you these until you withdraw your Consent (Article 6(1)(a) of GDPR). You can do this by clicking on the unsubscribe link in each email or by contacting us.

If you are a Tenant, we will send you emails using our Legitimate Interest (Article 6(1)(f) of GDPR). You can unsubscribe from marketing emails at any time. We may declare some emails or text messages as Service Messages which are not subject to marketing rules.

Tenant Surveys
The Regulator of Social Housing (RSH) requires Housing Associations, such as EPIC Housing, to engage with customers over the delivery and performance of our services. We carry out this processing because it is in our Legitimate Interest (Article 6(1)(f)). We have a legitimate interest in contacting you and finding out how we can improve our service through our market research surveys. We also have a legitimate interest in making our products and services the best that they can be and promoting the success of our organisation. We may write to you, email, text or call you in order to gather any information.

Where we collect personal data
We get information about you from the following sources:
- Directly from you
- Local Authorities, such as Stoke-on Trent City Council, who refer housing applications to us
- Referees you provide, previous landlords and employers
- Social workers, medical professionals, credit reference agencies and mortgage lenders who provide us with information relevant to your housing application and needs
- EPIC employees and contractors who deal with tenants
- CCTV images that we operate at our offices
If you provide us with personal information relating to members of your family, household, or associates we will assume that you do so with their knowledge.
Retention of data

EPIC Housing will retain:
- Unsuccessful tenancy applications for 6 months
- Details of Tenancies for 7 years after the termination date
- CCTV recordings for 30 days
We may deviate from the above where:
- We are legally required to retain information for longer;
- The information relates to a complaint;
- We are preparing information in relation to a legal claim.
The above and all other information we keep, and how long we keep it for, is defined on our retention schedule.
Sharing your personal data

EPIC Housing is committed to respecting and protecting your personal data. In certain circumstances, we may need to share your personal data with other organisations in order to fulfil contractual obligations. When we share personal data to complete a task, we will only share the minimum personal data required to complete that task. We will never sell, rent, or trade your personal data.

We will pass your information on to third parties whom you may ask us to, for example, if you ask us to put you in contact with professional advisers.

We may share your data with the following organisations:
- Repair and maintenance contractors
- Payment providers
- Local Authorities in relation to Council Tax liability and Housing Benefit claims
- Department of Work and Pensions in relation to Universal Credit claims and/or deduction of rent from welfare benefits
- Utility Companies to ensure utility bills are processed correctly at the start and end of a tenancy
- Ministry for Housing, Communities and Local Government in relation to new lettings or sales of social housing
- Debt Collection Agencies – where your tenancy agreement with us ends and there is a debt still outstanding
- Auditors, business associates and professional advisers
- Charities and voluntary organisations
- Emergency services
- Health authorities, healthcare, social and welfare organisations, probation services
- Survey and research organisations
- Other landlords, housing associations and property exchange platforms
Your data protection rights

Under data protection law, you have rights that we need to make you aware of. The rights available to you depend on our reason for processing your information.

Your right of access
You have the right to request a copy of the information we hold about you. This is known as a ‘subject access request’ (SAR). This right always applies. There are some exemptions, which means you may not always receive all the information we process. Please contact dpo@epichousing.co.uk if you wish to request access to your personal data. We will respond within 1 calendar month of receiving your request, provided we have all the details we need to find the information we hold about you. Please try to be specific about what personal data you want to see, what it relates to and the timeframe, as that will assist our search.

Your right to rectification
You have the right to ask us to rectify personal information you think is inaccurate or ask us to complete information you think is incomplete. This right always applies. If you think any of the information we hold is inaccurate or out of date, please advise us of any corrections via email at dpo@epichousing.co.uk

Your right to erasure
In certain circumstances, you have the right to have your information erased from our records. You can do this where:
- the information is no longer necessary in relation to the purpose for which we originally collected/processed it;
- you withdraw consent;
- you object to the processing and there is no overriding legitimate interest for us continuing the processing;
- we unlawfully processed the information;
- the personal information has to be erased in order to comply with a legal obligation.
We can refuse to erase your personal information where the personal information is processed for the following reasons:
- to exercise the right of freedom of expression and information;
- to enable functions designed to protect the public to be achieved e.g., government or regulatory functions;
- to comply with a legal obligation or for the performance of a public interest task or exercise of official authority;
- for public health purposes in the public interest;
- archiving purposes in the public interest, scientific research, historical research or statistical purposes;
- the exercise or defence of legal claims; or
- where we have an overriding legitimate interest in continuing with the processing.
Your right to restriction of processing
When processing is restricted, we can store the information, but not do anything with it. You can do this where:
- You challenge the accuracy of the information (we must restrict processing until we have verified its accuracy);
- You challenge whether we have a legitimate interest in using the information;
- If the processing is a breach of the GDPR or otherwise unlawful;
- If we no longer need the personal data but you need the information to establish, exercise or defend a legal claim.
If we have disclosed your personal information to third parties, we must inform them about the restriction on processing, unless it is impossible or involves disproportionate effort to do so.

Your right to object to processing
Where we say processing your information is in our legitimate interests, we must stop using the information unless we can show there is a compelling legitimate reason for the processing, which overrides your interests and rights, or the processing is necessary for us, or someone else to bring or defend legal claims.

Your right to data portability
This only applies to the information you have given us. 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 understanding, or in talks about entering into a contract and the processing is automated.

Your right to withdraw consent
Where the lawful basis for processing is consent, you have the right to withdraw that consent. Should you wish to withdraw your consent, please contact us immediately. Processing based on consent is likely to be limited to photographs at events or for equal opportunity monitoring. Withdrawing consent will not affect the legality of processing carried out before consent is withdrawn, e.g. a leaflet will not be recalled where this has already been distributed.
Data processors

Where we use data processors, we have a written agreement with them that ensures your data is protected and secure.

We have a legitimate interest in ensuring utility bills are accurate and assigned to a new tenant. We use a utility broker as a single point of contact to liaise with tenants, EPIC Housing and the utility companies.

When you move into an EPIC Housing property we share your name, contact details and the start date of your tenancy with the utility broker, Energy Angels https://energyangels.co.uk/

We use contractors to carry out property repairs and maintenance to whom we give your contact details so that they can liaise with you.

We use several technology data processors to store data and provide electronic communications.
Transfers to third countries

Where we transfer data outside of the UK, we will only do so in compliance with the GDPR transfer rules.
Website cookies
Cookies are small text files placed on your computer by the websites you visit. They are used to help make websites work efficiently. You can control cookies through the settings of your web browser. To find out more, visit www.aboutcookies.org or www.allaboutcookies.org.

These are the cookies we use when you visit our website:
- Google Analytics – to monitor website use and the type of browser that is accessing the website.
Automated Decision Making and Autoprofiling

We use email monitoring services to monitor the emails which we send to users. In doing this, we obtain information such as but not limited to:
- Time of receipt;
- Time of opening;
- Device used to open;
- Location it was opened in; and
- Which parts of the email you interacted with.
Further information and complaints

Please contact us if you have any queries about the personal information we hold and how we use it.

If you have any concerns about our use of your personal information, you can make a complaint to us at Head of IT, People & Change, 131-141 Ubberley Road, Stoke-on-Trent, ST2 0EF or via email: dpo@epichousing.co.uk

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

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