Privacy Notice - Applying for a home

Who we are

Homes4D&G is a common housing register that consists of four Registered Social Landlords and Dumfries and Galloway Council.  The four partners are; Wheatley Homes South, Riverside Scotland, Home Group and Cunninghame Housing Association.

Wheatley Group along with the partner you apply to be housed with will be the "data controllers" of the personal information that you provide to us. This will include personal information about you as a prospective tenant and about the people you wish to live with. This information is required to assess your eligibility for housing.

Wheatley Group manage all data on behalf of Wheatley Homes South as the lead partner within Homes4D&G.

If you are a Wheatley Homes South customer (part of Wheatley Group), applying for a Homes4D&G property through MyHousing this Privacy Notice will apply to you.

Each Homes4D&G partner has their own Data Protection Officer (DPO).  You can find the name and contact details for the DPO on the partner websites.

What we need

When you submit an application for housing to Homes4D&G we will ask you for the following personal information:

• Your full name (and proof of your identity / photo ID);

• Your tenure and current housing circumstances;

• Date of birth;

• National Insurance number (customers unique identifier);

• Contact details (phone, e-mail or correspondence address);

• Details of anyone authorised to act on your behalf if applicable;

• Basic details (name and DOB) of all household residents including any children;

• Banking details if you pay your rent by Direct Debit;

• Proof of housing eligibility, any interest or equity in other property from 2019;

• 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, rent arrears;

• Other details - e.g employment details, current involvement for you or your family with any of the Homes 4D&G partner organisations including all Wheatley Group subsidiaries;

• Equality, 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 customers make a decision around affordability and resolve any housing debt/arrears and provide welfare benefits, fuel and debt advice as a free service to help customers budget and pay bills. We may use this to apply for funding on a customer’s behalf;

• Health information. When we require this to make decisions on the property type customers may require, support needs including carer information or details of another person you may support and support funding for adaptations made to the property a customer is living in. More specific details are provided if you use this service;

• Medications aids adaptations and social support;

• Requirement to register RSO; and

• Assessment of risk posed by an individual.

We may transfer information about you to other Homes 4D&G partners and their subsidiaries for purposes connected to your tenancy application or the management of their business.

Children’s information

We do not usually process children’s information as part of the Housing Options or Housing Application process, as all applicants are adults. However, we may record children’s names, dates of birth, health and wellbeing information if they are to be resident in one of our properties. 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 at a later stage 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.

Why we need your personal information - Contractual Purposes and Legal Obligation

We need to collect your personal information so that we can assess your eligibility for and manage your Housing Application, if successful.  We will use your personal information to assess your Housing Application for a home with us and award priority for housing.

We are also under a legal obligation to process certain personal information relating to our tenants and applicants for the purposes of complying with our obligations under:

• Housing (Scotland) Acts 1987, 2001, 2006, 2010 & 2014

• Homelessness etc. (Scotland) Act 1987 and 2003

• Antisocial Behaviour etc. (Scotland) Act 2004

• Matrimonial Homes (Family Protection) (Scotland) Act 1981

• Children Scotland Act 1995

• Children and Young People (Scotland) Act 2014

• Civil Partnership Act 2004

• Immigration and Asylum Act 1999 & Immigration Act 2014

• Protection from Harassment Act 1997

• Management of Offenders etc. (Scotland) Act 2005

• Freedom of Information (Scotland) Act 2002

• UK General Data Protection Regulation

• Data Protection Act 2018

If you do not provide us with all of the personal information that we need to collect then this will affect our ability to process your Housing Options Application and/or Housing Application.

Why we need your personal information – legitimate purposes

We also process your personal information in pursuit of our legitimate interests to:

• Issue communications to our applicants regarding Housing services, including letters, newsletters, emails and texts;

• Carry out customer segmentation research to allow us to help us better understand our customers’ characteristics and prioritise, tailor and target services to you

• Undertake research and statistical analysis to help improve our business processes and the services offered to our customers, as well as to evaluate our performance against other benchmarks.  Where possible, statistical information is anonymised or pseudonymised; and

• We may also conduct surveys regularly and periodically relating to our services in order to gauge satisfaction and make improvements based on feedback.

As part of the Housing Application process we request your national insurance number in pursuit of our legitimate interest to future proof our services. You may choose not to provide this information to us.

Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes.  If you wish to object to any of the above processing, please contact us on InformationRequests@wheatley-group.com.  If we agree and comply with your objection, this may affect our ability to undertake the tasks above for your benefit.

Why we need your personal information – equality monitoring requirements

We are required to use your personal information relating to your health, racial or ethnic origin for equality monitoring purposes as required by government departments and agencies, Scottish Housing Regulator and auditors, with other organisations and agencies where we are legally allowed to do so.

We will process such personal information to identify and keep under review the existence or absence of equality of opportunity or treatment between groups of people within the same categories to promote or maintain equality within our Group.

Other uses of your personal information

We may ask you if we can process your personal information for additional purposes. For example, 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.

Where we do so, we will provide you with an additional privacy notice with information on how we will use your information for these additional purposes.

Who we share your personal information with

We share limited personal data with our contractors who are carrying out services on our behalf for example to carry out research, survey and segmentation on our behalf to help us to improve the services we offer to you. Our contractors are required to comply with the law and our own Data Processing Agreement or Data Processing Clauses within our contracts to ensure data is managed appropriately and for specified purposes.

As part of the application process you will be asked if you are interested in a mutual exchange.  If you answer yes to this your information will automatically be sent to a third party website owned and managed by House Exchange. The following information will automatically be sent to House Exchange:

• Name;

• Address;

• Email address; and

• Telephone number

Once registered you will be able to provide a description of your home, including features, restrictions and adaptations and can, if you choose, upload up to five photographs of the interior and/or exterior.

You will also be asked to provide information on the location, property type and size of home they are seeking.

How we protect your personal information

Your personal information is stored on our paper and IT filing systems which may be copied for testing, backup, archiving and disaster recovery purposes. Access to your information is limited to those who require it to provide services to you. All data is held within the UK.

If any of your personal information is transferred out with the European Union or the European Economic Area by any of our contractors we will ensure that there are adequate safeguards in place to protect your personal information in accordance with the General Data Protection Regulations and applicable UK Data Protection Legislation.

How long we keep your personal information

Wheatley Homes South has a data retention policy that sets out the periods for retaining and reviewing all information that we hold.  You can request a copy by sending an e-mail to  informationrequests@wheatley-group.com.

Your rights

You can exercise any of the following rights by writing to us at InformationRequests@wheatley-group.com

Your rights in relation to your personal information are:

• you have a right to request access to the personal information that we hold about you by making a "subject access request";

• if you believe that any of your personal information is inaccurate or incomplete, you have a right to request that we correct or complete your personal information;

• you have a right to request that we restrict the processing of your personal information for specific purposes; and

• if you wish us to delete your personal information, you may request that we do so.

Any requests will be considered under applicable UK Data Protection Legislation.  If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner's Office at www.ico.org.uk