At Barnet Homes, we’re committed to protecting and respecting your privacy.
We may change this policy from time to time to reflect changes to the law and our ways of working. We recommend checking this page from time to time to make sure that you’re happy with any changes.
Things you can do to help us:
- tell us when any of your details change; and
- tell us if any of the information we hold on you is wrong
Any questions about this policy and our data protection practices should be sent by email to Talk2Us@barnethomes.org, or by writing to Barnet Homes, 3rd Floor, 2 Bristol Avenue, London, NW9 4EW. You can also phone us on 020 8080 6587.
Our Data Protection Officer is Neil Topping, working on behalf of ParaDPO.
Who are we?
When we use your personal data, Barnet Homes is what we call the data controller.
As the data controller, we must:
- only keep your data that we need to provide services, and do what the law says we must;
- keep your records safe and accurate;
- only keep your data for as long as we have to;
- collect, store, and use your data in a way that does not break any data protection laws.
Barnet Homes is an Arms-Length Management Organisation (ALMO) that is wholly-owned by the London Borough of Barnet and is incorporated in England (04948659). The registered address is 3rd Floor, 2 Bristol Avenue, London, NW9 4EW.
It is a member of The Barnet Group Limited. The Barnet Group includes Barnet Homes Limited, Your Choice (Barnet) Limited, TBG Open Door Limited (‘Opendoor Homes’), Bumblebee Lettings Limited, and TBG Flex Limited.
What is personal data?
Personal data is information about a living person that we can use to work out who they are, such as name, address, telephone number, date of birth, bank details, etc. This can include written letters, emails, photographs, audio recordings, and video recordings.
Some data is called ‘special category data’. This is more sensitive information, and we have to look after it more carefully. This includes details of ethnic origin, religious beliefs, sexual orientation, physical and mental health, trade union membership, and biometric (e.g. fingerprints, facial recognition) and genetic (e.g. DNA) data.
Why we collect and store personal data
For some of our services, we need to use your personal data so we can get in touch, or provide the service. In many cases there is a law that says we must or we can process your data, and we can do so without your consent or permission.
We use your data for the following reasons:
- Service delivery and communications
- Statutory requirements, including reporting to the government
- Service improvement and planning
- Regulatory and enforcement functions
- Prevention and detection of crime
- Financial transactions
- Research, including consultations
- Equality monitoring
- Safeguarding children and vulnerable adults
- To answer Freedom of Information and data protection requests
We will only collect, use and share your personal information where we are satisfied that one or more of the following legal bases apply:
- The processing is necessary for compliance with a legal obligation to which Barnet Homes is subject;
- The processing is necessary for the performance of a contract to which you are a party or in order to take steps, at your request, prior to entering into such a contract;
- The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- In certain circumstances, the processing is necessary for the legitimate interests pursued by Barnet Homes or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal information. Barnet Homes considers that it has a legitimate interest in processing personal information for the purposes set out above, and to support the achievement of its immediate and long-term business goals and outcomes.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest (or for official purposes).
- In exceptional circumstances with your consent, such as in consultations and when you use our website and give consent to web analytics (cookies).
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information. Where we rely on legitimate interests, our legitimate interests are to ensure the smooth running of and protect our business.
We may process special categories of personal information in the following circumstances:
- In limited circumstances, with your explicit written consent.
- Where it is needed in the public interest, such as to fulfil a function under the law, for equal opportunities monitoring, for the prevention of crime or fraud, to support individuals with a particular disability or medical condition, or for safeguarding purposes.
- Where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations.
Please see our Appropriate Policy Document for more information about how and why we process this special category data.
We are allowed to use your data due to a legal obligation or public task under various UK laws including, but not limited to:
- The Housing Acts 1988, 1996, 2002, 2004
- The Housing and Regeneration Act 2008
- The Homelessness Reduction Act 2017
- The Landlord and Tenant Act 1987
- The Localism Act 2011
- The Protection from Eviction Act 1977
- The Housing Benefit Regulations 2006
- The Welfare Reform Act 2012
- The Anti-Social Behaviour Act 2003
- The Crime and Anti-Social Behaviour Act 2014
- The Environmental Protection Act 1990
- The Health and Social Care Act 2012
- The Health and Social Care (Safety and Quality) Act 2015
- The Care Act 2014
- The Mental Capacity Act 2005
- The Mental Health Act 1983, 2007
- The Equality Act 2010
- The Digital Economy Act 2017
How do we collect information from you?
We will only collect personal information when we need it. Personal information means information which can identify you as an individual. When we ask you for information we will make it clear why we need it. We will also make it clear when you do not have to provide us with information, and any consequences of not providing this.
Most information we hold will be collected from you, but we may also obtain information from third parties such as the local authority, your doctor or other health professional, a previous landlord, or a community partner. We may also obtain information from publicly-accessible sources, or engage the services of market research organisations to validate, or where appropriate enhance the information that we hold. Barnet Homes collects personal information in a number of different ways including when you use our services on our website; and through customer agreements, tenancies, and leases (including for leaseholders and temporary accommodation); contracts (including employment contracts); forms; and general customer contacts (including phone calls, letters, emails, and face-to-face conversations). We also collect information when you voluntarily complete customer surveys, or provide feedback.
In some circumstances, personal information may be collected indirectly from monitoring devices or by other means (for example, CCTV, telephone logs, and email logs), if and to the extent authorised by applicable laws.
Apart from personal information relating to you, you may also provide us with personal information of third parties, notably your dependants and other family members, for purposes of tenancy administration and management, including someone to contact in an emergency. Before you provide such third party personal information to us you must first inform these third parties of any such information that you intend to provide and of the processing to be carried out by Barnet Homes, as detailed in this notice.
We may take photographs at events organised and hosted by Barnet Homes and its partners. The images may be used on our websites, in brochures, and in other publicity materials such as newsletters, and may be provided to the media for publication in local or national newspapers or magazines. You will always be given the option not to be included in photographs.
What type of information is collected from you?
The type of information we need from you will vary depending on our relationship with you.
We collect and hold personal information about prospective, current, and former customers who live in our properties or access our services and other support, have done in the past, or may do in the future. When you apply for housing with Barnet Homes we may request and hold information necessary to process your housing application and subsequently deliver services to you, or if you sign up for tenancy or other forms of support we may request and hold information necessary to process your application and subsequently deliver services to you, including:
- Personal details: your name and contact details (including telephone number(s), email address(es), and details of anyone you may choose to represent you);
- Detailed personal information about you and other household members*, including: age; sex; date of birth; ethnicity; National Insurance number; income and benefits details; savings information; employment or education status; job history, skills, and experience; gender identity; relationship status; any disabilities and any reasonable adjustments required as a result; any communication and accessibility requirements; religion or belief; sexuality; nationality; languages spoken; caring responsibilities; access to financial services such as banks and credit unions; bank details; council tax; medical information (including changes of circumstances); pregnancy information; records of our contact with you (including contact from third parties representing you or about you); financial records including the amount of money you have paid us, any amount(s) outstanding, and associated recovery action; credit status; property access codes; and details of any unspent criminal convictions
- References from other housing providers / private landlords;
- Information from third parties, including the Police, support workers, mental health workers, social workers, and credit reference agencies.
- Monitoring information (to the extent authorised by applicable laws): closed circuit television footage, and photo.
* When you provide information about household members and other associates, we assume that you do so with their full knowledge and consent.
We will also collect any information required by relevant legislation.
The information we collect, store, and use may include the following special categories of more sensitive personal information:
- Information about your nationality, race, or ethnicity.
- Information about your religious beliefs, sexual orientation, and political opinions.
- Information about your health, including any medical condition, health, and sickness records.
- Information about criminal convictions and offences.
Please see our Appropriate Policy Document for more information about how and why we process this special category data.
How is your information used?
How we use your information depends upon our relationship with you.
Subject to applicable law, your personal data may be stored and processed by us for the following purposes:
- Prioritise and assess your housing applications, service eligibility, and complete tenancy sign-ups, including:
- Verifying your identity
- Allocating properties
- Confirming eligibility for housing
- Manage your tenancy, lease, or contract, including:
- Resolving tenancy issues and disputes, including complaints or housing management issues such as anti-social behaviour.
- Processing financial transactions, including receiving rent, service charges, and other payments and benefits involving Barnet Homes, the London Borough of Barnet, and other government bodies (e.g. Department for Work and Pensions)
- Providing essential servicing, repairs, maintenance, and major works services
- Contacting you in the event of an emergency or to enforce the terms of your tenancy / lease / contract
- Contacting you to discuss your account
- Working with partners and contractors to deliver services
- Re-assessing your needs, including your housing requirements
- Effecting changes to your tenancy (e.g. changing your name on our records)
- Maintaining the health and safety of our staff and contractors
- Preventing fraud and illegal subletting
- Meet your needs in our service delivery, including:
- Making sure our services are accessible
- Making sure we take account of any support needs you may have in our dealings with you and improving our communications with you (for example if you are involved with a carer, social worker, or advocate; taking into account any considerations we need to apply when visiting you at home, or if you need large print or translated text)
- Protect individuals from harm or injury, assist with personal security, our legal requirements including Health and Safety obligations, and the prevention and detection of fraud and other crime
- Provide you with additional guidance, advice, and support services, including:
- Offering assistance with debts and benefits
- Providing support services to enable customers to achieve their goals
- Communicating, promoting, and providing services appropriate to your needs, highlighting any free services or additional help available to you
- Manage the legal process if you apply to buy your home, including providing you with home ownership products and information in preparation for entering into contractual relations
- Understand how we’re performing, including:
- Reviewing call recordings for training and quality monitoring purposes.
- Carrying out market research and customer satisfaction surveys to help us monitor and improve our services to customers
- Segmenting our customers to help us target our resources and prioritise services
- Managing and analysing complaints
- Analysing patterns and trends of service usage
- Ensure that services are delivered appropriately, and to monitor equality, diversity, and inclusion
- Keep in touch with you, understand your needs, keep you up to date with news, and invite you to events, if it is in our legitimate interests to meet our objectives around social inclusion and helping to build communities
- Meet our legal obligations, including the requirements of our funders or regulators
- Tell you about relevant changes to Barnet Homes, for example our organisational structure and governance arrangements, or proposed or planned changes to services which may affect you.
- Where you have specifically consented to the use of your personal information
- For profiling purposes – we may use some of your personal data to create a profile of you so that we can identify relevant Barnet Homes services that might be of interest or helpful to you. For example, if information suggests that you might be having some difficulties with managing your finances which puts your tenancy at risk, or we think you might encounter difficulties in the future, we may direct you to our support and advisory teams for assistance with welfare benefits. Alternatively, if our information suggests that you might be a vulnerable tenant because of age, ill health, or other circumstances, we may offer you an enhanced service in line with our service policies. We may also use profiling information to contact you about our community development programmes that we think you may be interested in. We rely on our legitimate interests to process information for these purposes. We do not use automated profiling or automated decision-making to make any decisions on your application, tenancy, or leasehold.
- Where otherwise permitted under data protection legislation
We do not use computers to make automated decisions about you; however, should this position change we will notify you in writing.
To the extent authorised by local laws, Barnet Homes may collect and process a limited amount of personal information falling into special categories, sometimes called ‘sensitive personal information’. This term means information relating to:
- health-related details, including any reasonable adjustments;
- information revealing racial or ethnic origin;
- judicial information, including the results of criminal or police records checks which can include details of offences, alleged offences and sentences, and information from other intelligence sources (subject to relevant local laws and record retention periods);
- marital status and next of kin; and
- religious beliefs or other similar beliefs, and sexual orientation, should you choose to provide any such information.
Please see our Appropriate Policy Document for more information about how and why we process this special category data.
Provision of some of the information requested by us is part of a legal or contractual requirement, including where you have asked us to do something before you enter into a contract with us (for example, entering into your tenancy). Without this information, we will be unable to accept an application for services or may be unable to manage your services. For example, we cannot see if you are eligible for a tenancy or check that an application is not fraudulent without being able to verify your identity, and if we cannot consult with you about changes to your service if we do not hold your contact details.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
What are legitimate interests?
The law allows your information to be collected and used if it is necessary for a legitimate business interest of ours – as long as its use is fair and balanced and does not unduly impact on your rights.
A wide range of interests may be legitimate interests. They can be Barnet Homes’ interests, or the interests of customers, 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.
Our legitimate interests include:
- Having appropriate security for our offices and on our sites. This includes CCTV and identification photographs;
- Collecting unpaid debt;
- Official communications;
- Making sure that Barnet Homes remains commercially viable and protects its commercial and social assets;
- Working out which of our services may interest you and telling you about them to help meet our business objectives, encourage social inclusion, and help build communities;
- Understanding our customers’ experiences and views so that we can effectively influence and contribute to debates on future housing strategies;
- Working with the authorities and the police to support safer communities;
- Making sure that our services / properties meet the needs of our customers;
- Sharing your information with local utilities providers in the event of unpaid debts;
- Understanding how we are performing so we can meet our priorities and objectives;
- Demonstrating to our regulator that we are fulfilling our obligations, for example with respect to anti-discrimination laws; and
- Understanding who lives within your household, so we know who will be living on our premises to check that the accommodation offered is adequate for current and near-future needs of the household, to check that household members’ needs are being met, to ensure that the services we offer are inclusive, and to ensure that members of the local community will have quiet enjoyment of their homes.
Who has access to your information?
Sometimes we need to share personal information we hold about you with other organisations that we work with or which provide services on our behalf. When sharing information, we will comply with all aspects of data protection law.
Information is shared between departments across The Barnet Group to ensure that you are receiving all the services that are available to you, and may also be shared with certain third parties, including suppliers and service providers, or as requested by any government or regulator or law enforcement authority or agency.
Where sharing is in our legitimate business interests (ensuring this is proportionate and limited to that information which is strictly necessary in the circumstances) or where we are required to share information by law, we may do so without seeking your consent first. Barnet Homes will take appropriate steps to ensure that the recipient of personal information in such circumstances puts in place an adequate level of protection for such personal information in accordance with applicable legal requirements.
Information may be shared with:
- Our contractors to facilitate repairs, maintenance, or improvement works. These providers are under contract and have to keep your details safe and secure, and use them only to provide the service.
- Local authority teams such as social services, environmental health, and benefit agencies, and other organisations which provide services on behalf of the London Borough of Barnet such as Capita.
- Debt and money management advisors.
- Utility companies (and their representatives) and Council Tax Departments to ensure billing details are correct.
- Medical professionals.
- Landlords and their agents.
- Elected Members and MPs (as your representative).
- Third parties providing services on our behalf. For example, a mailing company distributing our newsletter; a research company carrying out a customer satisfaction survey, or a debt collection agency pursuing former tenant arrears.
- Credit reference agencies.
- Solicitors and legal advisers.
- Insurance companies.
- Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative.
- Police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs, Probation) in relation to the prevention and detection of crime, the apprehension of offenders, or the collection of tax or duty.
- Fire and Rescue Services.
- Judicial agencies (e.g. courts).
- Immigration Service.
- Safeguarding Boards.
- Regulators / investigatory bodies.
- Other statutory organisations (e.g. social services and health authorities as necessary for exercising statutory functions).
- Contractors providing IT services
When we share information with third parties, we disclose only the personal information that is necessary to deliver the service, and we have a contract and/or information sharing agreement in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.
We will never sell or rent your information to third parties.
When your data is sent to other countries
We may sometimes make use of cloud-based systems to support the management of our business. Where this happens, we will ensure that there are appropriate safeguards in place to protect your rights. Our services use platforms such as Microsoft Office 365, Google, and Amazon Web Services, which host data in the USA and EU under contract.
There may be occasions where we need to process your information outside of the UK; for example, where we use a third-party computer system supported by employees in the USA. Where we do this, we will take all necessary steps to ensure that your information remains secure.
We will routinely use your contact details to send you information and communicate with you about your tenancy, lease, or service. As a customer, we will also tell you about events in your area. If you have a preferred method of contact, you can make this known to us; however, we will use all means of contact available should we need to contact you in the event of an emergency or to enforce the terms of your tenancy, lease, or contract.
We would also like to keep you updated with information about other products and services (of ours and other reputable companies we work with to deliver services within our communities) which do not form part of our core landlord or housing management services but which we think may be of interest to you and where this will assist us in meeting our objectives to transform lives and communities. This would include information such as accessing training and employment, financial guidance, digital support, and energy efficiency.
It is a legitimate business interest for us to send you postal communications from time to time which may comprise information about all these areas of our work. You can object to receiving this type of content from us in the post. Before sending electronic communications of this nature (such as email and text message), we will follow the law and guidance which requires us to seek your consent. You can change your mind at any time. Please follow the ‘unsubscribe’ instructions on email communications, or contact us by email at Talk2Us@barnethomes.org, or by telephone on 020 8080 6587.
Your rights, and how you can access and update your information
We are committed to upholding your rights in respect of your personal data.
If you’d like to talk to us about your rights, you can contact us at Talk2Us@barnethomes.org.
Information on how to make a complaint to Barnet Homes can be found here.
Further information on raising data protection concerns can be found on the Information Commissioner’s Website or you can contact the ICO to seek an independent view.
The right to be informed
Through the provision of our suite of privacy notices, we will be open and transparent about how and why we use your personal information.
The right of access
You have the right to request a copy of the personal information we hold about you. This is known as a Subject Access request. In order for us to process a Subject Access Request we need this to be made in writing (we have a Subject Access Request form you can use for this purpose, to make it easier to include all the details we might need to locate the information you want), and we ask that your written request is accompanied by proof of your identity and address.
If someone is requesting information on your behalf, they will need written confirmation from you to evidence your consent for us to release this and proof of ID (both yours and theirs).
If you are seeking to obtain specific information (for example, about a particular matter or from a particular time period), it helps if you clarify the details of what you would like to receive in your written request.
Once your request has been received, along with your proof of identity and address, we will provide your information within one month.
We do not usually charge a fee for dealing with a Subject Access Request; please refer to our Subject Access Request Policy for further information. You can find information about our approach to handling Subject Access Requests, including our policy and optional forms to help you make your request, on our website: request for personal data.
In response to Subject Access Requests we will provide you with a copy of the information we hold that relates to you. This will not generally include information about your property such as repair logs, details of contractor visits, or general property maintenance information, as this is unlikely to constitute your ‘personal information’.
The right to rectification
You can ask us to rectify your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by keeping us informed if your details change.
The right to erasure
The right to erasure is also known as ‘the right to be forgotten’. In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for its continued processing. This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data. Our response will also be guided by the provisions of our Records Retention Schedule.
The right to restrict processing
In some circumstances you can ask us to restrict processing, for example:
- If you disagree with the accuracy of personal data and would like us to restrict processing until it is amended;
- If we’re processing your data on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate grounds override those of yours.
We will assess your request and seek to comply with it; however, there will be some situations where we will be unable to comply – for example due to a legal requirement or where processing of personal information is necessary in relation to providing a service. Where this is the case we will inform you of the reason for this.
The right to data portability
If the situation arises where it would be helpful for you to move, copy, or transfer personal data we hold about you, across different services, you may be able to ask us to do this. This right only applies to personal data you have provided to us (e.g. on a web form), where the reason we are relying on to use the information is either your consent or for the performance of a contract, and where processing is carried out by us using automated means. Please contact us to discuss.
The right to object
You can tell us if you object to our processing of your personal data:
- Based on legitimate interests.
- Based on the performance of a task carried out in the public interest or in the exercise of official authority (e.g. where we use your data due to a law).
Security precautions in place to protect the loss, misuse, or alteration of your information
We take our responsibilities to under data protection legislation very seriously, and we will apply appropriate technical and organisational measures to ensure your personal information is secure. For example, we have a number of policies, procedures, and templates in place in relation to protecting personal data, in addition to systems to ensure that access to personal information is restricted to authorised individuals on a strictly need-to-know basis. We also ensure all employees complete new starter training and annual refresher training on data protection.
When we need to share personal data with our contractors and third-party suppliers, our relationships are governed by our contracts with them which include strict data sharing and confidentiality protocols.
To help us ensure confidentiality of your personal information we will ask you (and any of your representatives) security questions to confirm your identity when you call us and as may be necessary when we call you. We will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so or where we have received a clear verbal instruction from you (as a one-off circumstance).
We only hold records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us. We hold a variety of data types which have different requirements for how long we need to keep them.
We have a Records Retention Schedule which sets out for how long we keep different types of information. This is based on National Housing Federation guidance, legal requirements, and best practice. We review our retention periods for personal information on a regular basis. We will securely destroy / delete personal data when we no longer need it or no longer have a legitimate interest in keeping it.
Links to other websites
Our website may contain links to other websites run by other organisations. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website. When you are transferred to another site by following an external link we recommend that you read their privacy statement on their use of your personal data.