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 legislation and ways of working. We recommend checking this page occasionally to ensure that you’re happy with any changes.
Any questions regarding this policy and our privacy practices should be sent by email to Talk2Us@barnethomes.org, or by writing to Barnet Homes, 3rd Floor, 2 Bristol Avenue, London, NW9 4EW. Alternatively, you can telephone 020 8080 6587.
Our Data Protection Officer is Denise Ailara, Data Protection and Compliance Officer.
Who are we?
Barnet Homes is an Arms-Length Management Organisation (ALMO) which 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.
How do we collect information from you?
We will only collect personal information when we need this. 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; general customer contacts (including phone calls, letters, emails, and face-to-face conversations); and recording of calls made to our contact centre. At some schemes and offices we have CCTV cameras to record events in public areas. We also collect information when you voluntarily complete customer surveys, or provide feedback. Website usage information is collected using cookies.
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. We will only take photographs for this purpose with your consent in writing.
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:
Customers – including 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, including:
- 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; income; National Insurance number; income and benefits details; savings information; employment or education status; job history, skills, and experience; gender identity; relationship status; any disabilities; any communication and accessibility requirements; religion or belief; sexuality; nationality; 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), including call recordings; 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 the Police, support workers, mental health workers, social workers, and credit reference agencies.
* 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.
How is your information used?
How we use your information depends upon our relationship with you.
Your information may be used to:
- 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
- Where otherwise permitted under data protection legislation
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.
It is also in our legitimate interests to understand how we are performing so we can meet our priorities and objectives.
There may also be a legal obligation for us to process information or to demonstrate to our regulator that we are fulfilling our obligations, for example with respect to anti-discrimination laws.
The law also 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.
Where enquiries relate to household members, it is in our legitimate interests to know who will be living in 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.
Please speak to us if you have any concerns.
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.
Where the information is of a sensitive nature, for example about your health, we will generally obtain consent from you prior to sharing this information, unless we are required or permitted to share this by law.
Where ‘sharing’ is in our ‘legitimate business interests’, we may share your information without seeking your consent first. This may be with:
- Our contractors to facilitate repairs, maintenance or improvement works.
- 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.
- Other organisations in The Barnet Group.
- Debt and money management advisors.
- Utility companies (and their representatives) and Council Tax Departments to ensure billing details are correct.
- Landlords and their agents
- 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.
- 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) in relation to the prevention and detection of crime, the apprehension of offenders, or the collection of tax or duty.
- Other statutory organisations (e.g. social services and health authorities as necessary for exercising statutory functions).
We may also share information when required by law for example where ordered by the Court or to protect an individual from immediate harm.
We may be unable to advise you immediately of such disclosure, subject to compliance with such regulations, at all times; however, we will take steps with the aim of ensuring that your privacy rights continue to be protected.
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.
There may be occasions where we need to process your information outside of the European Economic Area (EEA); 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 not sell or rent your information to third parties.
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.
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.
- 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. 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.
- For the purpose of direct marketing (including profiling);
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.
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 have a Records Retention Schedule which sets out how long we keep different types of information for. 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.
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.