At Your Choice (Barnet) (YCB), we’re committed to protecting and respecting your privacy.

This privacy policy explains when and why we collect personal information about people who access our services, how we use it, the conditions under which we may disclose it to others, and how we keep it secure.

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.

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 regarding this policy and our privacy practices should be sent by email to info@yourchoicebarnet.org, or by writing to Your Choice (Barnet), 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.

For information about employees’ personal data, please refer to The Barnet Group’s privacy policy.

Who are we?

When we use your personal data, YCB 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.

Your Choice (Barnet) is a provider of adult social care services which is incorporated in England (07873969). 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 may use your data for the following reasons:

  • Service delivery and communications
  • Statutory requirements – e.g. 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 data protection requests
  • To protect public safety

We collect information about you and your social care needs. This enables us to provide the appropriate care and support that you require, and to ensure your safety and wellbeing. This information may be recorded in writing, or electronically on a computer, or a mixture of both. 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 YCB is subject;
  • 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.
  • 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;
  • In certain circumstances, the processing is necessary for the legitimate interests pursued by YCB 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. YCB 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 Health and Social Care Act 2012
  • The Health and Social Care (Safety and Quality) Act 2015
  • The Care Act 2014
  • The Safeguarding Vulnerable Groups Act 2006
  • The Mental Health Act 1983, 2007
  • The Mental Capacity Act 2005
  • The Equality Act 2010
  • Local Safeguarding Children and Adults Boards Regulations 2006 (SI 2006/90)
  • The Crime and Disorder Act 2003

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, 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.

YCB collects personal information in a number of different ways including when you use our services on our website; and through customer agreements, 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.

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 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 YCB, as detailed in this notice.

We may take photographs at events organised and hosted by YCB 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 access our services, have done in the past, or may do in the future.  When you apply for services with YCB 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, including: age; sex; date of birth; ethnicity; 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; bank details; benefits; 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; property access codes; and details of any unspent criminal convictions.
  • Information from the support workers, including mental health workers, social workers, NHS, Police,other local authorities and carers.
  • 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 application to use our service, service eligibility, and to inform what is needed in your care package including:
    • Verifying your identity
    • Confirming your care needs
    • Confirming your eligibility for services
  • Manage your care whilst using our services including:
    • Ensuring that you are protected from financial and physical abuse
    • Contacting you or your chosen representative in the event of an emergency or to enforce the terms of our services to you
    • Contacting you or your chosen representative to discuss services we offer you
    • Working with other organisations to deliver services to you
    • Re-assessing your needs, including your care requirements
    • Effecting changes to information we hold about you (e.g. changing your name on our records)
    • Maintaining the health and safety of our staff
    • Resolving complaints about our services.
  • 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 where you are involved with a carer, social worker, or advocate; taking into account any considerations we need to apply when using our services)
  • 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:
    • 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
  • 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 or your representative, 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
  • Meet our legal obligations, including the requirements of our funders or regulators
  • Tell you about relevant changes toYCB, 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 an agreement of services with us. 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 our services without being able to verify your identity, and we cannot consult with you or your representative about changes to your service if we do not hold your contact details.

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, YCB 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 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.

A wide range of interests may be legitimate interests. They can be YCB’s 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;
  • Official communications;
  • 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;
  • Understanding how we are performing so we can meet our priorities and objectives; and
  • Demonstrating to our regulator that we are fulfilling our obligations, for example with respect to anti-discrimination laws.

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.

Information is shared across The Barnet Group to ensure that you are receiving all the services that are available to you, and may 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. YCB 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:

  • Other organisations in The Barnet Group.
  • Third parties providing services on our behalf. For example, a mailing company distributing our newsletter, or a research company carrying out a customer satisfaction survey.
  • Police and other relevant authorities in relation to the prevention and detection of crime, the apprehension of offenders.
  • Other statutory organisations (e.g. social services and health authorities as necessary for exercising statutory functions).
  • Fire and Rescue Services.
  • Judicial agencies (e.g. courts).
  • 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
  • Medical professionals.
  • 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.
  • Solicitors and legal advisers.
  • Insurance companies.
  • Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative.
  • 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.

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 or your representative 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.

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 not sell or rent your information to third parties.

Your choices

We will routinely use your contact details to send you information and communicate with you or your representative about our services. 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 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 info@yourchoicebarnet.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.

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 info@yourchoicebarnet.org.

Information on how to make a complaint to Your Choice (Barnet) 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 our relationships are governed by our agreements 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.

Use of cookies

Like many other websites, Your Choice (Barnet)’s website uses cookies. You can read our cookie policy here.

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.