Privacy Policy

We are required to collect personal information so that we can provide some of our services to you as set out in the tenancy agreement. This may include:

Personal Data:

• name;
• address;
• telephone number; and
• any other information from which you could be identified.

Special Category Data:

• race;
• financial circumstances;
• sexual life;
• gender;
• political opinion;
• religion;
• health;
• trade union;
• criminal record; and
• genetic and biometric data. 

Please note that the list above does not include every type of information that can be collected. To process Special Category Data, NPH is required to have further justification for processing and higher levels of protection.

Where relevant we will process information about:

• personal details;
• goods and services;
• supplier details;
• financial details;
• lifestyle and social circumstances;
• customer feedback including satisfaction surveys and complaints;
• education and employment and pre-employment details;
• medical, health, safety and security details;
• visual images, personal appearance and behaviour; and
• criminal activity and proceedings. 

Where relevant we will also process personal information about:

• tenants and household members;
• applicants for accommodation and members of their household;
• asylum seekers;
• business associates;
• landlords;
• Board members & directors;
• probation officers;
• social workers;
• spiritual and welfare advisers;
• consultants and professional advisers;
• survey respondents;
• employees, including self-employed contractors and consultants;
• offenders and suspected offenders;
• complainants and enquirers;
• suppliers and service providers; and
• images captured by CCTV. 

Information received from third parties

• We sometimes receive personal data about individuals from third parties - for example, we may be working with another organisation such as the police or social services.
• We may use third parties to help us conduct research and analysis on personal data and this can result in new personal data being created. We will let you know if this happens.
• We collect information from social media when you have given us permission to do so, this includes posting on one of our social media sites.

We use personal data for administrative purposes and this includes:

• receiving rent payments;
• maintaining databases of our staff, Board, panel members and contractors;
• performing our obligations under contracts; and
• to help us respect your choices and preferences.

We process personal information to enable us to provide social housing accommodation and services which include:

• letting, renting and leasing properties;
• administering waiting lists;
• carrying out research;
• contacting you to take part in surveys;
• administering housing and property grants;
• providing associated welfare services, advice and support;
• maintaining our accounts and records;
• supporting and managing our employees, agents, and contractors;
• the sale or disposal of property owned by WNC; and
• customer engagement, feedback and satisfaction surveys.

We evaluate, categorise and profile personal data so that we can tailor needs, services and communications. This also helps us improve our organisation and the service we provide. When we use information in this way, we will make sure that the data is deleted immediately after use or if stored that it cannot be linked to a specific individual.

NPH uses RentSense which is an intelligent automated decision-making tool that assists with identifying those rent accounts which are most likely to fall into arrears which could be prevented via early intervention. The tool applies algorithms and predictive analytics to existing transactional data, which in turn automatically identifies cases that most need attention.

You have the right to opt out of any automated decision-making software. Should you wish to discuss, please contact either your rent income officer or email Preferences.NPH@nph.org.uk.

NPH will not keep information for longer than is necessary.

There are specific legal requirements which NPH must comply with and which vary according to each document type.

NPH has a Data Retention Policy and Schedule to make sure that your information is destroyed within the appropriate timescale - a copy of the policy is available on request.

In some circumstances you can ask us to delete or remove your personal data where there is no good reason for us to continue to process it.  We may not always be able to comply with your request of erasure for specific legal reasons. If this happens we will notify you.

We may anonymise your personal data (so it can no longer be associated with you) for research or statistical purpose. In this case we may use the information indefinitely without further notice to you.

Under GDPR you have rights regarding the personal data that NPH holds and processes about you.

Specifically you have the right:

• to be informed.
• of access.
• to rectification.  
• to erasure.
• to restrict processing.
• to data portability.
• to object.
• in relation to automated decision making and profiling. 

We aim to respond to all requests within one month.

If you believe our records are inaccurate, you can write to us asking for them to  be amended. If you believe we have unfairly withheld information or unfairly refused to amend our records you can make a complaint using our standard complaints procedure

• We process personal information using CCTV systems to monitor and collect visual images for the purpose of security and the prevention and detection of crime. 
• CCTV is used for maintaining the security of property and premises and for preventing and investigating crime.
• CCTV may be used to monitor staff when carrying out work duties.
• For these reasons the information processed may include visual images, personal appearance and behaviours. This information may be about staff, customers and clients, offenders and suspected offenders, members of the public and those inside, entering or in the immediate vicinity of the area under surveillance.

Where necessary or required this information is shared, in line with Data Protection Regulations, with the data subjects themselves, employees and agents, services providers, police forces, security organisations and persons making an enquiry.

Should you have reason to complain about how your data has been processed, you can contact our Data Protection Officer (DPO). In the DPO’s absence, their post and email will be monitored.

NPH Data Protection Officer

Northampton Partnership Homes

The Guildhall

St Giles Square

Northampton

NN1 1DE

Local rate number: 0300 330 7003.

Email: Preferences.NPH@nph.org.uk

If you are not satisfied with the response from NPH you can contact:

The Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow, SK9 5AF

Tel: 01625 545745

Website: https://ico.org.uk/

NPH participates in the Cabinet Office’s National Fraud Initiative (NFI), a data matching exercise to assist in the prevention and detection of fraud, as we are required by law to protect the public funds it administers. We are required to provide sets of data to the Minister for the Cabinet Office for data matching.

Data matching involves comparing computer records held by one body against other computer records held by the same or another body to see how far they match. This is usually personal information. We may therefore share information with other bodies responsible for auditing and administering public funds. Computerised data matching allows potentially fraudulent claims and payments to be identified. Where a match is found it may indicate that there is an inconsistency which requires further investigation. No assumption can be made as to whether there is fraud, error or other explanation until an investigation is carried out.

The Cabinet Offices requires us to participate in a data matching exercise to assist in the prevention and detection of fraud. We are required to provide particular sets of data to the Cabinet Office for matching for each exercise, and these are set out in the Cabinet Office Guidance.

For further information on the Cabinet Office’s legal powers and the reasons why it matches particular information, see the National Fraud Initiative privacy notice.

The data controller for your matched personal data is the Cabinet Office. The contact details for the data controller are:
Head of the NFI
1 Horse Guards Road
London
SW1A 2HQ
Email: nfiqueries@cabinetoffice.gov.uk

Most of the personal information NPH processes is provided to us directly by you or your representative including:

• as part of an application for a service, discount or benefit.
• supplier or contract for a service or product.
• employee payroll.
• social housing applications (current tenants and individuals on a housing waiting list).
• Right to Buy applications (completed and in progress).

The data specifications setting out exactly what data we process in the above areas can be found on the National Fraud Initiative: public sector data specifications page.

The NFI is conducted using the data matching powers bestowed on the Minister for the Cabinet Office by Part 6 of the Local Audit and Accountability Act 2014 (the Act). It does not require the consent of the individuals concerned under current data protection legislation. There are certain public sector bodies that are required to provide data for the NFI on a mandatory basis, including local authorities, such as West Northamptonshire Council. In addition, other bodies or organisations, such as Housing Associations, can provide data to the Cabinet Office for matching on a voluntary basis under schedule 9, 3 of the Act.

Data matching by the Cabinet Office is subject to a Code Of Data Matching.

We use the information that you have given us in order to enable NPH to fulfil its financial responsibility and regulatory requirements in preventing and detecting fraud or error.

The information will only be used for these purposes. Information will not be sold, rented or provided to anyone else, or used for any other purpose than that for which it was originally collected unless required to by law.

Information may be shared in the following circumstances:

• Shared internally with other NPH services in order to identify fraud or error, ensure our records are accurate and up-to-date, and to improve the standard of the services we deliver.
• Shared with other local authorities including West Northamptonshire Council, and/or government departments including law enforcement in order to identify fraud or error, to ensure our records are accurate and up-to-date, and to improve the standard of the services we deliver.

Information sharing is undertaken in accordance with UK GDPR and the Data Protection Act 2018.

We keep your personal information for as long as regulatory bodies require us to and in line with NPH’s Retention and Destruction Policy.

Where a possible fraud has been highlighted but no fraud identified, information will be securely destroyed and not retained for these purposes. All data matched records are retained until the end of the initiative program of two years. If a match leads to a fraud, the investigation records are held for two years from the conclusion date, unless convicted by a criminal court, where the record is held for five years from date of conviction.