Privacy Policy

Privacy Statement

Southway respects an individual’s right to data privacy and data protection in line with data protection legislation. By this we mean the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

This Privacy Statement explains how Southway will collect, store, use, share, and protect (collectively known as ‘process’) your personal information. If you have a tenancy or other written agreement with us it may contain additional detail about our processing of your information.

By giving Southway your information, or by using our website or platforms you are confirming that you are accepting the practices outlined in this Privacy Statement. If you do not accept the outlined practices, please do not give us any information or use our website or other digital platforms or portals.

For the purposes of the data protection legislation, Southway is the Data Controller and is the company responsible for controlling the processing the information that you supply. On occasion this information may be shared with a third party who will act as a Data Processor to carry out a specified function on behalf of Southway. In all instances where we use a Data Processor we will have a Data Sharing Agreement to make sure that they apply the same standards of Data Protection as we do.

Who are we?

Southway is a registered provider of social housing and property developer whose registered office is: Southern Gate, 729 Princess Road, Manchester, M20 2LT

Southway is listed with the Office of the Information Commissioner as a Data Controller with the reference number: Z1389491

Southway owns a commercial subsidiary, Southway Plus that sells and leases market properties. Southway Plus is listed with the Office of the Information Commissioner with the reference number: ZA244003.

Both Southway and Southway Plus occasionally sell products and services under the Gecko trademark. Gecko has its own website with a separate privacy statement.

For the purposes of this Privacy Statement, Southway refers to both Southway and Southway Plus.

Why do we process personal information?

Data Protection legislation determines the lawful basis by which organisations can process data. In the majority of cases, Southway uses your date for legitimate interests (to run our business), however we may also process your data for the performance of a contract, to comply with certain law or regulation, or in exceptional circumstances to protect the vital interests of data subjects.

What information is being collected?

How you interact with us determines what information we collect from you.

We aim to limit the amount of information we process to that which is reasonably necessary to provide you with our services. In order to limit information requests, we will combine information that we receive from different sources and process it together.

The types of information that we collect are as follows:

Personal Data

This is information that could be used to identify you as an individual:

• Name (including previous names)
• Date of birth;
• Marital status;
• Nationality;
• Residential status;
• Income;
• Employment;
• National insurance number.
• Photograph.

We would typically collect this type of information in order for you to access a service or enter into a contract with us.

Special Category Data

In order to access some Southway services and for legislative requirements, it may be necessary to collect what is known as special category information (previously referred to as sensitive personal information. This includes your:

• Gender;
• Race;
• Ethnicity;
• Religion;
• Health;
• Physical or mental health medical needs;
• Incomes and outgoings; and
• Bank details;

Personal Contact information

• This is the information that you have given us in order for us to be able to contact you and includes:
• Telephone numbers;
• email addresses;
• Alternate postal addresses and in case of emergency; and
• Next of Kin details.

Online Account login information

If you have set up an online account with Southway or Gecko this refers to your; first name, surname, e-mail address, password, date of birth, tenancy id and postcode.

How do we collect your information and what is it used for?

We collect information about tenants, prospective tenants and customers using the following media:

• Southway and Gecko websites and mobile sites
• Southway and Gecko online portals
• Southway and Gecko social media
• Our Customer Hub contact centres
• Letters and Application forms
• Personal interviews

There are a number of reasons why Southway processes your information. Please note that not all of the uses will be relevant to every tenant or customer, in some instances we will issue a separate specific Privacy Statement to explain the data we are collecting and why we are collecting it.

Lettings

The majority of the information that we hold about our tenants derives from when they sign for a tenancy. We routinely collect the following:

• Name, address and date of birth, National Insurance Number and other formal identification, so we can identify you.
• Contact details so we can get in touch with you when we need to.

• Your financial circumstances including information about benefits you receive, how much you earn, any debts and any other income you receive. If you’re going to be a tenant, we need to confirm you are eligible to rent the home and can afford to pay the rent.
• Communication preferences – we have a diverse range of customers and it is helpful for us to know information about you which helps us to communicate with you in the way you find easiest. We might therefore ask you to share information about:
• Disabilities – if this impacts on how we communicate with you. For example, if you are deaf we can use assistive technologies to talk to you; if you have mobility issues we will make sure we wait patiently when we knock at your door or call you; if you have learning difficulties we can contact your support worker.
• Your preferred language, for example if English is not your first language we can access translation services.
• We collect the name, age and if appropriate contact details of the people who live with our tenants. We use this information to:
• Confirm that you aren’t sub-letting your home
• Identify any overcrowding issues
• Contact someone in the house if we can’t get hold of the tenant or have concerns for their safety
• Identify potential tenancy fraud

We will take a photograph of anyone who will be moving into the property who is over the age of 18 to help prevent tenancy related fraud.

When you sign up for a tenancy, we will ask you to complete a form so that we can supply information to the Ministry for Housing Communities and Local Government (MHCLG) about social housing lettings.

British Gas provide Gas and Electricity at our empty properties. In order to ensure that you have services ready for when you move in, we will pass your details to them. Once you moved in to the property you are free to change Energy Supplier.

We will provide all new tenants with a copy of this privacy statement.

Tenancy Management

In order to maintain your tenancy with us, we may use the information that was given to us when the tenancy was set up. This would include your personal information and contact information along with information about the other people in your household. This will allow us to ensure that you are paying your rent, deal with any

repair issues, investigate tenancy breaches and offer other general tenancy management services.

We will automatically set you up with an online account. This is your personal account and only you have access to this account and the information in it. You are under no obligation to register but by doing so, you can access our online repairs booking system 24/7 and raise repairs quickly and easily. You can also view your rent account, make rent payments and much more.

Age Friendly Schemes

If you live in one of our Sheltered Schemes we may need additional sensitive information to provide you with the services you require, for example to assist you with a housing enquiry, community alarm monitoring or seeking access to care or wellbeing services. This may come directly from you, or from a third party on your behalf, for example from a family member or GP. Examples of this sensitive information includes any medical conditions you may have or your racial or ethnic origin.

We will normally only hold, use and share this ‘sensitive’ information with your explicit permission, although there may be reasons when we are required to do so by law, or to protect your vital interests. In such circumstances we may process your information without your knowledge or consent.

Anyone living in one of our With Care schemes will be provided a copy of a specific With Care privacy statement when they sign for a tenancy.

Support Services

We also provide services that help to sustain tenancies. When doing this it may be necessary to process a tenant’s special category data. Examples of this include

• Our Advice Services team, with consent, using a customer’s income and outgoings to establish benefit entitlement.
• Our Early Help Team making referrals for additional support.

We will only process Special Category Data in these instances with your explicit consent.

Anti-Social Behaviour

In order to manage anti-social behaviour cases, we may share information on existing tenants regarding unspent criminal conviction/s and offences with our solicitors or other legal advisers.

If there is a record of anti-social behaviour, criminality or violence at your property we may place a maker on our Housing Management system to indicate this.

We will collect information relating to criminal convictions from rehousing applicants to ascertain whether they are unsuitable to be a tenant of Southway by reason of their behaviour or the behaviour of a member of their household. This information may be shared with senior representatives from the National Probation Service, Community Rehabilitation Company, Greater Manchester Police, Directorate for Adults, Other Registered Providers and Southway staff (on a need-to-know basis only)

Use of CCTV and Sound Monitoring

We use CCTV for the prevention, detection and investigation of anti-social behaviour and crime. We comply with the GDPR under the use of CCTV and the Information Commissioner’s current CCTV Code of Practice.

We may disclose CCTV footage (by way of a DVD or other suitable method) to:

• Law enforcement agencies, where it is believed that the images will assist in a legal enquiry.
• Prosecuting agencies.

Residents and other third parties may not view CCTV footage, with the exception of residents who have been recorded on the CCTV and make a valid Subject Access Request.

We hold CCTV recordings, not subject to an investigation, for a maximum of 3 months.

On occasion, when investigating an Anti-Social Behaviour complaint, we may use sound monitoring equipment to detect excessive noise coming from one of our properties.

We will destroy all sound recordings once the Anti-Social Behaviour case is closed.

Customer Engagement

For service improvement and to encourage customer and tenant engagement, we may collect feedback. This can be online, via e-mail, or through the use of paper surveys.

Community Events and Photographs

We hold regular events at our buildings, or within the community to which we invite Southway tenants and other local residents. We may take photographs at the event and use this as promotional material on our Website, Social Media sites and Tenant Newsletter ‘Southway Stories’. We will make clear to anyone attending the event that their image may be used in this way and give them the opportunity to opt out if they wish to do so.

Competitions

On occasion we may run competitions for which entry may require customer’s or tenant’s personal information. For compliance purposes, the information and general location of the winner may be published or shared.

Marketing and Communications

We may collect and use your personal and contact information to send you marketing communication, through emails, text messages, and postal mailings. These communications are sent for a range of reasons, including;

• The latest Southway news and service updates
• Training or Employment Courses that may be of interest.
• Southway Products or Services (e.g. Shared Ownership Properties)

You can ask us to stop sending you information on these products and services at any time. All maketing emails contain an option to unsubscribe. There are some items that we are legally obliged to send you and from which you cannot withdraw consent, an example of this is the annual rent statement.

If you participate in a promotion that involved a third party and you agree to receive marketing information from them, you’ll need to contact them directly to withdraw consent from receiving further marketing materials from them.

Southway produces a quarterly newsletter, Southway Stories, which it sends to all of its tenants. If you do not wish to receive this please contact the Southway Hub [email protected]

Visitor feedback

This is information you voluntarily share with us about your experience with Southway and includes unsolicited comments, suggestions and feedback which is typically collected in surveys, user groups, contact forms and emails

Equality and Diversity

For legal compliance and reporting purposes and to meet, we may use special category data relating to gender, ethnicity, sexuality, race and disability. We will anonymise data of this nature when including it in reports.

Third Party information

We may also obtain information about you from other sources. As an example we may hire a third-party organisation to collect information on our behalf to conduct surveys that provides us with additional information on our tenants to shape and improve our service delivery. An example of this is the bi-annual star survey which is sent to all residents and satisfaction surveys once you have received a service from us.

Monitoring

We may monitor and record communication with you (such as telephone conversations and emails) for the purpose of quality assurance, staff training, fraud prevention and dispute resolution.

Information about other individuals

If you give us information on behalf of someone else, you must confirm that the other person has appointed you to act on their behalf and has agreed that you can give consent on their behalf to the processing of their personal data. If you request data about other individuals, you will need to provide proof that they have consented for you to have the information this

Children

In accordance with the General Data Protection Regulation, Southway will also seek consent from parent/guardian of children in order to process their information and if they’re over 16 years old, we will seek their consent.

Protecting your personal information

We are committed to ensuring that your information is secure. At all times Southway will take both technical and organisational measures to protect the confidentiality and security of personal information, irrespective of the method of collection. This includes:

• Training all of our staff on data protection matters, so that they know how to keep your information safe and what they can use it for.
• Using a user name and password to access our computer systems, so there is less risk that someone will be able to log on who isn’t authorised.
• Keeping information held on paper in our office in locked cupboards with only staff that need it having access to it.
• Asking you some questions to confirm your identity when you get in touch with us.

We hold some paper records. These are stored securely at our offices and are confidentially shredded by a reputable firm when we no longer need them.

Refusing to give us personal information

There is certain information that we must hold in order to fulfil our obligations under your Tenancy Agreement and deliver core services. You have the right not to share further information with us. However, this may mean that we are unable to offer you additional services or tailor our services effectively to your needs.

Where you have given consent for us to use your information, for example to send you marketing emails, you have the right to withdraw this consent at any time.

Disclosing your personal information

We will never share information with any third party that intends to use it for direct marketing unless we have received specific consent from the individuals involved. There are occasions where we will need to share your information with selected third parties. In these cases, Southway will have a Data Sharing Agreement which ensures that your information is private, secure and only processed for the reasons specified by Southway.

In some instances, Southway will require your specific informed consent to process your information. On these occasions, the consent will be recorded, and you have the right to withdraw it at any time.

Information will only usually be shared with the following types of third parties.

Contractors

In order to provide a service to you, it may be necessary for Southway to appoint a contractor; an example of this would be carrying out a roof repair. The contractor would need to know your name and address in some cases your contact details to carry out the appointment.

If there is a history of violent behaviour at the property, we may disclose this information to help keep the contractor safe.

Other Service Providers

Southway relies on a number of third parties to provide services who may not necessarily need to contact customers. This includes the following

• We sometimes share your information with Government agencies to help you with benefit claims and any tenancy issues, and to help them to fulfil their public tasks. This includes Social Services, local authority council tax and benefits departments, the Department for Work & Pensions (DWP) and HMRC. We may share information with the DWP if you are in receipt of Universal Credit and have significant arrears, in order to make a request for your housing benefit to be paid direct to us.,

• If you owe us money, we will make a referral to our internal debt and welfare advisors who can help you with any financial management issues you have. We may also share your data with tracing agencies for the purpose of seeking payment or repaying you if you are in credit.
• We will share your information with third parties including the Police and other law enforcement agencies, emergency services and lone working service providers in order to prevent or detect a crime, or where we believe the health & safety of an individual is at risk. We will share personal data with a Local Authority in relation to any fraud prevention/detection work they carry out.
• Where we are providing you with debt advice, we may share your details with other debt advice agencies in order to provide that service. With your permission, we will also contact your creditors, DWP, HMRC, HMCTS, the local authority, other advice services, charities and schools.
• We will work in collaboration with other agencies, for example healthcare providers, law enforcement agencies, charities and third sector, in order to provide our customers with a more complete and co-ordinated service.

To enable us to provide a service to Tenants 24 hours a day, 365 days a year, we have a data sharing arrangement with Wythenshawe Community Housing and One Manchester who provide an Out of Hours Telephone Service. They have limited access to some of the information held on our housing management system in order to arrange repairs and deal with emergencies

Legal and Business transfer

There are occasions when we are required by law to disclose your information, for example, to comply with legal proceedings or to protect the safety or rights of Southway, its customers or the general public.

In the event of a merger or acquisition of part or the whole organisation, the partner or new owner will have access to the information obtained by Southway and its information could be transferred as part of reorganisation or similar event if permitted by and carried out in accordance with the applicable law.

Your individual rights

Under the terms of GDPR you have a number of rights in relation to how Southway processes your information. These include:

Right to be informed

You have the right to ask us why we’re collecting your information, how will it be processed, for how long, who we will be sharing it with.

Right to access

You have the right to access the personal information that we hold about you and to obtain a copy of it if you wish. This is called a Subject Access Request (SAR) and it’s free of charge. This is more formal than for example, asking for a second copy of your rent statement. Please be aware that we have one calendar month to respond to these requests. If the request is complex and additional time is needed, then we may take up to an additional two months to respond. If additional time is needed, then we will let you know within one month and why. For more information on SARs, please email us at [email protected]

Right to rectification

If the information we hold on you is incorrect, you have the right to ask us to correct it without undue delay and free of charge. You can exercise this right by contacting us at [email protected] . Please note that there may be occasions where we require additional information in order to process your request, for example a change of surname.

Right to Erasure/be forgotten

You have the right to request that all data held about you by Southway which identifies you is deleted. You can also make this request at any time but please note that we may be compelled to retain your information due to specific legislative or regulatory requirements, or legitimate business reasons. For example, we need a certain amount of information to manage a tenancy and we wouldn’t wholly delete the records of a former tenant who owed us rent at the conclusion of their tenancy.

Southway employees

As well as holding data on its tenants Southway has 200 staff on whom it holds personal and special category data to enable delivery of its services. Southway will maintain a separate privacy statement relating to how data is processed by the Human Resources Team, which will be made available to all staff.

Technical computer information

Servers

The servers which host our computer systems are based in the UK. We have agreements in place with service providers to ensure that your information is kept safe and in line with data protection law.

Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. The information contained within the cookie can include the IP address, operating system and browser information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For further information, visit: www.aboutcookies.org or www.allaboutcookies.org.

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

Spamming

Spamming is where unsolicited e-mails are sent to you containing advertisements or marketing related materials without your consent.

In accordance with the General Data Protection Regulation, Southway will not send you spam emails and we will not share your email address with third parties for them to use in this way.

If for some reason you believe you have received spam e-mail from Southway please contact us at [email protected]

E-mail

We use Transport Layer Security (TLS) to encrypt and protect email traffic in line with email information security policy. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.

Links to third-party sites

On occasion our websites or platforms may have links to third party sites, visiting these sites is done so at your own risk and we do not control or have any responsibility for the content or practices of any third-party site, application or feature. Please check the relevant third party’s privacy policies before you submit any personal data to these websites.

We use MailChimp for distributing promotional material and Survey Monkey for conducting online surveys. Both of these systems are hosted in the United States. While they are outside the jurisdiction of GDPR they subscribe to Privacy Shield, a system that is certified as providing a level of protection to meet compliance with GDPR.

Retaining your personal information.

We will only keep your information as long as is reasonably necessary and in line with our Data Retention Policy. This does mean that your information may be retained for a period of time after you have stopped using Southway services.

If you want to know how long we keep a particular type of information, you can ask our Data Protection Officer (see below).

Contacting us

Southway has a designated Data Protection Officer who you should contact with enquiries regarding the use of your information: