This Privacy Notice is a public document available to anyone and applies to residents of Zebra Housing to explain how we collect and process personal information in order to conduct normal business activities as a UK charitable housing association. We are a Registered Social Landlord (RSL) regulated by the Homes and Communities Agency (HCA). Our main activity is to provide housing and support services to international post graduate students and their families. This involves property and grounds maintenance and repairs, managing your housing, tenancy and rent account as your landlord, and organising our social programme.
WHO WE ARE?
Zebra Housing is the Data Controller whose head office is located at Jerome House, 5-13 Glendower Place, London, SW7 3DU – 020 75902440 – www.zebrahousing.com
Zebra’s Data Protection Officer can be contacted at DPO@zebrahousing.com
We own around 150 flats specifically designated for international post graduate students and their families in and around Central London.
HOW WE COLLECT YOUR INFORMATION
Zebra Housing collects information from you via a variety of sources, including
when you apply for one of our properties, complete one of our forms, when you call, write, email or meet with us or respond to a survey. We may collect information when you use our social media sites, websites or self-service portal (to be introduced in 2019)
We operate a CCTV system at our offices and all our residences for the detection and prevention of crime. It operates continuously, and recordings are held for one month.
We may also take photographs at our events, at our properties and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent.
We may receive information about you from third parties including your university or college, prior landlords and credit agencies when you apply for housing, representatives acting on your behalf, your bank and other financial institutions
WHAT INFORMATION WE COLLECT FROM YOU
Personal data relating to identity – Full name (and proof of your identity / photo ID), date of birth, gender, nationality, passport and visa details
Confirmation and details of your course from your university
Contact details (phone, email, correspondence address and home country address.
Details of anyone authorised to act on your behalf if applicable.
Details of all household residents (name and DOB).
Banking details so we can collect your rent by Direct Debit.
Your income and where it is derived from
Your monthly budget
The information we may collect from you includes:
Disabilities, vulnerabilities and health information
Who we should contact in an emergency
We use this information to tailor our service to better meet your particular circumstances and needs. We may use this information for safeguarding of staff.
If you do not provide the information we need then we may not be able to provide all our services to you, and ultimately you may not be able to hold a tenancy with us.
For the purposes of monitoring that we are allocating our housing fairly we collect the following information below. However, in this case we give you the option here of not disclosing if you so wish.
Ethnicity, race and colour
Whether you are married or in a civil partnership
WHAT PROCESSING WE DO WITH INFORMATION COLLECTED
The information we require from you is used to manage your tenancy agreement. Please read your contract carefully for specific details as ‘performance of a contract’ is usually the legal basis for processing your information and carrying out our activities. The processing activities we conduct can be summarised as:
Managing your account charges and payments, including arrears.
Managing the repairs, maintenance and adaptations of our properties.
Ensuring tenancy conditions are complied with
Complying with relevant legislation and regulation.
Zebra Housing conducts research and statistical analysis to help improve our business processes and the services offered to our customers, as well as to evaluate our performance against other benchmarks. When possible, statistical information is anonymised or pseudonymised. Zebra conducts surveys regularly and periodically relating to our services in order to gauge satisfaction and make improvements based on feedback. We operate a range of information and communications systems and technologies for efficient operation of the business. Personal information is stored and managed within those systems which are maintained to achieve a high level of Confidentiality, Integrity and Availability (CIA) including following best practice cyber security standards. We hold information in IT systems which may be copied for testing, backup, archiving and disaster recovery purposes. All data is held within the UK.
Zebra provides additional voluntary services including organising social events and gathering information to improve our services. For these voluntary services, where your personal information is needed, we will always notify you about the service being offered, explain the service and obtain your consent to proceed, usually by way of a sign up / consent form for that service. For the additional voluntary services, much of the information contained in our Privacy Notice is still relevant, such as details about Zebra such as the Data Controller, contact information for the Data Protection Officer and the rights you have
under the legislation, including the right to withdraw your consent and the right to complain.
7. CHILDREN’S INFORMATION
Zebra does not normally process children’s information as part of a tenancy, as all tenants are adults. However, we record children’s basic information if they are resident in one of our properties, including their name and date of birth. This is required for checking the property is not overcrowded and to assess other tenancy management issues where all householders and ages are required to be known. We may receive children’s information when determining our social programme.
Much of the data we use relates to our properties and their maintenance and repair. We do not consider property information used in conjunction with the property address to be your personal information. For example, the age of the kitchen, results from an asbestos survey, planning to replace windows or a repair to a tap. We are usually happy to provide you with answers to questions you may have about the property you are living in and work done to it. As soon as your name, contact details or other personal information is used in conjunction with property information, such as to complete a property repair visit, then this is treated as personal information.
HOW WE WILL COMMUNICATE WITH YOU
We need to communicate with our residents and this will usually be by email or by telephone.
We will not use your data for any direct marketing. We will only discuss or communicate your tenancy details with those named on the agreement or those authorised (temporarily or permanently) by you. You can authorise someone temporarily verbally over the phone or permanently in writing.
WHOW WE SHARE DATA WITH AND HOW LONG WE KEEP INFORMATION
Zebra shares limited personal data with our contractors who are carrying out services on our behalf. Our contractors are required to comply with the law and our own Data Processing Agreement to ensure data is managed appropriately and for specified purposes, including to run our out of hours service or to complete emergency, responsive or planned property repairs. We may share your information with a language translation service if it is necessary to translate any information into or from a foreign language for you.
Zebra may need to share personal information with government departments and agencies, with our regulator and auditors, with utility companies or with other organisations and agencies where we are legally allowed to do so.
Information relating to a tenancy agreement will be kept for as long as the agreement is active or where money is owed on the account, and for a period not exceeding three years afterwards. The basic history of who held a tenancy at which property and when will be held forever.
We may need to share information with solicitors, surveyors and valuers relating to valuations and property surveys.
WHAT WE WILL NOT DO
We will not send you unsolicited marketing material.
We will not sell your personal data on to third parties.
We will not pass on your personal data to unrelated third parties unless we are allowed or required to do so by law or we have your explicit permission to do that.
We will not transfer or store your personal data outside of Europe (the European Economic Area) outside of the control of the UK / European regulations
YOUR RIGHTS, THE RIGHT TO COMPLAIN AND THE ICO
You have the right to request a copy of the data we hold about you. Please contact email@example.com if you wish to request access to any of your personal data and we will always try to answer your questions in a friendly helpful way.
We will respond within one month of receiving your request. It will always help if you can be as specific about what personal data you want to see and what it relates to.
You have the right to correct information that we hold. Please advise us of any changes or corrections by contacting firstname.lastname@example.org
You may withdraw your consent to use any information that was previously provided with your consent. Please advise us if you wish to withdraw any consent previously given to email@example.com . You also have other rights which can be seen by visiting the Information Commissioner’s Office (ICO) website and reading about Data Protection law at
https://ico.org.uk/. You have the right to complain about any matter relating to our service including how we use your personal data: In the first instance please contact firstname.lastname@example.org If you are still not happy with our service you should use our formal complaints procedure which can be found at http://www.zebrahousing.com/feedback-complaints and that allows you ultimate recourse to the Housing Ombudsman Service at http://www.housingombudsman.org.uk
If you wish to complain about our use of your personal data you may complain to the Information Commissioner’s Office at https://ico.org.uk .
This is available on our website http://www.zebrahousing.com
CHANGES TO OUR PRIVACY NOTICE
Our Privacy Notice is regularly kept up to date and this version was approved by our Board on 12 April 2018.