Privacy notice for tenants and customers of Jigsaw Homes Group Limited.
Jigsaw Homes Group Limited recognises the importance of respecting your personal privacy and the need to have in place appropriate safeguards surrounding the processing of personal data. As a company who has access to and controls your personal data (a ‘Data Controller’) we are required to provide you with certain information about how we collect, store, destroy and otherwise deal with (also known as ‘process’) your personal data. We are also registered with the Information Commissioner’s Office (‘ICO’) as a Data Controller.
The Group uses closed circuit television (CCTV). For more details please view our CCTV Policy here.
We also collect data on behalf of CORE. For more details please view their privacy notice here.
Who is the data controller and what are their contact details?
The Data Controller is the company that decides the purpose for and the way in which any personal data is processed, Jigsaw Homes Group Limited and certain of its subsidiaries are data controllers registered with the ICO and details of all of the subsidiaries are set out below.
Jigsaw Homes Group Limited
ICO registration number: Z832622X
Registered as a Community Benefit Society with FCA registration number: 29433R
Housing Regulator registration number: LH4345
Jigsaw Homes Midlands
ICO registration number: Z1599688
Registered as a Community Benefit Society with FCA. Registration number: 8378.
Housing Regulator registration number: L4532
Jigsaw Homes North
ICO registration number: Z1657414
Registered as a Community Benefit Society with FCA registration number: 16668R
Housing Regulator registration number: LH0131
Jigsaw Homes Tameside
ICO registration number: Z1599674
Company number 3807022
Charity Commission number 1146435
Housing Regulator registration number: LH4266
ICO registration number: Z6749053
Registered as a Community Benefit Society with FCA registration number: 8241
Chorley Community Housing Limited
ICO registration number: Z9847037
Registered as a Community Benefit Society with FCA registration number: 30155R
Housing Regulator registration number: L4487
The registered office address for the above companies is:
In most cases the Data Controller will be the landlord responsible for your personal data as a tenant or the company who you are in receipt of any other services from. If you are in any doubt as to who your Data Controller is please get in touch with our Data Protection Officer.
Do we have a Data Protection Officer?
The Data Protection Officer for the Jigsaw Group is Matthew Selby who is contactable via email on firstname.lastname@example.org and in writing at:
What information do we collect about you and how?
We hold personal data such as your household’s names, dates of birth, contact details and records of any transactions such as payments or requests for information as well as sensitive personal data such as income information, gender, ethnicity, religion or other beliefs, sexual orientation and medical history.
We may collect information about you in a variety of ways including (and this list is not exhaustive):-
- we receive a nomination from a local authority or referring partner;
- you complete various forms, and contracts (such as application forms, tenancy agreements, employment support programmes etc.);
- you apply to become a customer; we obtain information to determine your housing needs and in order to help us assess your application we may take up references from other housing providers/private landlords, your mortgage lender (if you own/have owned your own home), the Police, the Probation Service, support workers, social workers, mental health workers and credit reference agencies;
- you become a customer including when you select an offer of one of our properties; we will also need your bank details, benefit and council tax information;
- you request any of our services;
- you apply for one of our home ownership products;
- you voluntarily complete our customer surveys;
- you provide feedback or make a complaint;
- you make an application and become a member of staff;
- you make an application and become a Board member;
- our officer/agents/contractors attend appointments with you;
- you contact us or use our services and we note any action taken, for example logging repairs, so that we have a record of what happened;
- we engage in other aspects of routine contact with you;
- we work with support agencies and third parties which relates to you;
- we have contact with people associated with you such as family, friends and neighbours;
- you use of our websites, social media sites and self-service portal;
- we take photographs, audio sounds, videos and comments at events organised and/or hosted by Jigsaw or one of the companies within the Jigsaw Homes Group. The photographs, audio sounds, videos and comments may be used by us in a variety of online/offline platforms and may be provided to the media for publication in local or national media outlets. Distribution of these materials may be geographically diverse to promote the products and services of Jigsaw Homes Group. The material may be edited to enable use in a variety of formats but this will not change the sentiment of the views expressed therein. If you do not wish your image/material to be used by us in this way, please make this known to a Jigsaw employee at the event you are attending or, if it is after you have attended the event, by emailing email@example.com.
- we record calls to and from our landlines in Connect (our contact centres). All telephone calls made to our Contact Centre are recorded and are used to train and coach staff and improve the services that we provide to you;
- we may collect data about your energy usage via 3G apps in the equipment we install in your home;
- where we have CCTV cameras to record events in public areas and we monitor and collect visual images and audio for:-
- security reasons;
- prevention and detection of crime; and
- staff safety and monitoring purposes.
If you provide us with personal information relating to members of your family or your associates we will assume that you do so with their knowledge and consent.
It is important that you notify us of any changes to your personal information as soon as possible so that we can contact you easily.
What is the lawful basis under which we use your data?
Processing personal data is lawful if the data subject (eg. you as our customer) has given consent or where the processing of personal data is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Processing of your data is lawful if you apply for housing with us, apply for a job with us or have been housed by us. We do not need your explicit consent to process your data in these circumstances.
Do I have to provide this information and what will happen if I don’t?
Where you are a tenant of ours we will use your personal data to contact you about your rent, repairs or other housing management issues. The consequences of not providing accurate and up to date personal data in this example may mean that we could not properly and effectively manage your tenancy under the agreement we have with you.
Who the personal information relates to
We collect and hold personal information about:
- customers – This includes current, former and potential customers who live in our properties or access our support and other services and includes members of their family and people associated with them.
- visitors – Visitors to our website and our offices.
- anyone who makes a complaint or enquiry to any of the Jigsaw Homes Group companies.
- partners, including employees and representatives of organisations with whom we do business including contractors, suppliers and other agencies.
How will we use the information about you?
We use your personal information to:
- enable us to provide you with accommodation and to communicate with you
- provide social and other types of housing
- assess your ability to afford our home ownership products by sharing your name, address and contact details with our appointed contractor. We will also notify any third parties involved in the sale of the property you are buying of the outcome of your application
- undertake Property and grounds maintenance and repairs
- manage your housing, tenancy/lease and accounts as your landlord or provider of another service to you
- ensure that we meet all our legal and statutory duties such as those which apply under the Equality Act, Fire safety etc and those owed to our funders and regulators
- promote equal opportunities and fair treatment for all our customers
- provide information (e.g. about products and services) you request from us
- help with crime prevention, prosecution of offenders and resolution of disputes. Where an allegation of a tenancy breach is made we will record the details on our case management system and will retain the details of such allegations for the duration of the tenancy of the (person or persons) against whom they are made, whether or not they are proven, as a means of establishing a pattern of anti-social behaviour that may assist us in taking enforcement action at a later date either against the alleged perpetrator(s) or the alleged victim(s);
- prevent and detect fraud and money laundering
- promote safety and the quiet enjoyment of our neighbourhoods and communities in our capacity as social housing providers
- engage with customers and make improvements to our products and services
- improve services by gathering your feedback in automated surveys
- protect individuals from harm as part of our safeguarding and other obligations
- provide you with welfare services including advice and appropriate support
- provide support for elderly and vulnerable customers
- keep in touch with our customers, understand your needs and preferences and invite you to events
- apply for grants to make improvements to your home; and
- carry out research and to provide anonymised information to help improve our services
Sensitive personal data
Certain personal information is classified as ‘special categories data’ and means any personal data which tells us about your ethnic origin, political opinion, religious or philosophical beliefs, trade-union membership or anything revealing your genetic data, biometric data or anything which has the purpose of uniquely identifying you, anything concerning health or data relating to a person’s sex life or sexual orientation, allegations of criminal offences and criminal convictions and offences.
We minimise our holding and use of special categories data but, given the services we provide, there are times when we use it to understand our customers and their needs better, for example when providing accommodation for disabled persons or those with problems around substance abuse, when resolving neighbourhood disputes involving alleged criminal activity or anti-social behaviour or when helping someone to access care services. When we collect specific sensitive data we will notify you of how we will use it, including who it may be shared with, and seek your consent to this.
We also use sensitive personal data to ensure that we are complying with our obligations under the Equality Act.
Will you be using my information to make any automated decisions?
We do not propose to use your personal data to make any automated decisions. Should our policy change, we will write to you and tell you this.
Who we will share/send your information to:
Your personal information will be kept secure and confidential and access to it by staff of Jigsaw Homes Group is managed and monitored. We may share information with contractors or agencies we work with such as Local Authorities, Social Services, Police, other social landlords, energy hubs, the Department for Business Energy and Industrial Strategy and any other situation where we are required by law and/or where we believe it is in your or the public’s interest to do so.
We may share your data with companies who provide cloud-based information services and systems. Any third party asked to process your personal data on our behalf will be bound to strict terms and conditions outlined by us and will not be permitted to share your data with other organisations.
We will not transfer your data with any organisation outside of the European Economic Area.
The list below sets out specific examples of where we may share your information but this is not an exhaustive list. In processing your personal data we may:-
- share current or forwarding addresses with utility companies and Council Tax offices to ensure billing details are correct,
- share information about you with authorised debt recovery agencies to enable them to recover the debt if you default on any tenancy/licence conditions. This may affect future applications for tenancies credit and insurance,
- discuss your financial situation and share information about rent payments (including any arrears) and any claims made for welfare benefits with the local authority housing benefit department, the local authority’s housing advice and homeless prevention team or the Department of Work and Pensions to make sure that benefits are paid correctly;
- pass data about your rent payment record to credit reference agencies to enable them to assist other organisations to assess your financial standing if you apply for products and services,
- pass your contact information to a third party to conduct surveys and research on our behalf which allow us to gather feedback and improve the services we offer you.
- share your National Insurance number to verify your Universal Credit application and manage these payments,
- share your National Insurance number in order to prevent and investigate tenancy and Right To Buy application fraud
- share your data with Motiv8 delivery partners and funders (details at www.motiv8mcr.org/) if you are on this programme.;
- share your energy usage data with energy companies (other than your preferred energy supplier) and with heat pump and other heating product manufacturers.
Changes to this privacy notice
This privacy notice will be updated to reflect any changes either to the way in which we operate or changes to data protection legislation. We will bring any significant changes to your attention but to make sure that you keep up to date, we suggest that you revisit this notice from time to time.
How long will you store my personal data for?
We store personal data in line with our own document retention policy, a copy of which is available on request. Examples are:
- applications for accommodation: kept for 6 years after offer accepted;
- tenancy files: kept for 6 years after the end of the tenancy;
- application forms for shortlisted job applicants: 1 year;
- application forms for non-shortlisted job applicants: 6 months.
How will my personal data be stored and kept secure?
The Group applies technical measures to keep personal data stored securely on information systems, including controls over the organisation’s information network perimeter, such as firewall, anti-virus software and back-up/replication measures to prevent data loss. Access to personal data held on systems is controlled by password and can be monitored by audit records. Sharing of data with third parties is controlled by the use of secure transfer measures such as encrypted email and secure file transfer protocols.
The data held on mobile devices (smart phones, tablets and lap-tops) used by staff are encrypted. Staff are equipped with lockable bags for carrying personal data files outside of the office and we apply a clear desk policy in our offices.
The technical measures are supported by training and awareness raising exercises to ensure that staff understand the risks and their responsibilities for keeping personal data secure.
Your rights in relation to the personal data you provide:
We have set out below some information on the rights you have under the General Data Protection Regulation effective from 25 May 2018. More information can be found by visiting the ICO website at www.ico.org.uk.
You have the right to:
- be informed about our collection and use of your personal data;
- access the personal data we hold about you (see below);
- ask us to rectify any personal data we hold about you if it is inaccurate or incomplete;
- ask us to delete any personal data we hold about you. We only hold your personal data for a limited time as explained above but if you would like us to delete it sooner please contact us. However, we need to maintain certain records to enable us to comply with our contractual or statutory obligations so certain information may still be retained by us even if you make such a request;
- restrict (i.e. prevent) the processing of your personal data;
- data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- object to us using your personal data for particular purposes;
- be informed about when we are using your personal data in automated decision making and profiling and object to this. We will inform you where such decisions and profiling occur; and
- withdraw your consent to our use of your information where the information was previously provided with your consent, please advise us if you wish to withdraw any consent previously given by writing to : firstname.lastname@example.org
If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 2 above and we will do our best to solve the problem for you. If we are unable to help you also have the right to lodge a complaint with the ICO; please go to www.ico.org.uk.
Accessing your information
You have the right to access any personal information we hold about you. There is a formal process for this known as a Subject Access Request (SAR). If you would like to make a SAR please send a request in writing to email@example.com or in a letter to our registered office address above. We may require some proof of identity from you before releasing information.
We are required to provide this information within one month of receiving your request and will not normally make a charge for this service. However, we may make a charge where we consider the amount of information you have requested to be complex or if you make numerous requests, and we may then take up to three months to fulfil your request.