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Our privacy notice

How we will use your information

The Guinness Partnership Ltd, 30 Brock Street, Regent’s Place, London, NW1 3FG will be responsible for determining the use of your information.

We’re committed to protecting the personal information we collect about you. This privacy notice explains what happens to the information you are providing to us.

  • Scope of this Privacy Notice

    This Privacy Notice applies to you if you ask us about, or use our services in relation to buying a home. This includes Private Sale, Shared Ownership, Right to Buy or Right to Acquire.

    It describes how we handle your information, regardless of the way you contact us (for example by email, through our website, by phone and so on). We will provide you with further information or notices, if necessary, depending on the way we interact with each other, for example, if you apply for a lease extension.

  • Data Protection Officer

    Our obligations under Data Protection Regulations are overseen by the Information Management Governance and Risk Team who can be contacted on informationmanagement@guinness.org.uk

    The Guinness Partnership has appointed a Data Protection Officer to monitor our compliance with Data Protection Regulations.

    If you have any concerns, our Data Protection Officer can be contacted by using on dataprotectionofficer@guinness.org.uk or by writing to:

    Data Protection Officer
    The Guinness Partnership
    Bower House
    1 Stable Street
    Hollinwood
    Oldham
    OL9 7LH

  • What type of personal data do you hold?

    We collect ‘standard personal data’, special category (previously sensitive) personal data and information about any criminal convictions you may have had.

    Standard personal information includes:

    • contact information, such as your name, username (when registering online), address, email address and phone numbers

    • your age, your date of birth and national identifiers (such as your National Insurance number or passport number)

    • information about your employment

    • details of any contact we have had with you, such as any complaints or incidents

    • financial details, such as details about your payments, your bank details or financial circumstances;

    • information about how you use our products and services, such as disrepair claims

    • information about how you use our website or other technology, including IP addresses or other device information

    • Information to any criminal convictions you may have had

    Special category information could include:

    • Disability or other relevant health information
  • Why do you need my personal data?

    We need to know your personal data in order to:

    • Assess and manage your application to purchase a home

    • If you are applying for a Shared Ownership property or a Leasehold property to manage the services as part of your agreement with us

    • Assess your financial affordability

    • Ensure you have the right to live in the U.K

    • Carry out Credit Reference Checks so that we make fair and responsible decisions about whom we sell properties to

    • Process your payments to us

    • To ensure there is no unacceptable risks posed to you, our staff and contractors

    • At your request to involve you in Guinness initiatives and the opportunity to feedback and shape Guinness services; and

    • ensure we are fair and transparent with all customers

    We need a lawful reason to use your information, for the majority of your personal information we will use one of the following conditions:

    • Consent – for example to keep you updated or involved in Guinness initiatives. We will never ask for consent where if you do not consent would put you at a disadvantage.

    • Necessary to take steps or for the performance of a contract – if you have applied for a home or we have an agreement with you, we will process your personal information to fulfil that agreement (that is to provide you and your household with amazing service), without this we caanot progress your application.

    • Legitimate interests – there will be from time to time a need for us to process your personal data in our or a third parties legitimate interests.

    Further information can be found in this Privacy Policy.

    We will process special category information to ensure that there are no risks posed to you or your household. This could include processing for the purposes of:

    • health information – to ensure your home has any necessary adaptations so that you can live without further risks to your wellbeing

  • Legitimate Interests

    We will also process your personal information if it is in our legitimate interest to do so, including managing some aspects of our relationship with you, for marketing, to help us improve our services to you, and in order to exercise our rights or handle complaints. More detailed information about our legitimate interests is set out below.

    Legitimate interest is one of the legal reasons why we may process your personal information. Taking into account your interests, rights and freedoms, we have carried out Legitimate Interest Assessments which allow us to process your personal information including:

    • Communicate with you by text message to keep you updated on our service delivery 

    • Carry out customer surveys with a third party to help us improve services to you

    • To identify and investigate fraud, corruptions and/or bribery

    • To engage with contractors when carrying out a planned maintenance programme of work

    • To trace former customers, if we need to contact you if you still have arrears

    • To supply your details to utility companies (for shared owners) when you move out of your home to ensure correct payment of utility bills 

    • To record some telephone calls for the purpose of monitoring quality and training. 

    If you wish to object to us using your information for any of these legitimate interests please contact us at:

    Information Management Governance and Risk Team 

    The Guinness Partnership
    Bower House
    1 Stable Street
    Hollinwood
    Oldham
    OL9 7LH

    Or use any of the following methods:

    • by email informationmanagement@guinness.org.uk

    • Telephoning us on: 0300 456 0522

    • Use our contact form on our website, or

    • Live Chat with us via our website

    We will need to be sure that it is you making the request so may ask for two forms of identity if we have any doubts.

    We will consider each and every request and respond within one month. If your request is particularly complex we may extend this, by exception, for up to a further 2 months.

    We will let you know if this is the case at the earliest opportunity.

  • Marketing and Preferences

    We may use your personal information to send you marketing by post, by phone, through social media, by email and by text, for example, to keep you updated of upcoming properties available to purchase in your area.

    We can only use your personal information to send you marketing material if we have your permission or a legitimate interest as described above.

    From time to time we also run direct marketing campaigns, in our legitimate business interests, promoting Guinness Homes in your area, using a third party called Precision Connects.

    You can ask to stop receiving these communications or update your preferences by using one of the following options:

    • Selecting 'unsubscribe' at the bottom of our emails sent to you

    • Returning the mail you receive from us as "return to sender"

    • Telephoning us on: 0300 456 0522

    • Use our contact form on our website, or

    • Live Chat with us via our website.

    If you ask us to stop, we will need to keep a small amount of your information so that we don't by accident, start sending yopu communications again.

  • Who will you share with and receive my personal data from?
    • Our Communications team

    • Our Business Support teams

    • Our Fixed Assets team

    • Our Customer Accounts team

    • Our Customer Service Centre

    In order to be able to provide you with effective services we will be required to share with/receive your personal data from external organisations and/or people such as:

    • People who you have authorised to act on your behalf

    • The main customer, if you are not the main customer living in the household

    • Zoho our Customer Relationship Management system supplier to manage your preferences with us, manage your application for outright sales or shared ownership and track your visits to the Guinness Homes website

    • Equifax and/or Experian to carry out Credit Reference checks

    • Barclaycard to manage your reservation deposits to us

    • Trowers & Hamlins and Taylor & Emmet our Solicitors

    • Your Solicitor

    • The Sellers Solicitor (when purchasing a pre-owned home)

    • KPMG - our Auditors

    • Homes England who regulate our activities

    • Kwest and Voluntas that carry out surveys on our behalf

    • Surveyors

    • Your MP or local councilor where they are representing you and your interests

    • For Shared Owners, Right to Buy and Right to Acquire your previous landlord

    • When investigating complaints made by you and/or others

    • When you call us your call may be recorded for quality and training purposes

    • If you are a former Shared Owner in arrears we use Esendex to send text messages to you about your shared owner account

    • If you are a former Shared Owner in arrears the relevant court in any legal proceedings.

    In some cases we may have a duty to disclose your information to:
    other housing associations

    • our regulators and government departments

  • How will you keep my information safe?
    • We will apply appropriate measures to ensure your personal information is secure.  For example, we have systems in place so that access to personal information is restricted to authorised individuals on a strictly need-to-know basis.

    • When we need to share personal data with our contractors and third party suppliers, we have contracts with them that sets out their responsibilities 

    • 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).

    • Making sure staff complete mandatory Data Protection Training

     

  • Transferring information outside the European Economic Area (EEA)

    We deal with many international organisations to help us manage your tenancy and provide services to you. We will try our best to ensure that your personal information is not transferred outside of the EEA, however, sometimes your information will be. Not all countries outside the EEA have data-protection laws that are similar to those in the EEA and if so, the European Commission may not consider those countries as providing an adequate level of data protection.

    The Guinness Partnership has ensured that appropriate safeguards are in place for these transfers such as

  • How long will you keep my information?

    If you purchase a Shared Ownership home then your information will be retained until 6 years after the lease has been sold/transferred.

    If you purchase a Freehold property outright from Guinness then the information you have provided will be kept for 12 years from completion of your home.

    If you purchase a Leasehold property outright from Guinness then your information will be retained until 12 years after the lease has been sold/transferred.

    Unsuccessful applications will be retained for 6 months.

    The results of our customer satisfaction surveys will be retained for 2 years.

  • What rights do I have in relation to the information you hold on me?

    Data Protection law gives you greater control as to how we can use your information. To enable this you have the right to request us to take action in relation to your information. You have the following rights:

    • Right of Access – the right to request details as to how we use your information and to be provided with a copy of that information.

    • Right to Rectification – the right to have inaccurate data corrected

    • Right to Erasure – the right to have certain information about you deleted

    • Right to Restriction – the right to request us to limit the use of your personal information in certain circumstances

    • Right to Object – the right to object to us using your information for a task carried out in the public interest, where we have informed you that we are processing in our or a third parties legitimate interests or if we use your information for direct marketing

    • Right to Data Portability – the right to request certain types of information to be provided to you or transferred to a third party in an electronic, machine-readable format. Currently this will be provided in a .csv format.

    • Right to Withdraw Consent – if we have asked for your consent to process some of your personal information, you have the right to withdraw this at any time. We will never ask for consent for providing a service to you or if you would be disadvantaged if you did not want to consent.

    • Automated Decision Making – we currently do not make any decisions relating to you in a solely automated fashion. i.e. without any human involvement. If we do we will tell you and you will have the right to request us not to unless it is strictly required to enter into (or performance of) your contract, required by law or you have provided your explicit consent.

    Please note that these rights are not absolute and will be considered on a case by case basis except where you withdraw consent or object to direct marketing.

    In each case we will let you know in our correspondence with you whether we can comply with your request and provide a full explanation if we cannot comply.

  • How do I make a request in relation to my rights under Data Protection?

    When you make a request we need to be sure that it is you applying. You will need to either pass our data protection checks or we may ask you to provide 2 forms of identification if we have any doubts.

    We will consider each and every request and respond within one month of receiving a valid request. If your request is particularly complex we may extend this, by exception, for up to a further 2 months.

    If you would like to request access to your personal data you can by using our online form here.

    You can also request access to your personal data or to exercise any of your other rights, by contacting us at:

    Information Management Governance and Risk Team 
    The Guinness Partnership
    Bower House
    1 Stable Street
    Hollinwood
    Oldham
    OL9 7LH

    Or use any of the following methods:

  • Visitors to our website

    Our website is hosted by a third party, Prodo. Also some functions on our website, like our Shared Ownership application form, are hosted by our Customer Relationship Management supplier Zoho. 

    When you submit information on our website this will be stored on secure servers at Prodo and Zoho.

    When someone visits www.guinnesshomes.co.uk we use two pieces of tracking software, Zoho Sales IQ and Google Analytics. We use the Internet Protocol address, browser type, browser language, referring URL, files accessed, errors generated, time zone, operating system and other visitor details collected in our log files to analyse trends, administer our website, track visitor movements and to improve our website.

    We link this automatically collected data to other information we collect about you like your name and email address.

  • What do I do if I am not happy?

    If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer on dataprotectionofficer@guinness.org.uk who will investigate the matter.

    If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can make a complaint to the Information Commissioner’s Office (ICO).

    Information Commissioner
    Wycliffe House
    Water Lane
    Wilmslow
    Cheshire
    SK9 5AF

    Telephone: 0303 123 1113

    www.ico.org.uk

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