Full privacy notice

Processing Purpose

Legal basis for processing

mhs homes customers

When you are an mhs homes customer, we will collect information from our interactions with you, including any complaints or allegations that are made by you, or about you, and we process this information to allow us to manage our relationship with you, collect your rent, and provide you with tenancy or sales related services appropriate support services and to manage any complaints or alleged ASB or similar issues.

This will involve sharing information with, and receiving information from, third parties, as explained below.

• Where crimes have been committed or alleged, we share information with the police and other agencies with investigative and prosecution powers.
• Where we have concerns about anyone requiring safeguarding for any reason or requiring protection from financial abuse due to a mental or physical health issue, we share information with the relevant authorities in order to get help for the people affected.
• We share rent information with local authorities for the purposes of administration of appropriate benefits.
• Where local authorities require information for council tax purposes, we confirm tenancy information to allow the correct tax to be paid. For more information on our sharing for fraud please see below.
• When necessary, we share information with debt collection agencies so they can collect debts on mhs homes’s behalf.
• We sometimes share information with utilities companies so they can collect debts on bills.

Personal data is shared between teams internally at mhs homes, but is only shared, accessed and used on a need-to-know basis, to enable relevant teams to carry out their tasks.

Most of the information we collect and use as part of our ongoing interactions with you is necessary for the performance of your contract and is linked to ensuring both you and mhs homes are complying with the requirements of the contract.

We have a legal obligation to keep business and financial transaction records as appropriate.

We will offer you further support based on both our and your legitimate interests to enable you to sustain your relationship (tenancy/shared ownership relationship) with us to the best of your ability.

If we contact you by email or text to let you know about our services, we will do so based on either our legitimate interests of keeping you updated about the services you receive from mhs homes, or based on your consent where we are contacting you about new services.

If we contact you by post to let you know about new services, we will do so based on our and your legitimate interests of keeping you updated about the services available to you.

You can opt out of receiving information about new services at any time.

We contact customers from time to time to ask for honest feedback, based on our and your legitimate interests of helping us to improve our services.

If we refer you to an external agency for further support, we will do so only with your consent to pass your details on to them, unless we believe there is an overriding lawful basis for the referral without your consent.

When we share information for the reasons explained, we will do so on the basis of it being necessary to protect individuals and communities, is for a task in the public interest (crime, benefits and tax payment) or for the legitimate interests of debt collection.

Sometimes we ask for information about race/ethnic origin, religion, health/disability, or sexual orientation, where we deem it is necessary for us to monitor and improve equality of opportunity and treatment, in the substantial public interest, and it is optional for you to provide this information particularly health/disability that having this information will enable us to provide services that meet individual needs.

Collecting special category information

mhs homes is dedicated to treating everyone fairly and providing equal opportunities, regardless of differences in race or ethnic origins, religious or philosophical beliefs, physical or mental health or sexual orientation. In order to monitor and improve performance in this area, we collect information about race, beliefs, health and sexual orientation from customers and employees, if you are happy to provide this information.

The processing of these special categories of data is necessary for a task which is in the substantial public interest, specifically for the purposes of identifying and monitoring equality of opportunity and treatment between different groups of people, with a view to enabling equality to be promoted or maintained.

Website for more information on what cookies we use please see our cookie pages.

General contacts

For members of the public who are not customers but come into contact with mhs homes in another way, such as to make an enquiry, we will collect information from our interactions with you, so that we can provide you with the information you have requested.

We process this information on the basis that it is necessary for our legitimate interests of responding to your enquiry, complaint or allegation, as appropriate. If we need to process any special categories of data in order to handle the issue, we do so with your explicit consent, or on the basis of it being necessary for a task in the substantial public interest, such as reviewing equality of opportunity and treatment.

Phone calls to our main telephone number are recorded so that we can monitor and review the quality and content of calls as necessary.

This processing is on the basis of our legitimate interest of providing good customer service, as well as protecting our colleagues and other people from any problems or issues arising from ambiguity in phone call conversations.

Business contacts

Contact details for people, organisations and companies we work with is personal data and we treat it accordingly. We will use it only as part of our relationship with your organisation, whether we work in partnership or have a customer/supplier relationship.

This processing is based on our legitimate interests of managing business relationships appropriately. We use the data only for the purposes explained, keep the data secure and safe, and protect your rights, freedoms and interests.

Surveys and feedback

In order to understand our customers’ experiences and improve our services and products, we will contact you at various “touch-points” during our relationship with you and ask you to complete a survey and give us feedback, by email, text or over the telephone. We contract with specialist companies to carry out surveys on behalf of mhs homes, which involves sending them your contact details and they gather your responses for us. You can opt out of this sort of contact if you prefer.

mhs homes, and the specialist companies we work with, process data in order to ask for your feedback, based on our legitimate interests of improving our customer services and products.

Customer Scrutiny Panel (CSP)

The Customer Scrutiny Panel is an independent customer group that reviews our services, listens to your feedback, and puts forward constructive recommendations to our Leadership Team to make a real difference to mhs homes.

All members of the CSP have received bespoke Data Protection training and sign agreements with mhs homes. They are only given information relevant to information depending on the project they are supporting.

For more information on the CSP including how to join visit their page.

Emergency situations

Unfortunately, there will always be emergency situations that negatively impact on our customers, employees and wider communities, and we will respond as appropriate and as quickly as possible in order to protect people and property. Whether we are responding to fire, flood, crime, safeguarding issues, pandemic, or any other emergency situation, mhs homes will treat people’s health and wellbeing as a priority, which we acknowledge includes protecting personal data and ensuring it is handled lawfully and securely.

Processing of data in the immediate response to emergency situations is done only where it is necessary to protect individuals and communities, on the basis that we are acting under employment or social protection law, or in the public interest / substantial public interest.

Applications for rented properties, garages and commercial properties

When you apply to live in an mhs homes, we collect information directly from you and from relevant third parties, about you and your household, in order to assess your eligibility and suitability for the application you have made.

We receive your contact details and housing need information from the Local Authority or via Home choice if you have been nominated by them and we take up references from former landlords.

Some decisions are made automatically about your eligibility, based on the answers you provide in your application, but you will always be given the opportunity to challenge an automatically made decision.

This processing is necessary for being considered for, and for signing up to, a tenancy agreement, which means entering into a contract with us. We need to know that you are eligible, and that you can afford the property, and/or sustain your tenancy and we may need to offer you additional support as part of your tenancy. If you do not provide the information, we need to be able to process your application, we may not be able to offer you a tenancy.

If you provide us with special categories of data, such as health, or disability in your housing application, we will process this data only as far as it is necessary for us to manage your application and ensure you are housed appropriately and safely, in line with our legal and statutory obligations as a housing provider and employer.

In some cases, we will process information about criminal offences and convictions, where it is necessary to do so in order to protect the safety and wellbeing of individuals and our communities, in line with our legal and statutory obligations as a housing provider and employer.

 When we ask for information about race/ethnic origin, religion, health/disability, or sexual orientation, this is where it is necessary for us to monitor and improve equality of opportunity and treatment, in the substantial public interest, and it is optional for you to provide this information.

We might also ask your personal and special category  information about the people you will be living with to help us gain a better understanding of your needs.

If your application is successful, we will use this information to create your profile on our core customer systems so we don’t have to ask you things twice.

Shared ownership enquiries and applications

When you enquire and apply to purchase a share of an mhs homes home, we collect information directly from you and from relevant third parties including any referees and your solicitor and mortgage provider, about you and your household, to assess your eligibility and suitability for the application you have made.

We will communicate directly with your solicitor and mortgage provider as necessary to facilitate the purchase.

In the early stages of making enquiries, data is processed on the basis of consent, and as a purchase progresses data is processed on the basis that it is necessary for entering into (or negotiating to enter into) a contract.

This processing is necessary for entering into a purchase agreement with us. We need to know that you are eligible and can afford the property and to meet our legal responsibilities regarding money laundering and fraud .

Maintain and enforce the lease or shared ownership lease agreement – including charging and collecting rent, investigating breaches of lease, and providing relevant leasehold services to you.

In some cases, we will process information about criminal offences and convictions, where it is necessary to do so in order to protect the safety and wellbeing of individuals and our communities,  in line with our legal and statutory obligations as a housing provider and employer.

When we ask for information about race/ethnic origin, religion, health/disability, or sexual orientation, this is where it is necessary for us to monitor and improve equality of opportunity and treatment, in the substantial public interest, and it is optional for you to provide this information. This monitoring information will not be used as part of your eligibility assessment.

Our support services

mhs homes does not just provide housing, we also provide support to people who need it, through our specialist services, some of which are linked to your tenancy and some of which are standalone, for example help with money management, getting back into work, or more general day to day support.

We process your data as part of providing this support on the basis of our contract with you, where it is tenancy-linked support, or on the basis of it being necessary for complying with our legal obligations or carrying out a task in the public interest.

Where we process special categories of data, or criminal information, about you as part of providing this support, we do this where it is necessary to protect individuals in line with our legal and statutory obligations as an employer and as a housing and support provider. Where this (or another) basis is not appropriate, we will ask for your consent.

Sometimes we ask for information about race/ethnic origin, religion, health/disability, or sexual orientation, where we deem it is necessary for us to monitor and improve equality of opportunity and treatment, in the substantial public interest, and it is optional for you to provide this information.

Sharing your data with our ‘Processors’

When mhs homes uses other companies to supply goods or services on our behalf, sometimes we need to share relevant information with those suppliers and contractors so they can carry out that work. They are known as our ‘Processors’ and are legally bound by contract to act only on our instructions regarding your personal data, and not use it for their own purposes.

The relevant legal basis for each Processor we use will be dependent on the type of work they are carrying out for us, and our legal basis for undertaking the processing that is linked to that work.

For example, we carry out repairs work on the basis of our contract with you, and in some circumstances the repairs may be contracted out to contractors who need your address etc. in order to carry out the repair. This makes the contractor our Processor.

The contracts we use with Processors comply with Article 28 of the UK General Data Protection Regulation (GDPR), which rules how Processors are appointed, and sets out their relevant responsibilities.

Sharing your data with other contractors

Sometimes, we share personal data with suppliers, contractors or consultants where they process the data on the basis of their own knowledge and expertise, not just acting on our instructions. For example, solicitors. In these cases they are not our Processors, but instead are Data ‘Controllers’ in their own right.

As Data Controllers these organisations have their own legal obligations and responsibilities to handle your data lawfully and safely and are also bound by contract to comply with their data protection obligations.

We share information with contractors etc. who are Controllers only when it is necessary for us to carry out our tasks in the public interest, to carry out our legal obligations, or for our legitimate interests of outsourcing the provision of some services and of providing appropriate support, to enable us to run the business efficiently. We do not share your data with any Controllers that we are not confident will protect your data, and therefore we protect your rights, freedoms and interests

Insurance claims

If a claim is made against mhs homes 's own insurance policies, by customer or a third party, we will sometimes need to share personal data with our insurance providers so they can assess the claim and handle it appropriately. Only minimal information will be shared, and it will be shared securely.

Data is shared with our insurance providers when it is necessary for us to fulfil our legal obligations, for example our responsibility to insure against employee and public liability and enable claims under the insurance cover.

Where special categories of data is shared with our insurance providers, such as health data, this is on the basis of it being necessary for a task in the substantial public interest, namely insurance purposes.

Our Software Providers

Our software providers are mhs homes “Data Processors”, which means they carry out work on our behalf, and under our control, which means they have access to the personal data we hold.

In particular, some software providers will need to access the personal data in order to review and fix problems with the software, from time to time. This involves the use of “Break-fix environments” all of which are in the UK or EU.. Where this happens, the access is well controlled with appropriate safeguards including contract clauses, non-disclosure agreements, access controls, and close monitoring. This is only done when the issue that needs to be fixed is a priority as it is affecting the way we can provide our services, and needs specialist work carried out.

Our Data Processors work on our personal data on the same legal bases on which we process personal data. We only use software providers that are able to demonstrate their compliance with data protection legislation, and we ensure controls are used as explained in the first column.

Exercising of Data Rights

If you ask us about exercising any of your Data rights, such as accessing copies of your data, or objecting to the way your data is being processed, or requesting relevant information as a resident in a so-called “higher-risk” building (high-rise buildings), we need to obtain relevant information from you in order to identify that you are the data subject in question, or acting on their authority.

When we fulfil requests such as these, specialist staff members will review the documents in question in order to fulfil the request lawfully, which will include redacting information about third parties.

The information processed to check your identity and to fulfil your request is only used for these purposes and is kept securely.

See full details on your data rights.

This processing is carried out as necessary for us to carry out our legal obligations of upholding your Data Protection rights

Complaints

In order to investigate and respond to complaints or allegations against mhs homes or an employee or customer of mhs homes, or complaints and allegations made about neighbours, or any other topic, we will usually require contact details and information about the complaint from you or your representative. We will request the minimum amount of information from you, and only use it for the purposes of the investigation.      

See full detail on complaints.

Customer complaint related processing is done on the basis of it being necessary for us complying with the terms of your contract with us. For complaints from non-customers, depending on the nature of the complaint, the processing is necessary for us to comply with our legal obligations or for carrying out our tasks in the public interest. If special categories of data are processed (including health, race, religion, sexual orientation) it is on the basis of being necessary for defending a legal claim or for acting in the substantial public interest. This includes responding to elected representatives such as MPs, who have raised a matter on your behalf where we have your consent.

CCTV

mhs homes uses CCTV in our offices and in some of our housing/schemes, as well as during development of new sites, for the safety and security of premises, property, colleagues, contractors, customers, neighbours, the public and any third parties.

CCTV footage will be disclosed to those organisations acting on official authority, including the police, as necessary to investigate potential crimes and to prosecute crimes.

We process data from CCTV for the purposes of our legitimate interest of protecting property and premises, and for carrying out tasks under our legal obligations and in the public interest/substantial public interest; these include protecting the safety of people and premises and supporting investigations into and prosecutions of crime and fraud, and other serious misconduct.

The use of personal CCTV and doorbell recording devices

Whilst we are not data controllers for private recording equipment we would like to remind customers of their responsibilities and what customers can do if they are unhappy.

As an interim the links are Customers using CCTV and ring door bells.

National Fraud Initiative

As part of our commitment to tackle housing tenancy fraud we will be participating in the national fraud initiative phase 2 pilot during 2024 which is being led by the cabinet office. This initiative uses data from multiple sources and is designed to address key housing fraud risks such as subletting.  Full details of the pilot can be found on the cabinet offices website. 

Building safety related data

Sometimes it is necessary for us to collect, hold and process information about people who live in, or are otherwise connected with, our buildings for the purposes of managing and protecting the safety of all people connected with our sites; our customers and family members, guests, and neighbours, as well as our colleagues, contractors, and the wider community.

This includes the use of CCTV, as explained above, resident engagement activities for safety purposes, emergency evacuation planning, and monitoring and reviewing building access records in the case of suspected crime or misconduct affecting safety.

We process data for purposes related to building safety in order to comply with Health & Safety and Building Safety legal obligations to protect people and acting in the substantial public interest to protect the community from potential harm.

CORE reporting

So that the Department for Levelling Up, Housing and Communities (DLUHC) can produce statistical information, we are required to report information to them about our lettings and shared ownership sales via the CORE (Continuous Recording) system. The information provided does not include your name or full address, but it does contain special categories of data.

The processing of this information by the DLUHC is necessary for the performance of a task in the public interest and so far as the data includes special categories, the DLUHC states that the processing is necessary for reasons of substantial public interest. The data is used to compile statistics on the use of social housing, including reviewing equality of opportunity and treatment.

Please see the CORE website for more details.