Privacy notice

Your privacy is important to us. We only collect the information we need from you and your household to provide you with our services. Our Privacy Notice describes the categories of personal data we process and why.

Under the data protection legislation, including the Data Protection Act (DPA) 2018 and United Kingdom General Data Protection Regulation (GDPR), we have to tell you why we collect information about you, how we plan to use it, if we’ll share it with anyone else and how long we’ll keep it for.

1. Introduction

2. About mhs homes

3. Your privacy rights

4. What kinds of personal identifiable information we use

5. Why we collect this information

6. How we gather your personal identifiable information

7. Capturing images

8. How we lawfully use your personal information

9. Our legal basis for using your personal information

10. Sharing and getting back your personal identifiable information

11. Regulators and other legal obligations

12. International safeguards

13. Accuracy of your information

14. Data Protection Impact Assessments

15. Commitment to Refer

16. How to make a complaint

17. Our Data Protection Officer

18. Having control of your personal information

19. Can we use your information for any other purpose?

20. Deleting your information

21. Your rights

22. Transfers outside of the UK

23. How long we keep your personal information for

24. Keeping you up to date

25. Direct marketing

26. Email marketing

27. Your online activities

28. Our legal requirements

29. Phishing

Equality statement

Data protection

Feedback

1. Introduction

1.1 We take your privacy seriously and you can find out more here about your privacy rights and how we collect, use, share and secure your personal identifiable information. This includes the personal identifiable information we already hold about you now and the further personal identifiable information we might collect about you, either from you or from a third party. How we use your personal identifiable information will depend on the products and services we provide to you

1.2 This Privacy Notice is a public document available to anyone. It explains how we and appointed third party organisations use your personal identifiable information and it details your rights.

1.3 See section three for more information about your rights and how our Data Protection Officer (DPO) can help you.

1.4 Our Data Protection Officer (DPO) provides help and guidance to make sure we apply the law to the processing and protection of your personal identifiable information. If you have any questions about how we use your personal information, the Groups’ DPO can be contacted by email at data.protection@mhs.org.uk or by post at mhs homes, Broadside, Leviathan Way, Chatham, Kent, ME4 4LL

1.5 This Privacy Notice provides up to date information about how we use your personal information and replaces any previous information we have published/supplied about using your personal identifiable information. This Privacy Notice will change. This notice is non-contractual. mhs homes reserves the right to update this privacy notice at any time according to the need to. You will be notified if any changes to this Privacy Notice are significant.

2. About mhs homes

2.1 We provide safe, secure affordable homes. We’re a charitable housing association operating in north Kent, owning and managing over 10,000 homes. We employ more than 250 people. We’re unique in being the largest social landlord in the UK not registered with the social housing regulator and have two main subsidiaries - Heart of Medway Housing Association and mhs community charity.

2.2 Our registered address is:
Broadside
Leviathan Way
Chatham
Kent
ME4 4LL

mhs homes Ltd is a private company limited by guarantee. Our Company number is 10704997

2.3 mhs homes group is a group of companies; where we refer to ‘we’ or ‘us’ in this Privacy Notice, we are referring to all companies within the group

2.4 mhs homes Ltd is the 'data controller' of your personal identifiable information

Company ICO Notification Ref Regulated by
mhs homes Ltd  Z629086 Charity Commission
Heart of Medway Housing Association ZA079387 Regulator of Social Housing
mhs community charity Z5296068 Charity Commission

3. Your privacy rights

3.1 As a data subject you have eight rights:

1. The right to be informed
2. The right of access
3. The right to rectification
4. The right to erasure
5. The right to restrict processing
6. The right to data portability
7. The right to object
8. Rights in relation to automated decision making and profiling

3.2 In brief, you have the right to be told about who’s obtaining and using your personal identifiable information, how it’ll be retained, shared and secured and what lawful grounds will be used to obtain and use your personal identifiable information. You have the right to object to how we use your personal identifiable information in certain circumstances. You also have the right to obtain a copy of the personal identifiable information we hold about you

3.3 In addition, you can ask us to correct inaccuracies, delete or restrict personal identifiable information or to ask for some of your personal identifiable information to be provided to someone else

3.4 You can make a complaint if you feel we’re using your personal identifiable information unlawfully and/or holding inaccurate, inadequate or irrelevant personal identifiable information which if used may have a negative impact on you and/or your rights. See section 15 on how to make a complaint

3.5 To make enquires for further information about exercising any of your rights in this Privacy Notice, please contact data.protection@mhs.org.uk or write to us at:



The DPO
Broadside
Leviathan Way
Chatham
Kent
ME4 4LL

4. What kinds of personal identifiable information we use

We currently collect and process the below information. Whilst we do collect all of the below information, we do not collect every piece of listed information in every instance with every customer:

  • Personal identifiers (for example, name, DOB, gender, tenancy reference, national insurance number, photographs, marital status)
  • Contact information (for example, home address, email address, mobile and home number, next of kin contact details, references)
  • Browsing information via Hotjar (for example, browsing time, cookie information, IP address, browsing history within the mhs website, user account information for the My Account portal)
  • Financial information (for example, bank account information, bank statements, income and benefit details, credit history information)
  • Criminal convictions information
  • Video or audio footage (for example, we may have CCTV cameras on some developments, and complainants may record alleged noise nuisance on their mobile device and send this to us)
  • Other information – This may be information that does not directly relate to yourself as an individual, but where you may be identifiable (for example, our smart homes initiative in some properties collects property address, boiler usage, property humidity, condensation, hot water usage)

Special category information – this is considered to be sensitive. The special category data that we collect includes:

  • Sexual orientation
  • Ethnic origin
  • Religious beliefs
  • Long-standing illnesses, conditions, or impairments, and informal carer status
  • Other health data

 

5. Why we collect this information

5.1 We use your personal data in various areas of our work, including:

  1. Management of homes
  2. Collection of rents, other sums and receipt of benefits
  3. Maintenance/repair of your home
  4. Regulatory purposes - e.g. requirements of the Regulator of Social Housing research
  5. Legal proceedings
  6. To meet health and safety requirements of our residents and staff
  7. Prevention and reduction of crime including fraud
  8. Equal opportunities monitoring
  9. Research
  10. Improving our service to you

5.2 Sensitive personal data is normally only held if you or someone authorised by you (e.g. a doctor or social worker, or someone living with you) has given us the data.

5.3 We only ask for special categories of information where it’s necessary for the service using legitimate business interest and our legal basis of processing i.e. our processing condition as required under Article 9

5.4 Where we’re using your information because you’ve provided your consent, you are entitled to withdraw your consent at any time. The lawfulness of our use of your information before consent was withdrawn isn’t affected.

5.5 Typically, we hold and process such data regarding managing your housing arrangements to meet your needs. We also use anonymous information about our customers to identify which services we need to provide.

5.6 Sometimes where we ask for your personal identifiable information to enter into a contract/agreement with you (for example: tenancy agreement, lease, housing application, support plan) or to meet our legal or regulatory duties (for example: to process housing applications, council tax benefit, equality monitoring and/or government or housing regulator reports), we won’t be able to provide some of our housing, support or products or services without it

5.7 We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

5.8 Most of the sensitive information that we collect is known as special category personal data. In some circumstances we need to collect special category personal data:

  • To provide specific services to you
  • For equality monitoring purposes

As well as a lawful basis for collecting the following information about you, we will need to satisfy a specific condition.

5.8.1 Providing specific services to you

We may collect sensitive information from you depending on the services you wish to take from us.

5.8.2 Equality monitoring purposes

We obtain your consent to collect your information for equality monitoring purposes. This is to perform statistical analysis and make sure our services are delivered fairly without discrimination.

6. How we gather your personal identifiable information

6.1 We obtain personal identifiable information by various means, this can be by face to face, by email, telephone, and correspondence and or by receiving this information from others, for example: a local elected member who’s representing you, police, health or social care agencies, benefit agencies. We can also receive information about you from other people who know you and/or are linked to you (for example: relative, person nominated to act on your behalf or your legal representative). Some further examples are below:

  1. directly from you, for example: when you fill out an application, transfer or mutual exchange form or as part of your right to buy application
  2. by observing how you use our housing, support, products and services, or those of other members of our Group for example: from the transactions and operation of your accounts and on-line services
  3. from other organisations such as former housing and support providers, health and social care agencies, law enforcement agencies, debt collectors, energy or utility companies, benefit agencies and or credit reference and fraud prevention agencies
  4. from other people who know you including joint account holders and people you are linked to you or live in the same community as you with regard to reports of anti-social behaviour
  5. from monitoring or recording calls as part of quality and complaints monitoring. We record these calls for training and to ensure the safety of our staff. We’ll not record any payment card details as part of our accounts and payments operations
  6. from our CCTV systems for the prevention and detection of anti-social behaviour or crime, or to detect damage or vandalism to our properties and to ensure the safety and security of our staff and individuals obtaining services from us.

7. Capturing images

7.1 Before any CCTV cameras are installed, a privacy impact assessment is conducted to ensure that their installation is justified, necessary and proportionate.

7.2 We use CCTV cameras to manage the safety and security of staff and visitors to all corporate buildings and some properties that we manage and own. Cameras are clearly marked with signage explaining that cameras are in use. Further detail on how we manage cameras is available in our CCTV policy which can be requested by contacting us.

7.3 We may also capture and process images during events organised and hosted by mhs homes using film photography, digital photography, video or other medium and may be used on our websites, in brochures or other publicity material (such as internal and external newsletters and social media) and may be provided to the media for publication in local or national news publications. We’ll tell you when we’re undertaking recording of this nature and if you don’t want to be included, let a member of staff know.

7.4 We undertake to inform all those whose images may be recorded (or their parents/guardians if under 18 years of age) of the purposes for which the images may be used by us. We inform all persons taking part in our activities that they may be photographed, filmed, videoed or otherwise captured in image form. Where reasonable and practical to do so, we’ll seek written consent to capture images. Where this isn’t possible for practical reasons, unless express objections are received, individuals attending a mhs homes event are deemed to have given their consent by attending or remaining at the event. Any queries or complaints should be raised with the event host in the first instance.

7.5 mhs homes acknowledges its responsibilities in capturing images by photography or other means under the provisions of the following legislation:

  1. The Protection of Children Act 1978 - We recognise that it’s a criminal offence to take, permit to be taken, distribute, have in one’s possession or publish indecent photographs (including films and other imagery) of children
  2. The Human Rights Act 1998 - We recognise an individual’s rights to privacy as protected by this Act

8. How we lawfully use your personal information

8.1 In accordance with the data protection laws, we need a "legal basis" for collecting and using information about you. There are a variety of different legal basis for processing personal data which are set out in the data protection laws.

8.2 The lawful bases are:

  1. You have provided consent to our use of your information
  2. Using your information in this way is necessary for us to perform the contract between us and to take steps at the request of you prior to entering into the contract
  3. It’s a requirement of regulatory or governing bodies – The processing is necessary to perform a task in the public interest of for official functions
  4. It’s a legal obligation
  5. It’s necessary for our legitimate interests or the legitimate interests of a third party
  6. Vital interests: the processing is necessary to protect your life.

8.3 We may contact you by email, phone, or post unless you’ve registered with the appropriate preference service or requested that we don’t. To provide you with our housing services we have a legal duty to confirm a person(s) has the right to reside in the country. We’ll need to record your name, contact details, date of birth, your current and previous countries of residence/citizenship, and a copy of identification documents (such as passport, home office residence papers and driving license)

8.4 We might also need health and social care information (such as physical, social or mental health information or medication) to help support our customers who have a vulnerability and/or receive a support or care service from us

8.5 We sometimes need to gather, use and share your personal identifiable information for particular reasons, which are set out in more detail below

8.6 What do we do with the information we collect?

1. It’ll be stored and used by us in accordance with this Privacy Notice and in accordance with your rights under the Data Protection Act 2018 and the UK General Data Protection Regulation

2. It’ll be provided to regulators or Government bodies for research and policy purposes

3. It’ll be collected and used by us fairly and openly for providing our services to you

4. It’ll allow us to provide services which are tailored to your needs

5. It’ll allow us to contact you in the most appropriate way

8.7 An understanding of your personal situation and individual needs will allow us to provide a tailored service that meets any physical, cultural or financial needs that you may have:

  1. To operate and administer our housing and support services, including managing and responding to complaints we collect, use and share contact and occupation information with third parties who help us deliver our repairs, support and housing services. For example our repairs contractors and their appointed sub-contractors
  2. We use your personal identifiable information in this way because it’s necessary to meet the conditions set out in the contract/agreement with you and/or to meet our legal or regulatory obligations
  3. To administer payments to and from your accounts or other agencies (e.g. benefits agency)
  4. Contact and occupation information with benefit agencies and financial advisors who as agencies or financial organisations help us to process payments to your account(s)
  5. To prevent financial crime including benefit fraud or illegal subletting
  6. We use your personal identifiable information in this way because it’s necessary to meet the conditions set out in the contract/agreement with you and/or to meet our legal and regulatory obligations
  7. To carry out our duties under health and safety and to support our vulnerable people
  8. Vulnerability indicators with contractors and sub-contractors to ensure services are tailored to meet your needs for example: a warning marker may be applied for a tenant with a mobility restriction, to ensure sufficient time is given for the tenant to answer the door
  9. Concerned/warning/ be aware indicators with contractors and sub-contractors to ensure health and safety measures are in place. We would have informed you of this indicator and when it’ll be applied and for how long - We use your personal and special identifiable information in this way because it’s necessary to meet the conditions set out to meet our legal and regulatory obligations in relation to health and safety
  10. To report or share information with agencies where you or another person is at risk of physical, mental, emotional, or sexual harm or damage, or where you, or another person, is in need of being protected as a vulnerable person from significant harm or serious exploitation
  11. To carry out our lettings we will consider any financial information you provide in order to offer tenancy support where necessary. We may also use any information about former debt you owe us in terms of making decisions about you
  12. Information about those you’re linked with in the proposed agreement or contract with us, for example, a joint tenant or owner
  13. We may share and receive information with and from banks, building societies, credit reference and fraud prevention agencies. The credit or fraud prevention agency might add details of our search to the records they hold about you, whether or not your engagement with us proceeds. The use of your information is based on our legal obligations
  14. To carry out market research and analysis to develop and improve our housing, support, care and products and services; provide to regulators or government agencies for research and policy purposes

9.1 We only use your personal identifiable information where it’s permitted by the laws that protect your privacy rights. This’ll be where:

  1. We need to use the information to comply with our legal obligations
  2. We need to use the information to perform a contract with you
  3. It’s fair to use the personal identifiable information either in our interests or someone else's interests, where there’s no disadvantage to you – this can include where it’s in our interests to contact you about products or services, market to you, or collaborate with others to improve our services
  4. Where we need to seek your consent (if consent is appropriate). Where we have your consent, you have the right to withdraw it. We’ll let you know how to do that at the time we gather your consent

9.2 Special protection is given to personal information that’s sensitive. This includes information about your health status, racial or ethnic origin, political views, religious or similar beliefs, sex life or sexual orientation, genetic or biometric identifiers, trade union membership or criminal convictions or allegations. We will only use this kind of personal information where one of the below applies:

  1. We have a legal obligation to do so (for example to protect vulnerable people)
  2. It’s necessary for us to do so to protect your vital interests (for example if you have a severe and immediate medical need whilst on our premises)
  3. It’s in the substantial public interest
  4. It’s necessary for the prevention or detection of crime
  5. It’s necessary for insurance purposes
  6. You have specifically given us explicit consent to use the information

10. Sharing and getting back your personal identifiable information

10.1 We share this information with:

10.2 Subsidiaries of the mhs homes Group

  1. mhs homes is made up of several related companies. We’ll share your information with other members of the Group where necessary to best provide the services to you in accordance with the contract between us. An example of this could be when we wish to let you know about a service being offered by another company in the Group that could benefit your experience with us
  2. The obligations which are set out in this notice shall apply to the other members of the Group to the same extent that they apply to us
  3. When we share information about you within the Group, we’ll tell you it’s happening and the reasons why
  4. We might share your personal information with companies who perform services on our behalf. They’ll only use this information to provide that service. We may also share it with other members of our corporate group, or a purchaser or potential purchaser of our business. If the situation occurs, we may share your personal information without your consent if the law permits it, for example to government bodies or law enforcement agencies
  5. Generally, only our staff have access to your personal information. However, in some cases we share it with third parties, such as:
  • Contractors and managing agents working on our behalf
  • Local authorities
  • Legal advisors
  • Police and fire service
  • Government departments
  • Welfare advisors
  • Medical professionals
  • Other housing associations
  • National Fraud Initiative credit agencies
  • Surveying agencies (who only act on our behalf)
  • Mail printing companies
  • Third party managing agents
  • Other third parties, provided there is a lawful basis to do so, or an exemption applies under the legislation 

10.3 We always make sure the organisations we work with understand that the information must be used for the reasons we have specified and must be kept safe and secure. Our contractors and sub-contractors are contractually required to ensure that they securely collect and store your information as set out in the Data Protection Act 2018 or the UK GDPR (as applicable)

10.4 We’ll only share information about you which is relevant and necessary to the purpose. We may share information about you without informing you that we are doing so, for example where an exemption applies such as where the information will assist a third party with their investigation about you, under the Crime and Taxation exemption.

10.5 In any other instances your personal information will not be shared with any other third parties, unless your explicit consent has been granted for example your MP to respond to a complaint. Where we share information for these reasons we’ll tell you before the information is shared.

10.6 There may be incidences where we need to share your name, address and tenancy start or end date to utility providers. We will only do so upon request from the provider if you have started a new tenancy and still haven’t signed up to their services, or have moved out of a property without paying the final bill. Our lawful basis to share this information is legitimate interest

10.7 Sometimes we might share your information with the Council to prevent you becoming homeless. We will only do this if we have a Data Sharing agreement in place. We share your data so that we can ask our partners to help you sustain your tenancy. Our lawful basis to do this is legitimate interest

10.8 All our contractors and service providers sign our Data Sharing Agreement to ensure that they are processing your data in a secure way, in compliance with the UK GDPR and that the data is not shared with other third parties unless approved by us.

10.9 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 National Fraud Initiative privacy notice - GOV.UK (www.gov.uk)

11.1 We may also be required to share your information with our regulators who are permitted access to this information by law. For example, to respond to a complaint that you’ve raised with them and with other organisations where we have a legal obligation to share the information with them

11.2 We also share your information with Government bodies for research and statistical purposes. The information helps provide the Government with a better understanding of the social housing market and help inform social housing policy. More information about how this data is used by the Government and why can be found in the Continuous Recording of Social Housing lettings and sales (CORE) notice

12. International safeguards

12.1 The information you provide us with will not be disclosed by us outside of the United Kingdom or European Economic Area, unless there are appropriate safeguards in place, including contracts and requiring any third party to adhere to those. All our contracts with suppliers state that they must seek our permission before transferring data outside of the United Kingdom. However, if we do discover that any of our suppliers aren't compliant and they're storing data outside of the UK without our permission, we'll rectify this as soon as we can

13. Accuracy of your information

13.1 We aim to keep our records up to date. However, if any of your personal details change (e.g. phone number, address), please let us know and we’ll update our records

14. Data Protection Impact Assessments

14.1 A data protection impact assessment (DPIA) is a process to help identify and minimise the data protection risks of a project.

14.2 mhs homes will complete a DPIA when implementing or making a change to a process or system that could have an impact on the privacy of individuals. A DPIA will always be completed when the process or project involves:

  • Systematic and extensive profiling with significant effects
  • Large scale use of sensitive data
  • Public monitoring
  • Innovative technology
  • Denial of service
  • Large-scale profiling
  • Biometrics
  • Genetic data
  • Data matching
  • Invisible processing
  • Tracking
  • Targeting of children or other vulnerable individuals
  • Risk of physical harm

14.3 Any new project will be tested against a DPIA screening checklist to establish whether a full DPIA is required. Where a DPIA is not required, we may choose to undertake one anyway.

15. Commitment to Refer

15.1 It is a commitment that housing association have, to refer their tenant to a local housing authority if they are homeless or threatened with homelessness, thereby supporting the aims of the Homelessness Reduction Act and particularly the Commitment to Refer.

15.2 In the course of carrying out our business (known as our ‘legitimate business interests’) MHS Homes will need to share your personal data with local housing authorities. Should any of our tenants or other people residing in our properties be threatened with becoming homeless, certain information may be shared with the local authority to assist in preventing this happening

16. How to make a complaint

16.1 As with all our services, if you aren’t happy with the way we’ve used your data, you’re entitled to make a complaint

16.2 To do this, contact the Information Commissioner's Office (ICO). You can find out how to contact the ICO on their website, or write to them at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number

17. Our Data Protection Officer

17.1 Our Data Protection Officer (DPO) is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws

17.2 If you have any concerns or questions about our use of your personal data, you can contact our DPO by writing to:

Data Protection Officer
mhs homes
Broadside
Leviathan Way
Chatham
Kent
ME4 4LL

You can also get in contact by emailing us at data.protection@mhs.org.uk

18. Having control of your personal information

18.1 The Data Protection Act and General Data Protection Regulations are in place to protect your privacy. You have many rights under the legislation, one of which is that you can ask to see the information we hold on you by filling out a ‘subject access request’

18.2 You can contact the Data Protection Officer or write to the address below if you have a request or question:

Subject Access Request,
Data Protection Officer
mhs homes
Broadside
Leviathan Way
Chatham
Kent

You can also email us with the subject heading ‘Subject Access Request’ to data.protection@mhs.org.uk

19. Can we use your information for any other purpose?

19.1 In limited circumstances we may use your information for a purpose other than those set out in this policy. If we intend to use it for another purpose, we’ll contact you before we do unless we are relying on a legal exemption which does not require us to do so (such as the Crime and Taxation exemption).

20. Deleting your information

20.1 We’ll store the personal data for as long as you remain a service user. Once you stop using our service we’ll review your information and determine whether there are any reasons why we need to keep it. For example, if a service user is in arrears when they leave the property, it may be necessary to retain information about them to recover those arrears. Once the identified purpose comes to an end we’ll delete your information by referring to the retention schedule at all times.

21. Your rights

21.1 In relation to the information which we hold about you, you are entitled to:

1. Ask us for access to the information
2. Ask us to rectify the information where it is inaccurate or is incomplete
3. Ask us to erase the information and take steps to ask others who we have shared your information with to also erase it
4. Ask us to limit what we do with your information
5. Object to our use of your information and ask us to stop that use
6. Instruct us to provide you with the information we hold about you in a structured and commonly used format or transmit that information directly to another organisation (for example, if you want the information to be sent to another housing provider)
7. Our obligations to comply with the above rights are subject to certain exemptions

21.2 We’ll share personal information with the mhs homes Group and with others outside the Group where we need to do that to make products and services available to you, market products and services to you, meet or enforce a legal obligation or where it’s fair and reasonable for us to do so

21.3 Who we share your personal information with depends on the products and services we provide to you and the purposes for which we use your personal information. For most products and services we’ll share your personal information with our own service providers such as our IT Suppliers, with credit reference agencies and fraud prevention agencies. See section 3.6 ‘How we use your personal information’ for more information on who we share your personal information with and why

21.4 Most of the time the personal information we have about you is information you’ve given to us, or gathered by us in the course of providing products and services to you. We also sometimes gather personal information from and send personal information to third parties where necessary for credit checking and fraud prevention or marketing purposes, for example so you can receive the best offers from us and our partners

22. Transfers outside of the UK

22.1 We do not transfer our data outside of the EU, UK, EEA, or a country with ‘adequacy’ status. If our suppliers wish to process data outside of these areas they must seek our permission

22.2 If data were to be transferred outside of these areas, appropriate safeguards will be applied.

22.3 You can find out more information about standard contractual clauses as detailed by the ICO. Visit their website and search for ‘International transfers’

23. How long we keep your personal information for

23.1 This depends on the services we deliver to you. We’ll never retain your personal information for any longer than is necessary for the purposes for which we need to use it

23.2 We have a Corporate Retention Schedule in place which outlines how long we keep different types of information. This is in line with the law, guidance. and best practice.

23.3 At the end of the defined retention period, we will delete your data.

24. Keeping you up to date

24.1 We’ll communicate with you about products and services we’re delivering using any contact details you have given us - for example by post, email, text message, social media, and notifications on our app or website

24.2 Where you’ve given us consent to receive marketing, you can withdraw consent, and update your marketing preferences by contacting us directly

25. Direct marketing

25.1 We’d like to provide you with updates about events, services and other information that we believe may be of interest to you in relation to the services we offer. We may send you such information by post or telephone unless you have registered with the appropriate Preference Service or have asked us not to do so

25.2 We don’t provide your personal information to other companies for their marketing purposes

25.3 If at any time you don’t want your information used for direct marketing purposes, please contact us by email

26. Email marketing

26.1 We’d also like to provide you with some information by email. However, we appreciate that email 'spam' is a problem. If you’ve registered with us or have previously asked us for information on our services via email, we may use that email address to contact you. However, not all the information we’ll provide to you will necessarily be sent by email

26.2 You can change your preferences on receiving emails from us at any time by emailing us

27. Your online activities

27.1 When you use our online services, your information may be collected via our Live chat records, your IP address, Cookie information and the website address from which you accessed our website

Find out more about cookies by reading o cookie policy

28.1 We’re committed to protecting your data. We’ll ensure your data is:

1. Fairly and lawfully processed
2. Processed for limited purposes
3. Adequate, relevant and not excessive
4. Accurate
5. Not kept longer than necessary
6. Processed in line with your rights
7. Safe and secure
8. Not transferred to countries without sufficient protection

28.2 For more information please see:

28.3 We’re committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we’ve put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect

28.4 Only relevant members of staff will access the information you provide to us

29. Phishing

29.1 'Phishing' is the name given to attempts to steal personal details and financial account details from a website user. 'Phishers' use fake or 'spoof' emails to lead users to imitation websites where the user is tricked into entering their personal details, such as credit card numbers, usernames and passwords. mhs homes will never send emails asking you for such details and our staff will never ask you for your password

29.2 If you do receive such an email or are asked for your password by anyone claiming to represent mhs homes, please forward the email or report the incident by emailing us at data.protection@mhs.org.uk

Equality statement

mhs homes has a duty to ensure that no one receives less favourable treatment from the organisation on the grounds of age, disability, gender reassignment, marriage, civil partnership, pregnancy, religion or belief, race, sex or sexual orientation.

Data protection

mhs homes will only share information that meets the requirements of the Data Protection Legislation. Confidentiality and impartiality will be exercised at all times.

Feedback

We welcome suggestions and comments from people who use or provide our services. We believe that this can provide some important lessons to help us ensure that the service is improved for everyone.