1.1 Under the Data Protection Act 2018 and the General Data Protection Regulation, we are required to explain to you why we are asking for this information about you, how we intend to use the information you provide and whether we will share this with anyone else.
2.1 We are Sanctuary Supported Living, a trading name of Sanctuary Housing Association and Sanctuary Affordable Housing Limited both a part of Sanctuary Group (“Sanctuary”), one of the UK's leading providers of housing, care and commercial services. Our address is Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ.
3.1 Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
3.2 If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing firstname.lastname@example.org.
4.1 At application stage, we will use the information provided to us to assess the suitability of our service for you, understand your needs and prioritise your application.
4.1.1 The information that is used at application stage is the information provided to us in a referral from your local authority.
4.2 Should you become a client of ours, we will use the information provided to us to support you in managing your tenancy
4.2.1 The information that is used should you become a client of ours is the information provided during the application stage and information provided during on-going:
4.2.2 In order to support you in managing your tenancy, your support provider will also provide us with information about any major changes in your support needs. When they do this, it is because you have provided your explicit consent for them to share your information with us.
5.1 At application stage, we collect the following information that is provided to us:
5.2 Should you become a client of ours, we will use the information provided during your application in order to provide you with our services. We will also collect the following information to support you in managing your tenancy:
5.3 We have CCTV in operation at some of our locations; if there is CCTV in operation, there will be signs clearly visible to indicate that this type of recording is taking place. CCTV is only used in public areas.
6.1 Your information will be stored and used by us in accordance with this privacy statement and also in accordance with your rights under the Data Protection Act 1998 and the General Data Protection Regulation.
6.2 At application stage, the information provided to us will be used for the following purposes:
6.2.1 it will be collected and used by us fairly and openly for the purpose of assessing your suitability for our housing and prioritising your application;
6.2.2 It will allow us to ensure that our services are fair and accessible to all; and
6.3 Should you become a client of ours, the information provided to us will be used for the following purposes:
6.3.1 it will be collected and used by us fairly and openly to support you in managing your tenancy with us; and
6.3.2 understanding your personal situation and individual needs will allow us to provide a tailored service that meets any cultural, financial, learning, mental or physical needs that you may have and will be used to improve the services you receive from us.
7.1 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 bases for processing personal data which are set out in the data protection laws.
7.2 The lawful bases on which we rely in order to use the information which we collect about you at application stage and should you become a client of ours are:
7.2.1 using your information in this way is necessary for us to take steps to perform the contracts between us, and in order to take steps at the request of you prior to entering into the contract;
7.2.2 you have provided explicit consent to our use of your information. There is a limited amount of special category information that we will use on the basis of your consent. We will inform you prior to collecting or processing your information based on consent and keep a record of your consent.
7.2.3 using your information is necessary for us to comply with a legal obligation to which we are subject; and
7.2.4 it is necessary to use that information to protect someone’s vital interests (which will usually be a ‘life or death’ situation).
8.1 Sanctuary Group is made up of a number of related companies. We will share your information with other members of Sanctuary Group where necessary in order to best provide the services to you in accordance with the contract between us.
8.2 Your information will only be accessed by other companies in the Group where it is necessary to do so in order to provide services to you in accordance with our contract. 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.
8.3 For more information on which companies make up Sanctuary Group, please go to www.sanctuary-group.co.uk/about-us.
8.4 It may be necessary to share information about you with our contractors and sub-contractors in order to provide you with the services in accordance with the contract between us. We will only share information about you with the contractors and sub-contractors which is relevant and necessary to address your individual needs. The contractors and sub-contractors shall be contractually required to ensure that they adhere to the security requirements imposed by the Data Protection Act 1998 and / or the General Data Protection Regulation (as applicable).
8.5 Our contractors and sub-contractors will not share your information with any other parties and will only be able to use the information when completing work on behalf of us.
8.6 We may also be required to share your information with our regulators who are permitted access to this information by law and with other organisations where we have a legal obligation to share the information with them, for example, the Regulator of Social Housing.
8.7 We may from time to time share your information with other organisations, such as:
8.7.1 utility companies so they can provide services to you and contact you in respect of utility charges, if you are a resident of a Sanctuary property;
8.7.2 the police for the purpose of detection and prevention of crime;
8.7.3 organisations with a function of auditing and/ or administering public funds for the purpose of detection and prevention of fraud; and
8.7.4 local authority teams such as: social services about any safeguarding concerns we may have, environmental health, council tax departments and benefit agencies.
9.1 We will not transfer the information you provide to us outside of the European Economic Area.
10.1 The information that you provide will be uploaded, stored securely on our systems and the form that you complete will be shredded. Our security measures and procedures reflect the seriousness with which we approach security and the value we attach to your information.
10.2 Only relevant members of staff will access the information you provide to us.
11.1 In limited circumstances, we may use your information for a purpose other than those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.
12.1 We will hold your information securely during the period of our relationship and for a set period afterwards in line with legal requirements, best practice and any follow up that may be necessary.
12.2 At application stage, if you decide not to take your application any further, we will hold your personal information for 6 months after your last contact with us.
12.3 Should you become a client of ours, we will hold the information collected at application stage and while you are a client during the period of our relationship and for set periods of time afterwards. For example, we will retain your tenancy records for six years after your tenancy end date, in-line with the Limitation Act 1980.
12.3.1 The exact periods that we hold your information for will depend on the type of information, as set out in our Group retention schedule.
12.4 Once the relevant set period set out in our retention schedule has come to an end, unless there is another identifiable reason for which it necessary to hold on to your information, we will delete your information.
13.1 In relation to the information which we hold about you, you are entitled to:
13.1.1 ask us for access to the information;
13.1.2 ask us to rectify the information where it is inaccurate or is incomplete;
13.1.3 ask us to erase the information that is used on the basis of your consent and take steps to ask others who we have shared your information with to also erase it;
13.1.4 ask us to limit what we do with your information;
13.1.5 object to our use of your information and ask us to stop that use; and
13.1.6 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 or support provider).
13.2 Our obligations to comply with the above rights are subject to certain exemptions.
13.3 Where we are using your information because you have provided your consent to that use, you are entitled to withdraw your consent at any time. The lawfulness of our use of your information before consent was withdrawn is not affected.
13.4 To exercise any of the rights referred to above, you should contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing email@example.com.
13.5 You also have the right to complain to the Information Commissioner's Office (the "ICO") if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.