Privacy Policy

In this Part we list out the different categories of your information, briefly explain them where needed, explain what we do with the information and why, as well as specifying the relevant legal gateway we rely on to do so.

We use the word “handle” to cover collecting, compiling, using or storing this information.

Identity and contact details

1. This includes name, contact details, date of birth and national insurance number

2. We handle this information in order to enter into the tenancy agreement and subsequently to manage the tenancy and the property. This is done to perform the contract.

Personal and background information

1. This includes details of the tenant’s present residence and their current landlord (if any), current occupation and status, employed, student etc., employer or educational institution, state benefits received, details of other residents, any bankruptcy or county court judgments, next of kin etc., pets and any photographs of yourself.

2. This information is handled to evaluate your suitability as a tenant. This is done for our own legitimate interests. These are to ensure that any let is to reliable tenants and residents with suitable guarantors where applicable.

3. We also handle this information which relates to next of kin etc., to contact them in the event of an emergency. This is to protect your vital interests.

4. This information will also be handled if we need to trace you to contact you in connection with the tenancy or the property or to pursue a claim against you, e.g. for rent arrears. This is in our own legitimate interests. These are to enforce your obligations, deal with property left behind at the property or to recover property.

Bank details

1. This includes details of your bank, building society or other paying organisation, including those operating digitally/online.

2. We handle this information in order to receive payments from you or on occasion to make payments to you. This is done to perform our contract.

3. We also handle this information if we seek to make recovery from you of unpaid debt. This is in our own legitimate interests. These are to recover what is due to us.

4. We also handle this information as part of our verification of your suitability as a tenant, including to protect against money laundering. This is in our own legitimate interests to ensure that we let to suitable tenants/residents and do not receive proceeds of crime.

Tenancy details

1. This includes renewals of the tenancy. Information within this category includes the address of the property, start date for the tenancy, period of occupancy, rent and other payments.

2. We handle this information to prepare and complete the tenancy agreement and then to manage the tenancy and the property. This is done to perform our contract.

3. Tenancies are renewed by agreement. This will involve a request from you. We handle information about the renewal of tenancies. This is done for contractual performance.

4. Where you are a joint tenant or there are residents living with you details of any other joint tenant or resident are linked with the tenancy/property.

5. We handle this information to prepare and complete the tenancy agreement and thereafter to manage the tenancy and the property. This is done so that we can form a contract.

6. Where there is a guarantee, e.g. from a parent, we collect information about the identity and contact details of the guarantor, background information about the guarantor and details of property owned. This is then linked to your tenancy and the property.

7. We handle this information to protect our own legitimate interests. This is to provide security for the payment of the rent and to ensure compliance with tenancy obligations.

Deposits (if any)

1. This includes the amount of a deposit, who pays it and in what shares and the steps taken to protect the deposit.

2. We handle this information to deal with the deposit received and to administer the deposit. This includes handling information about persons who contribute towards the deposit who are not a tenant. This is done both for contractual performance and to ensure compliance with legal obligations relating to handling deposits under the Deposit Protection Legislation. This is to secure payment of the rent and compliance with tenancy obligations.

3. We also handle deposits at tenancy termination and this is dealt with under that section.

Immigration/right to rent checks (England only)/verifying tenant’s identity

1. Under immigration legislation we check that each tenant and adult resident in the property has the right to rent. This includes retaining copies of passports, driving licences and other specified documentation. We must retain this for inspection if required by the Home Office.

2. We handle this information in accordance with the requirements of immigration legislation in order to carry out our legal obligations.

3. We also handle this information in order to verify the identity of tenants and residents along with guarantors in order to protect our legitimate interests. These are to ensure that we are dealing with the correct person. This is done in Wales as well as in England for this purpose.

Rent and payment collection

1. This includes records we compile to record receipt of rent and other payments from you and associated documentation relating to such payments. This also includes any documentation where we need to issue reminders for payment, including levying charges for interest or fees for late payment.

2. We keep this information in order to compile correct and up to date records. This is done for contract performance.

Recovery of arrears, claims and possession proceedings

1. In the event of non-payment of rent or other payments due, or if there is non-performance of the contract (including allegations against ourselves) then we record this and enter into relevant communications. This includes information and documentation related to any proceedings which may be commenced or brought against us in relation to these matters, including proceedings to recover possession of the property.

2. We handle this information in order to pursue recovery of what is owing to us and to enforce our rights, to defend claims, and to recover possession of the property. This is done in our own legitimate interests. These are to protect our property interests, to enforce our rights and to ensure payment due to us is made, as well as to defend any claims brought against us.

Repairs/housing standards/health and safety

1. This includes condition surveys, inspection reports, reports of repairs required and information about actions taken. This extends to conditions and standards generally at the property including health and safety, e.g. gas safety.

2. We handle this information to ensure that the property and its contents are properly maintained. This is done both for the purposes of contractual performance and, where applicable, to comply with our legal obligations.

Breach of tenancy agreement/nuisance etc.

1. This includes complaints which we receive or information which we hold relating to alleged breaches by a tenant or resident (which could include a child) including nuisance and anti social behaviour. This includes records and related communications. This includes complaints about these matters made by neighbours or other tenants or residents.

2. We handle this information so as to ensure that tenancy obligations are complied with and that tenants and residents live harmoniously with neighbours. This is to protect our own legitimate interests and the legitimate interests of affected third parties. These legitimate interests are ensuring the tenancy obligations are complied with as well as the prevention and detection of crime and anti-social behaviour.

3. We also handle this information under a legal obligation where there is a selective licensing area in force or where the property is a licensed house in multiple occupation (HMO) or under the licensing scheme operating in Wales.

Council Tax liability

1. Notification is given to the local authority in relation to tenant/resident liability for Council Tax. This can include information about the period of occupancy as well as former and subsequent addresses.

2. We handle this information in order to ensure that the liability for Council Tax is dealt with correctly. This is done to protect our own legitimate interests and those of the local authority. These are for the correct billing and collection of Council Tax and to ensure that we do not have to meet Council Tax liability ourselves where this is not appropriate.

3. In the event of the local authority serving a statutory notice we then we must supply this information to comply with our legal obligations.

4. Where appropriate the tenant may be entitled to a reduction in Council Tax (formerly called Council Tax benefit). Information is handled relevant to claims made by tenants. This is in the interests of the local authority administering the scheme to see that benefits are properly calculated and paid.

Water charge payments

1. This relates to notification to a water company of the tenants/residents who are living at the property their periods of occupancy and it can include previous and subsequent addresses. It also relates to communications between ourselves and the water company concerned.

2. In the area covered by Welsh Water this information is handled pursuant to a legal obligation.

3. Outside the Welsh Water area we handle this information to establish liability for water charges in our own legitimate interests and those of the water company concerned. This is to ensure that legal liability for payment of water charges is correctly established and discharged.

Utilities and other service providers

1. We arrange and establish liability for payment of gas and electricity consumed at the property and any services which are provided, e.g. Broadband or cable tv. These services may be provided as a requirement under the tenancy agreement. It includes communications about changes of tenants, interruptions and disconnection of supply and work to be carried out in connection with utilities and services such as the installation of smart meters/replacement meters.

2. We handle this information in order to arrange provision of utilities and services and ensure that the correct liability for relevant charges is established and that these are paid for. This is done in our own legitimate interests and those of the utility company/provider concerned. These are to ensure utilities and services are provided and that liabilities are paid.

3. We also handle this information in order to deal with breakdowns, interruptions and disconnections and to ensure that the appropriate quality of service is provided. This is done in our own legitimate interests. These are to ensure that requisite utilities and services are available and are provided at the property.

Universal Credit/Housing Benefit/Local Housing Allowances

1. Where eligible a tenant will be entitled to the appropriate welfare benefits to assist them to pay rent. Information may be required by the Department for Work and Pensions (DWP) or local authority to verify entitlement. Normally, payment of benefit is made direct to the tenant; however, if the tenant is vulnerable or there are arrears, payment of benefit can be made direct to us. This extends to Council Tax reductions (the old Council Tax benefit).

2. We handle tenancy details and rent payment records, including information about arrears of rent, and the tenant’s personal circumstances, relevant to the processing of claims and the administration of benefits. This is done for contractual performance. It is also carried out in our own legitimate interests to secure payment of rent due to us.

3. We handle information relevant to applications for benefit and in particular applications for direct payment to ourselves including reasons for non-payment of rent. This is for contractual performance.

4. On occasion where direct payment has been made to us there may be claims by the benefit authority for recovery of overpayments. We handle information relevant to such claims. This is done for our own legitimate interests. These are to ensure that we can collect and retain rent due to us.

Tenancy termination

1. A tenancy may run out and the tenant leaves. Tenants can leave early while the tenancy is still running on. We may serve notice requiring the tenant to vacate and, if need be, enforce this by court possession proceedings.

2. Tenancy terminations of whatever kind also involve the return of any deposit paid, possible claims against guarantors, claims on rent insurance or property insurance, arrangements for tenants/residents to vacate the property, tenants/resident’s property being left behind. They also give rise to issues around the state and condition in which the property has been left, e.g. cleanliness.

3. We handle information relevant to these matters concerning tenancy termination. This is done in our own legitimate interests. These are to ensure that the property is returned to us in a proper state with vacant possession and that all appropriate financial claims by either party against the other are correctly dealt with. These include our obligations in relation to the refund of deposits, to comply with our contractual obligations between us and the tenancy deposit scheme with whom the deposit is protected.

Complaints

1. We operate a complaints procedure which may be informal. Although we will do all we can unfortunately sometimes things go wrong so complaints may arise.

2. Information handled concerns complaints which you may make or which may be made on your behalf. These will give rise to communications and records being compiled by us.

3. We handle complaints with a view to resolving these, although this might involve external intervention, e.g. by the courts.

4. We handle complaints for contract performance. This is also done in our own legitimate interests. These are to protect ourselves against claims and to ensure that the complaints are properly resolved.

Health/disability

1. Importantly, this is sensitive personal information to which additional protections apply. We may be given information about your health (whether mental or physical) or disabilities.

2. Health information may be given to us to explain your absence from the property or as a reason why rent has not been paid. You may wish us to have information about your health so that we are aware of how you may need assistance on occasion. This could also be information about health or disabilities affecting someone else which impacts on you.

3. We may be given information about your disabilities so that we can make particular arrangements for you, including any adaptations which may be required to make under disability discrimination legislation.

4. We handle information about your health or disability, and the health of others depending upon the circumstances to assist us in the management of the tenancy and the property. This may be to protect your vital interests. It may alternatively be for contractual performance where it affects your ability to perform your contractual obligations under the tenancy agreement. It will be in our own legitimate interests if we are told of any medical condition which affects you. This is so we are aware of possible impacts on you.

5. In regards to information concerning any disability, we handle this information to assist in the management of the tenancy and the property. This may also be under a legal obligation where we are obliged by law to make provision to deal with your disability.

6. In addition, as this is special category data, additional legal requirements are imposed upon us about your health and/or disability and we may request your consent to handle this information.

CCTV and Audio

1. If we operate cctv you will be given information about this. We may operate cctv to cover common parts or the exterior of the premises.

2. We may also hold audio recordings, e.g. messages from you on telephone answering machine or mobile phone.

3. Where cctv is operated this is for the safety and security of the premises in question and for the prevention and detection of crime and anti social behaviour, as well as monitoring tenancy obligations. This is done in our own legitimate interests. These include the protection of our property and ensuring compliance with tenancy obligations as well as the safety and security of tenants, residents and neighbours.

4. We handle audio recordings to assist with accurate record keeping. This is done for contract performance or in our own legitimate interests. These are to ensure that we have reliable records of communications.

Correspondence etc

1. Correspondence includes all ways in which we receive communications from whatever source. This includes emails, text messages, social messaging and messages, letters and documentation. This can include photographs and other visual recordings.

2. We handle these communications initially relating to entering into the tenancy agreement and then for the management of the tenancy and the property, as well as associated matters arising under the various categories of information referred to in this Table. This is done for contractual performance where applicable, to carry out any applicable legal obligations imposed on us, to protect your vital interests, or in our legitimate interests. These legitimate interests are to ensure that we have the necessary information relating to these matters and for accurate record keeping.

Websites and online platforms

1. Information about you is available in the public domain, often put there by you. This can be accessed by appropriate searches which allow for access to the websites which hold this information.

2. Information about you is also made available when you access online platforms, e.g. to enquire about properties which are available for renting.

3. We handle this information to assess your suitability for tenancies/residency and for the management of the tenancy and the property. This is in our own legitimate interests to ensure that tenants/residents are suitable and that the tenancy and the property are effectively managed. This can include ensuring that tenancy obligations are performed. These legitimate interests are to ensure that our property interests are protected and our rights are enforced.

4. We handle information received via our online platforms for contract performance, including arranging lettings and entering into tenancy agreements.

Insurance

1. We insure the buildings and may insure contents belonging to us. We may also insure against public liability, including liability to yourself for injuries and rental insurance, in the event of rent arrears or other tenancy default.

2. We handle information about you which may be relevant to our insurances to arrange cover, to administer insurance contracts, to renew insurances and to make claims. Contractually we are under certain duties, e.g. to disclose information to the insurers. We handle this information to protect our legitimate interests. These are to ensure that appropriate risks are adequately insured against and to recover any sums due to us under the policy as a result of claims.

3. It is your responsibility to insure your own contents/belongings. You may seek information from us relevant to arranging such insurance or making claims. We handle this information and will do so with your consent which is provided as part of your request for any assistance or information.

Flat management

1. This applies in particular where the property is a flat. This flat will be held by us under a lease or subject to other contractual arrangements which will set out various responsibilities for the upkeep, insurance etc., of the block including common areas. The lease or other arrangements place contractual obligations on us which in turn may be passed on to you under the terms of the tenancy.

2. We handle information about you in order to carry out our responsibilities under these leases/arrangements. This is done in our own legitimate interests and in the interests of the freeholder etc., of the block so as to ensure that respective obligations are properly performed.

Car registration

1. We hold records of car registrations for vehicles which you keep at or in the vicinity of the property.

2. We handle this information to manage the property for contract performance.

We also handle this information in our own legitimate interests and those of others such as neighbours in order to monitor and regulate parking. This is to protect our own property interests and rights and those of others such as neighbours who may be affected by parking issues