Privacy policy and cookies

1.Introduction

To operate as a housing business, RHP Group (which includes Co-op Homes (South) Ltd) must get, process and store personal information about our applicants for housing, tenants and customers. This Privacy Policy supports our Privacy Notice. It explains how RHP Group treats your personal details.

2. What is personal information?

Personal information is information that relates to a living individual (data subject) that allows them to be identified. Personal data includes contact information about:

contact details and preferences
finances
education and employment
safety and security

Certain types of personal information is categorised as 'sensitive". They might relate to

racial or ethnic origin
political opinions
religious or philosophical beliefs
membership of a trade union
genetic or biometric data
health
sexual preference.

We usually only collect personal data so we can provide housing and management services, provide regulatory and legal returns and otherwise comply with our legal obligations (see Section 6 "How will we use your information?"

3. What information does RHP Group collect?

When you contact us you might need to provide:

your name, address and contact details. These will only be used, as necessary, within the RHP Group, or by our suppliers and partners
your age, sex, date of birth, ethnicity, whether you have a disability and any other needs or preferences.

We may also get your personal details from organisations you've dealt with in the past like councils and past landlords, We use this information so we can understand our customers and their needs better.

When we provide you with a housing service, we might gather information on :

your housing needs, so we can find a property that suits your
bank accounts and direct debit information so you can make payments to us such as rent or service charges (we only exchange the details with the account holder and don't store any card details)
benefit and council tax information
voice and video recordings for safety and crime reduction
support you're receiving from another organisation (for example, a council's social services team

You might also provide us with other information when you chat to us or our contractors.

We might gather the following information to improve our service:

details of any friends, relatives, neighbours or carers you trust to contact us on your behalf
your name and contact details for customer satisfaction surveys, newsletters and service information
your name, photo, video or story for brochures, press releases or advertising for use by the media (but only with your explicit consent)
information about complaints about our service. We keep this separate from other information about you
accidents or incidents involving you or your home.

If you ask for additional services from us:

we'll hold detailed information about yours and your families needs
we'll hold records of payments for the services
we'll hold detailed information about your income and debts if you contact us about money issues. We'll keep this separate from our other information about you.

If we need it to look after our employees, business or anyone else, we may hold information about your history, e.g. regarding credit, or offences.

We'll only request personal data that's relevant for delivering our services and meeting our legal obligations. If you feel any requests are inappropriate you can refuse, but this might mean that we're unable to carry out requested or essential work, like repairs. We may also obtain your personal details from organisations you have dealt with in the past, such as referral agencies, councils and past landlords.

4. Controlling your personal data

Here's how we're committed to ensuring that your privacy is protected:

We'll process (collect, store and use) the information you provide in a way that meets the relevant data protection legislation.
We'll do our best to keep your information accurate and up to date and not keep it for longer than we need to. Sometimes the law sets the time information has to be kept, but in most cases we'll follow housing sector regulation and legal guidelines to make sure we're not keeping information for longer than we need.
We don't want to be intrusive, so we won't irrelevant or unnecessary questions. We won't use the information you give us inappropriately.
We won't sell, distribute or lease your personal data to third parties unless we are required by law to do so or to deliver our services. We may use your personal data to send you promotional information about third parties which is related to your tenancy or that we think you interesting. We will only do this with your consent.
If you've previously agreed to us using your personal data for direct marketing purposes, you can may change your mind at any time by writing to or emailing services@rhp.org.uk or homes@coophomes.coop
If you believe any information we hold on you is incorrect or incomplete, email customer.services@rhp.org.uk or homes@coophomes.coop and we'll put it right
We gather and analyse personal data, but we don't draw any conclusions from it. This is called "profiling" and its covered later.

5. Where do we store your personal data

We're committed to storing your personal data securely. This means only Co-op Homes employees and contractors that need to see it can. We'll always it electronically if possible - but sometimes we'll need to keep a paper copy.

Our computer systems are secure and protected. Sometimes we also use computers which are owned or managed by our suppliers. Their computers will always be secure and protected too. Where we share your information with others in line with the legislation we will make sure that those third parties also have relevant security systems in place to make sure that your information is kept safely.

6. How will you use my information?

We'll only use your data where we have a legal reason to do so.

For example:

a lot of the information we collect about you will be so that we can proces your housing application and manage your tenancy with us, to ensure we are both complying with the terms of that agreement
some information is used to provide you with additional support outside of the terms of your tenancy agreement, and is in the legitimate interests of RHP Group and you to use the information in this way to provide you with housing information and information about other support and services available.
we have legal and regulatory obligations to collect certain information and we sometimes need information to defend or pursue legal claims.
there may be times where we need your consent to your information in certain ways, for example, if you want to agree to us sending your promotional material. You don't have to give us your consent but refusing to give your consent may mean that we can't carry our work for you or provide you with specific services. This will be explained to you at the relevant time.

Information collected about you is used to:

process your housing application
maintain our records and provide a quality housing service
contact you about your rent account
manage and enforce your tenancy conditions
carry out repairs and maintenance work to your home
support to help you live independently
support any claims you make for benefits or grants
help improve and shape our service
to provide you with general housing information
to provide management services
allow us to meet our legal and regulatory obligations.
conduct surveys and provide statistics on tenant and household profiles when the Social Housing Regulator or other agencies appointed by the government ask for them
prevent, detect and investigate crime using Closed Circuit Television (CCTV)
carry out data matching. This is when we compare computer records to help us identify fraudulent claims and payments.

If we need to use your personal data for any reason we'll always make sure that its in line with the law. For example, we may need to use your information if a crime's been committed or there are risks to the public or our employees, we might also have a legal duty to use your data in a certain way, for example though a court order.

7. How long do you keep my information for?

We generally hold information contained in your tenancy file for 6 years after your tenancy ends. In some circumstances we may be required to hold some information for longer in order to comply with our legal obligations or to protect you or your interests, for example to defend or pursue legal claims.

If you would like further information on specific period please contact us.

Our employees are trained to handle your information correctly and protect your privacy. We aim to maintain high standards, adopt best practice for our record keeping and regularly check and report on how we are doing. Your information is never collected for direct marketing purposes, nor sold on to any third parties and not processed overseas. Sometimes RHP Group’s services may be provided by our business partners, in which case appropriate members of their staff will have access to your information in order to deliver these services to you.

8. Who has access to my information?

Only employee are trained to handle your information properly and protect your privacy. Only RHP Group employees who have an operational need to see your data will be allowed to see it. We aim to maintain high standards, adopt best practice for record keeping and regularly check and report on how we're doing. Your information is never sold on to their parties or processed overseas.

Where appropriate, we may need to pass your personal data on to our service providers and contractors, for example those who:

undertake repairs and maintenance services so that we can meet our obligations under the terms of your tenancy;
assist us with collecting and processing rent payments by car or direct debit and collect rent arrears'
provide us with facilities and support for our CCTV operations, where this is in operation;
help us to carry out market research or customer survey call

Where we work closely with these contractors they must store your details securely, and use them only to undertake the work we have asked them to do. When the job is done they will securely dispose of the details in line with RHP Group’s procedures and relevant data protection legislation.

We also work closely with partners to help us provide you with services and support and may need to pass on your personal data to those organisations. For example:

Housing Benefit departments and government benefits offices. e.g. to help process a customer's Housing Benefit claim.
Local authorities and the police, for example including responding to a council enquiry on behalf of a customer, supporting the council with disabled adaptations to a customer's home or asking the police for information about a crime report that affects a RHP Group or co-op property.
Utility companies (electricity, water, gas), e.g. to confirm a customer has moved out of a property.
Our insurance company - to ensure that they are aware of any relevant accidents or incidents and our policy is kept up to date.

We will ensure that when we're sharing your information, its appropriate, relevant and in line with the legislation. We have data-sharing agreements with a number of other organisations. They sign up to a code of how data will be exchanged and used.

In some circumstances, we need to share information in an emergency or because we have a legal or regulatory obligation to do so. For example:

for the prevention or detection of crime and fraud
in connection with legal proceedings
in relation to someone's physical or mental health, to protect them or others from serious harm
for making a safeguarding alert where there's a concern about a child or vulnerable adult's safety
for research and statistical purposes - for example, for government research on who we let homes to
to protect the health and safety of our employees
to comply with the law.

From time to time we'll use credit agencies to make sure our records are up to date. We'll also use them for the prevention, detection and prosecution of crime, including social housing fraud and benefit fraud. This information won't be used for any inappropriate purposes.

9. Profiling

Profiling is automated processing that's designed to evaluate an individual and analyse or predict characteristics such as:

economic situation
health
personal preferences
reliability
behaviour
location
movements.

We don't use profiling at RHP Group.

10. Website information

Effective as of 8th April 2022

Use of cookies

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A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting. More specifically, we use cookies and other tracking technologies for the following purposes:

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you, which amount to a request for services, such as logging in or filling in forms. They protect your data from being accessed in an unauthorised way.

Cookie Name	Cookies Purpose	Cookie type and duration
OptanonConsent	This cookie is set by the cookie compliance solution from OneTrust. It stores information about the categories of cookies the site uses and whether visitors have given or withdrawn consent for the use of each category. This enables site owners to prevent cookies in each category from being set in the users browser, when consent is not given. The cookie has a normal lifespan of one year, so that returning visitors to the site will have their preferences remembered. It contains no information that can identify the site visitor.	First-party persistent cookie, 365 days
OptanonAlertBoxClosed	This cookie is set by the cookie compliance solution from OneTrust It is set after visitors have seen a cookie information notice and in some cases only when they actively close the notice down. It enables the website not to show the message more than once to a user. The cookie has a one year lifespan and contains no personal information.	First-party persistent cookie, 365 days
ASP.NET_SessionId	General purpose platform session cookie, used by sites written with Miscrosoft .NET based technologies. Usually used to maintain an anonymised user session by the server.	First-party session cookie deleted after you quit your browser
yourAuthCookie	This is a cookie that is used as part of the login process to control access to content within the members area. and is removed on closing the browser.	First-party session cookie deleted after you quit your browser
__RequestVerificationToken	This is an anti-forgery cookie set by web applications built using ASP.NET MVC technologies. It is designed to stop unauthorised posting of content to a website, known as Cross-Site Request Forgery. It holds no information about the user and is destroyed on closing the browser.	First-party session cookie deleted after you quit your browser

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous.

Cookie Name	Cookies Purpose	Cookie type and duration
__utmz	This is one of the four main cookies set by the Google Analytics service which enables website owners to track visitor behaviour measure of site performance. This cookie identifies the source of traffic to the site - so Google Analytics can tell site owners where visitors came from when arriving on the site. The cookie has a life span of 6 months and is updated every time data is sent to Google Analytics.	First-party persistent cookie, 182 days
_utmv#########	Used to store visitor-level custom variable data. This cookie is created when a developer uses the _setCustomVar method with a visitor level custom variable. This cookie was also used for the deprecated _setVar method. The cookie is updated every time data is sent to Google Analytics.	First-party persistent cookie, Less than day
__utmt	This cookie is set by Google Analytics. According to their documentation it is used to throttle the request rate for the service - limiting the collection of data on high traffic sites. It expires after 10 minutes	First-party persistent cookie, Less than day
__utmb	This is one of the four main cookies set by the Google Analytics service which enables website owners to track visitor behaviour and measure site performance. This cookie determines new sessions and visits and expires after 30 minutes. The cookie is updated every time data is sent to Google Analytics. Any activity by a user within the 30 minute life span will count as a single visit, even if the user leaves and then returns to the site. A return after 30 minutes will count as a new visit, but a returning visitor.	First-party persistent cookie, Less than day
__utmc	This is one of the four main cookies set by the Google Analytics service which enables website owners to track visitor behaviour and measure site performance. It is not used in most sites but is set to enable interoperability with the older version of Google Analytics code known as Urchin. In this older versions this was used in combination with the __utmb cookie to identify new sessions/visits for returning visitors. When used by Google Analytics this is always a Session cookie which is destroyed when the user closes their browser. Where it is seen as a Persistent cookie it is therefore likely to be a different technology setting the cookie.	First-party session cookie deleted after you quit your browser
__utma	This is one of the four main cookies set by the Google Analytics service which enables website owners to track visitor behaviour and measure site performance. This cookie lasts for 2 years by default and distinguishes between users and sessions. It it used to calculate new and returning visitor statistics. The cookie is updated every time data is sent to Google Analytics. The lifespan of the cookie can be customised by website owners.	First-party persistent cookie, 729 days

Functional Cookies

These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Cookie Name	Cookies Purpose	Cookie type and duration
vuid	This domain is owned by Vimeo. The main business activity is: Video Hosting/Sharing	Third Party persistent cookie, 729 days

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Some of the information collected at this time of submission includes:

All cookies placed by Google over the last 6 months,

How many mouse clicks you've made on the screen (or touches if on a touch device),

The CSS information for that page,

The date,

The language your browser is set to,

Any plug-ins you have installed on the browser, and all Javascript objects

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11. Your Rights

Data Protection law gives you the following rights:

The right of access to see the information we hold on you. To request this please contact customer.services@rhp.org.uk or homes@coophomes.coop. There is no charge for this service and we have one month to provide you with this information unless it interferes with other people rights and freedoms or requests are repetitive, manifestly excessive or unfounded.
The right for your information to be rectified it is inaccurate or incomplete.
The right to ask for erasure (right to be forgotten) where we no longer need to continue processing your information.
To right to ask for restriction of processing your information
The right to data portability – where processing is automated, based on consent and not in the public interest or necessary "in the exercise of official authority", you have the right to obtain your data from us in a commonly used, machine readable format.
To right to object to how your information is used if we are not using it for legitimate business interests.
If you have provided us with your consent for us to use your information in a certain way, you will always be able to withdraw that consent by contact us. This might affect the services we can provide, but we will explain the consequences to you.

12. Contacting us and complaints

If you have any questions about how your information is used or want to let us know your information has changed please customer.services@rhp.org.uk or homes@coophomes.coop. If you want to see your information, or if you believe that it is not accurate, or if you want to make a complaint about the use of your information then contact:

The Data Protection Officer, RHP Group, 8 Waldegrave Road, Teddington, TW11 8GT email: customer.services@rhp.org.uk

If you're not happy with the way we deal with your query or complaint you can contact: The Information Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Tel: 0303 123 1113; Fax: 01625 524 510; Email: casework@ico.org.uk ; Website: https://ico.org.uk/