PRIVACY POLICY

What personal data we process

Our purpose for doing so

Our lawful justification

Contact details, details about your home, household and your housing needs and tenancy agreement.

Allocating homes, managing our services, providing repairs.

Performance of a contract

Rent and service charge information, including details of any arrears.

Allocating homes, managing our services, making financial arrangements related to your home (setting up council tax payments), informing relevant local authority departments.

Performance of a contract

Financial information, including any credit checks, income details, bank details, housing

benefit information & any guarantor details.

To make financial arrangements related to your home, such as to enable automatic rent payment

through direct debit or housing benefit payments, set up your

Performance of a contract, Legal Obligation

council tax payments or deal with any mortgage arrangements;

To set up arrangements relating to your home, such as informing the Local Authority departments of your tenancy arrangements for council tax and housing benefit purposes To help other people or companies to provide services or utilities to your

home or to contact you. This may include where they need to contact you when you first move in to set up payments or about any unpaid bills while you live at your home and/or after you leave your home;

References received about you (e.g. from your employer or previous landlord).

Allocating homes, managing our services, administration

Performance of a contract

Medical information & emergency contact details, next of kin & any advocate, Information about any accidents or incidents which involve you or your home.

To provide information to our staff to enable them to provide services to you to meet your needs and to train and protect them where necessary;

To deal with any medical or other emergencies and to carry out your wishes or Requirement’s such as any religious or cultural wishes;

To act in someone’s best interests such as where we have concerns about a person’s health or welfare and may need to involve agencies such as Social Services or the police;

Explicit Consent, Social Protection Law or Protecting Vitals Interests in extreme circumstances

Details about your home when you apply to shared ownership

Allocating shared ownership homes.

Performance of a contract

Right to buy/acquire information

Records necessary for Right to Buy /acquire properties

Legal obligation, legitimate interest

Welfare benefit referrals, Housing benefit notifications, rent Statements, RentSense information

Administration of the contract

Performance of a contract, legal obligation

Information about any complaints made by you or which relate to you.

Legitimate Interest, Legal Obligation.

Information regarding your marketing preferences.

To deliver marketing materials such as our newsletter or make note of particular preferences.

Consent

Any photographs taken of you or your property.

Monitoring defects, assessing any health & safety risks, administering tenancies and security.

Legitimate Interest of Organisation

Any marketing materials/photos taken at events.

To promote our services.

Your Consent

Ethnicity data, Sexual Orientation and Religious Beliefs

To ensure fair and equal access for all to our services; To help us put together statistics to give to our regulator or other government organisations;

Explicit Consent for Equal Opportunities Monitoring

Convictions, proceedings and criminal acts

To respond to legal claims, to deliver our services, safeguarding, The apprehension or prosecution of offenders

Performance of a contract, social protection law, legal obligation, employment law, prevention and detection of crime

CCTV footage

For the prevention and

detection of crime

Legitimate Interest

Call Recordings

To improve our services

Legitimate Interest

Right available

Description of right

The right in practice

Right of access

You have the right to obtain confirmation from Hexagon as to whether or not personal data concerning you are being processed, and, where that is the case, access to that personal data.

Hexagon will provide a copy of all personal data belonging to you, or specific personal data if you so require it. This will not include the personal data of any other individuals, or information regarding Hexagon’s operations. We will redact where possible where exemptions apply. These may include a duty of confidentiality being in

place.

Right to rectification

You have the right to oblige Hexagon to rectify inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed by providing a supplementary statement.

This will only apply to inaccurate personal data; information contained on your application form or any flags placed on your record. This will not lead to any personal data which you disagree with being rectified, merely personal data which is inaccurate.

Right to erasure (right to be forgotten)

You have the right (under certain circumstances, but not all) to oblige Hexagon to erase personal data concerning you. This will never include current tenancy details as necessary to fulfil our contractual obligations, or any information we are required to process under law.

The right to be forgotten only applies:

• Where the personal data is no longer necessary

• If you withdraw consent

• If we unlawfully held your personal data

• If you successfully object to our processing

• If we have to follow a legal obligation to delete.

Right to restriction of processing

You have the right (under certain circumstances, but not all) to oblige Hexagon to restrict processing of your personal data. For example, you may

This right only applies:

• Where you contend the accuracy of any

personal data until

request this if you are contesting the accuracy of personal data held about you.

it has been made accurate

• Where you have objected to any processing whilst we present our evidence

• If we are processing anything unlawfully and you do not wish for it to be erased

• If we no longer need the personal data but you require the data to establish, exercise or defend a legal

claim.

Right to data portability

You have the right (under certain circumstances, but not all) to oblige Hexagon to provide you with the personal data about you which you have provided to in a structured, commonly used and machine-readable format.

You also have the right to oblige Hexagon to transmit those data to another controller.

This right only applies to data collected by automated means. As Hexagon does not currently undertake processing which is automated, we do not see any circumstances in which we would have to comply with this right. For a copy of your personal data, please carry out a subject access request instead.

Right to withdraw consent

If the lawful basis for processing is consent, you have the right to withdraw that consent. If you wish to withdraw your consent, contact us immediately.

Processing based on consent is likely to be limited to photographs at events, marketing information and in certain cases ethnicity or sexual orientation information.

Withdrawing consent will not affect the legality of any processing carried where consent were given

i.e. leaflets distributed will not be recalled.

Right to

Where your personal data are processed

This right will apply

object to

for direct marketing purposes, you have

instantaneously in most

direct

the right to object at any time to

instances. If you would still

marketing

processing of your personal data for

like to receive marketing in

marketing, which includes profiling to the

one particular medium,

extent that it is related to such direct

please let us know.

marketing.

Hexagon still reserves the

right to contact you

regarding important

matters unrelated to

marketing i.e. chasing rent

arrears.

Rights in

Hexagon does not perform any

Unlikely to occur in

relation to

automated decision-making based on

practice; Hexagon does

automated

personal data that produces legal effects

not carry out any

decision

or similarly significantly affects you.

automated decision

making and

making based on profiling.

profiling

Where profiling is carried

out without automated

decision making, we will

inform you where it

crosses a certain

threshold.