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Privacy Notice

A guide how we use your personal information

Privacy Notice for customers and suppliers.

Our Privacy Notice describes the categories of personal data we process and for what purposes. We are committed to collecting and using such data fairly and in accordance with the requirements of the General Data Protection Regulation (GDPR).

1 - Introduction

1.1     At Longhurst Group, we hold your privacy in the highest regard. This Privacy Notice ("Notice") is our commitment to transparency, ensuring you understand how Longhurst Group and its affiliated companies collect, use, disclose and process your personal data. We refer to ourselves as "Longhurst Group," “the Group,” "we," "us," and "ours" throughout this document. Longhurst Group is the 'data controller' of your personal data because we determine the use of this information.

1.2     This Notice encompasses the privacy practices concerning:

  • Customers: This includes you, prospective customers, tenants, partners and your representatives.
  • Suppliers: Our current or prospective suppliers and representatives of our suppliers and prospective suppliers.
  • Contacts: Anyone who communicates or engages with us regarding our products and services.
  • Dependents and emergency contacts: Dependents or emergency contacts associated with our workforce or customers.

1.3     Throughout this Notice, when we say "you" or "your," we are referring to you, our valued customer, supplier, contact, or someone associated with our workforce or customers.

1.4     This Privacy Notice is a public document available when Longhurst Group obtain and use your personal data. It explains how we and appointed third-party organisations/people use your personal data and your rights.

1.5     We obtain your personal data to conduct our normal business operations as a provider of housing, care, support, and training services.

1.6     We have a separate Privacy Notice which sets out how we will obtain and use personal data for job applicants, colleagues and others engaged with Longhurst Group to provide services. See here: Staff Privacy Notice.

1.7     Contacting Our Data Protection Officer:

For further information or enquiries, please contact our Data Protection Officer:

Eleanor Jacobsen
Assistant Data Protection Officer

Longhurst Group Ltd
1 Crown Court, Crown Way, Rushden, Northamptonshire NN10 6BS
Phone Number: 0800 111 4013

2 - Who we are

Regulation and oversight

2.1     As a registered social housing and care provider, Longhurst Group is regulated by the Regulator of Social Housing, the Housing Ombudsman, the Care Quality Commission, and the Financial Conduct Authority.

2.2     In this Privacy Notice, when we mention the term 'Group,' we are referring to other members of our 'Group' of companies, including holding and subsidiary entities. Our group of companies and their Information Commissioner’s Office (ICO) registrations are as follows:

  • Longhurst Group
    ICO Registration: Z5282684
  • Keystone Developments (LG) Limited
    ICO Registration: Z7833811  
  • The Teetotal Homes
    ICO Registration ZB180608
  • Pondersbridge Management Limited
    ICO Registration ZB180582
  • DHG LG LLP (formerly Evera Homes LLP)
    ICO Registration ZB180321
3 - How we collect you personal data

We employ various methods to collect personal data about you:

3.1     Direct collection: In-person, in writing, on the phone, or via our website:

When you provide information directly to us, or example:

  • When you fill out a form either in hard copy or online, such as a mutual exchange form.
  • By observing how you use our housing, support, services and products, for example from the transactions and operation of your online account and services with the Group.

3.2     Correspondence:
By receiving information from sources such as a local elected member who is representing you, police, health or social care agencies, former housing and support providers.

3.3     Third-party contributions:
Information may be received from individuals connected to you, such as relatives, people nominated to act on your behalf or your legal representatives, for example joint account holders, people linked to you or living in the same community as you.

3.4     Automatic collection - website interaction:
When you access our website, we may utilise technologies like cookies and pixel tags to automatically collect information about your device and site usage (with your consent where required).

Pixels in HTML emails may be used to track if an email was opened/read or delivered.

3.5     Other methods:

  • Call monitoring and recording:
    Monitoring or recording calls as part of quality and complaints monitoring. We may record these calls for training and to ensure the safety of our colleagues. We will not record any payment card details as part of accounts and payments operations.
  • CCTV and bodyworn video systems:
    We use CCTV and bodyworn video cameras for the prevention and detection of crime or to detect damage/vandalism to our properties, and to ensure the safety and security of our colleagues and individuals obtaining services from us.
  • Audio recordings:
    We only use audio recordings which are obtained from lone working devices and bodyworn video cameras when colleagues feel they may be at risk of harm or abuse.
  • Observation of service usage:
    The information we receive when observing how you utilise our housing, support, products, and services provided by the Group. This is used to improve the services we offer and your access to them.
  • Information from external organisations:
    For example, information received from your former housing, care and support providers, health and social care agencies, law enforcement agencies, debt collectors, energy or utility companies, benefit agencies, credit reference and fraud prevention agencies, and our learning and development provider. We use this to ensure you can access the right service and information.

3.6     Third-party involvement:

  • Social media providers and other platforms:
    Information may be gathered from third parties outside of the Group, including social media providers (e.g., Facebook, X (formerly known as Twitter) or other third-party platforms (e.g. Orlo) and companies. We use this to review and improve the effectiveness of our marketing. 
  • Customer Employment and Skills programme providers where we act as a data processor passing your completed enrolment forms to the third-party provider.
4 - What kind of personal information do we use

4.1     We use a variety of personal data depending on the services we deliver to you.

4.2     Personal data/information includes:

  • Contact details - name, address, email, home, work, and mobile telephone numbers.
  • Age – date of birth.
  • Identification - information to allow us to check your identity.
  • Credit information – information about your credit history.
  • Photographs – information to record your identity.
  • Bank and direct debit details.
  • Online computer identification (IP address) – information recorded when you engage with us by email, use our website or My Account (online portal).
  • National Insurance numbers – information to carry out functions such as universal credit and/or supporting people contracts.
  • Information about your family, lifestyle, and social circumstances.
  • Details about your behaviour.
  • Details about your employment status.
  • CCTV and bodyworn video recordings – for anyone on our premises.
  • Telephone recordings of anyone calling us.
  • Audio recordings – in an emergency where a colleague is at risk of harm or abuse.

4.3     We may also collect the following information for occupants of your property (i.e. those people who may live with you, but who have not applied or who do not receive our services directly)

  • Name
  • Gender
  • Date of birth
  • Relationship to those receiving or applying directly for our services.

4.4     We also collect details of your representatives and/or next of kin. (You should always seek their consent before providing us with this information.)

  • Contact details – address, phone numbers, e-mail address.
  • Relationship to those receiving or applying directly for our service.

4.5     Special information includes information about your:

  • Health - to support our housing, care and support functions and vulnerable customers.
  • Race – optional, and solely to support our equality monitoring purposes.
  • Ethnic origin – optional, and solely to support our equality monitoring purposes.
  • Religion – optional, and solely to support our equality monitoring purposes.
  • Sexual life or sexual orientation – optional, and solely to support our equality monitoring purposes.
  • Convictions – to prevent and detect crime, fraud, and anti-money laundering, to aid in the prosecution and rehabilitation of offenders, for your safety, and the safety of residents and colleagues.
  • Additional needs and vulnerabilities – to provide a more tailored approach to our customers when delivering a service.

4.6     There are other types of special information which we do not collect but are deemed important under the law:

  • Trade union membership.
  • Biometrics (where used for ID purposes).

4.7     For more information about the kind of personal information we use for different services, see section 5.

4.8     Sometimes, where we ask for your personal data to enter into a contract/agreement with you (for example, tenancy agreement, lease, housing application, support and/or care plan agreement) 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 will not be able to provide some of our housing, support or products or services without this information.

5 - How we use your personal data

5.1     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 will need to obtain 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 licence).

5.2     We also need to collect proof of your immigration status and your identity for the government’s Right to Rent legislation.

5.3     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, or additional needs and/or receive a support or care service from us.

5.4     We sometimes need to gather, use, and share your personal data for particular reasons, which are set out in more detail below.

5.4.1     To operate and administer our housing, support, care and repair products and services, including managing and responding to complaints:
a) Contact details, household information, accommodation history, conduct of previous tenancies or similar agreements, benefits and income details, health, and lifestyle to assess your eligibility for housing and/or to meet any care or support needs/or to assist you in applying for disabled facilities grants or care and repair services.
b) We use your name and contact information with third parties who help us deliver our repairs, support, care, and housing services. For example, our repair contractors and their appointed sub-contractors.
c) Your contact details, health information and next of kin or representative details, for the provision of emergency alarms and monitoring services, and assistive technology services.
d) Information about your health, wellbeing and lifestyle choices and preferences, to be able to provide management, care, and support to you or refer you for appropriate support.
e) Equality and diversity information to monitor access to, and take up of, our services.
f) With your consent, next of kin, or representative details to be able to contact them in an emergency such as when you are taken ill or when we need to contact someone because we need to enter your accommodation to carry out emergency repairs.
g) Information about your complaints which we may be required to share with an MP, councillor or recognised complaints panel acting on your behalf, as well as with the Housing Ombudsman or Regulator of Social Housing.
h) Information about the behaviour and criminal behaviour or activity of you, your household or visitors, to be able to manage, support or tackle the victim(s) or perpetrator(s) of anti-social behaviour and provide our housing management services. We may share information with the police and other law enforcement agencies for the purpose of the prevention and detection of crime.  We use CCTV, bodyworn video camera and lone working audio recordings to detect and prevent crime. Contact details, income, and health information to assist you in applying for disabled facilities grants and care and repair services.

We use your personal data in this way because it is necessary to meet the conditions set out in the contract/agreement with you and/or to meet our legal or regulatory obligations or because we have your consent.

5.4.2     To administer payments to and from your accounts, and/or in relation to payments owed to or due from other agencies (e.g. benefits agency and utility companies):

We use your personal data in this way because it is necessary to meet the conditions set out in the contract/agreement with you and/or to meet our legal and regulatory obligations and/or where it is fair for us to do so.

5.4.3     To carry out our duties under health and safety regulations and to support our vulnerable people and promote safe communities:
a) Vulnerability indicators with contractors and sub-contractors to ensure services are tailored to meet your needs.
b) Concerned/Warning/Lone working 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 will be applied and for how long, for example a warning marker will be applied when an incident has occurred which results in a threat being made by you to a colleague or contractor team.
c) Criminal convictions such as sexual offences, violence, or arson, which may mean you are at risk of harm, or that you pose a threat to colleagues, residents or other communities if housed in certain types of accommodation or areas.
d) CCTV and lone working recordings to protect communities and colleagues.

We use your personal and special identifiable information in this way because it is necessary to meet the conditions set out to meet our legal and regulatory obligations in relation to health and safety, and it is in the public interest, and/or for the prevention or detection of crime and/or where it is fair for us to do so.

5.4.4     To report or share information with agencies where it is believed you or another person’s vital interests are at risk:
a) Where you or another person is at risk of physical, mental, or sexual harm or damage. Information may be shared with a health professional, social worker, emergency services or local agencies with a responsibility for safeguarding.
b) Where you or another person is in need of being protected as a vulnerable person from significant harm or serious exploitation.

We use your personal and special identifiable information in this way because it is necessary to meet our legal and regulatory obligations and to protect your and others’ vital interests. 

5.4.5     To carry out our lettings and home ownership affordability assessments, for grant purposes and former debt decisions about you:
a) Information you give to us about your former addresses will be used to carry out a credit history check with approved suppliers (e.g. Experian). No credit ‘footprint’ will be left as part of this process.
b) Information about those you are linked with in the proposed agreement or contract with us, for example, a joint tenant or owner.
c) Information about how you or the person linked to you has former debts owing to us or other landlords which may prevent you from obtaining accommodation with us or limit your ability to pay your rent, management fees and or service charges.
d) Information about your current earnings and outgoings to assess your ability to pay your rent or purchase a home, or as part of a grant application.
e) We may also use credit agencies such as Experian to trace you if you leave us owing a debt.

For these purposes, we 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 or where it is fair for us to do so.

See a list of credit reference and fraud prevention agencies with which we engage in Appendix 1.

5.4.6     To carry out market research and analysis to develop and improve our housing, support, care and products and services:
a) Contact and household information, including profiling information about those who have direct services from us such as age, gender, sexual orientation, ethnicity, religion, and disability. This information may be shared with third-party contractors who carry out research or surveys on our behalf. This information is used to help us ensure we achieve results which are representative of our customer base.

5.4.7     To promote the goods and services of Longhurst Group and its member companies:
a) Photographs and testimonials may be used with your consent in marketing and publication materials.
b) Where we have your permission, we will use your contact details to contact you about our goods, services, or competitions.

5.4.8     To facilitate and undertake the work of our training academy:
a) Your contact details so we can facilitate training and guidance.
b) Details of your educational achievements or attendance and/or employment status to help us provide training and guidance to you.

We use your personal data in this way because it is necessary to meet the conditions set out in the contract/agreement with you.

5.4.9 We share information on the grounds of public interest with the Department for Levelling Up, Housing and Communities (DLHC) as part of the regulatory requirements of CORE (Continuous Recording of social housing lettings and sales) used for research and statistical purposes. DLHC have their own Privacy Notice which can be found here: Personal information charter - Department for Levelling Up, Housing and Communities - GOV.UK ( and where you can find more information about the process and who to contact if you have any concerns.

5.4.10 We share information on the grounds of public interest with the Department of Security & Net Zero (DESNZ) and its Consortium partners TrustMark Research and Innovation (TRI) as part of the conditions of the funding we receive to enable monitoring of performance and delivery of the energy performance of social housing stock. We are required to provide a monthly performance report to DESNZ which includes personal data on the legal basis of public task. DESNZ’s privacy notice can be found here: Social Housing Decarbonisation Fund: Wave 2.2 - Privacy notice - GOV.UK (

5.4.11 TRI collects information from the Longhurst Group in relation to customers who have publicly funded works conducted on their property. TRI or Longhurst Group may contact you on the legal basis of public task to seek your informed consent and may share your data with DESNZ or TRI on the lawful bases of legitimate interest.

5.4.12 On behalf of the Social Housing Decarbonisation Fund (SHDF) your personal data is collected by TRI for the purposes of research and development and is limited to building specific information namely: property address, energy meter data and building test results. The TRI do not hold or process personal data such as name, telephone number, email address or occupation nor do they hold any special categories of data. TRI’s Privacy Notice is available on request.

Please see Appendix 2 to see a full list of our categories of suppliers. 

6 - Automated decision-making

6.1     Sometimes we use your personal data in automated processes to make decisions about you, such as credit scoring. We might also use automated processes to create a profile of you. We do this to help ensure decisions are made accurately, fairly, and efficiently and to offer services tailored to you.

6.2     We will inform you where your information is forwarded to Experian as part of the ‘Rent Exchange Scheme’ and we share information as follows:
a) Information about you to Experian as part of the ‘Rent Exchange Scheme’ including details of your rent payment history, your tenancy start and end date, your tenancy reference, your rent, and your rent balance, including any arrears.

7 - Our legal basis for using your personal data

7.1    We only use your personal data where that is permitted by the laws that protect your privacy rights. This will be where:
a) We need to use the information to comply with our legal obligations.
b) We need to use the information to perform a contract with you; and/or
c) It is fair to use the personal data either in our legitimate interests or someone else's interests, where there is no disadvantage to you – this can include where it is in our interests to contact you about products or services, market to you, or collaborate with others to improve our services.
d) Where we need to seek your consent (if consent is needed).

7.2    Where we have your consent, you have the right to withdraw it. We will let you know how to do that at the time we gather your consent. See section 10, clause 10.4 for details about how to withdraw your consent to marketing.

7.3     Special protection is given to certain kinds of personal information that is particularly sensitive. This is 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:
a) We have a legal obligation to do so (for example to protect vulnerable people).
b)it is 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).
c) it is in the substantial public interest.
d) it is necessary for the prevention or detection of crime.
e) It is necessary for insurance purposes; or
f) you have specifically given us ‘affirmative’ consent to use the information.

7.4    Details of our lawful basis relied on for our different processing activities are set out in the following table. 

Processing Activity - Customers

UK Lawful Basis for Processing, including Legitimate Interests (where applicable) 


Our legitimate interest in managing our business sales services.

Care, Support and Housing 

Our legitimate interests in supporting our customers with care and support, tenancies, leasehold, sales, repairs, and other enquiries, and in communicating with our suppliers regarding the products and services they offer. 

Our legitimate interest in running our business, we share potential customer, supplier and existing customer details with the Department of Work and Pensions and relevant local authorities’ Housing Benefit and Council Tax departments for fraud prevention.

Out of hours Care and Support

Our legitimate interest to provide our services and appoint Out of hours support service providers.

Property maintenance

Our legitimate interest in providing our services contracting with various third-party repairs and maintenance providers.

Hardship Fund services

Our legitimate interest in contracting with various third-party white good suppliers to purchase and deliver goods.


Our legitimate interest in running our business.  

Emergency alarm

Our legitimate interests in providing emergency alarm and telecare services


Our legitimate interest in promoting our business, our brand, our properties and services. 

Research and analytics 

Data Protection Act 2018 exemption (where applicable) or our legitimate interest in identifying and responding to changing market conditions and our customers’ needs, for example customer satisfaction surveys, to provide research on the goods requested under the hardship fund in the previous two fiscal years.

Planning and managing events 

Our legitimate interest in promoting our business, our brand and our properties, products, and services. 

Safety and security 

Our legal obligations to protect, and to the extent that our activities go beyond the strict requirements of applicable law, our legitimate interest in ensuring the safety of all individuals attending our offices or properties. 

Exceptionally; your, or another individual’s, vital interests. 

Credit reference agencies

Our legitimate interest in managing our business.

Our legitimate interest in running our business, we share potential customer, suppliers and existing customer details with credit referencing agencies.


Compliance with legal & regulatory obligations 

Our legal obligation to comply with applicable law.

To the extent that our activities go beyond those strictly required by law, our legitimate interest in complying with our legal and regulatory obligations effectively and efficiently. 

General business obligations 

To comply with our legal obligations. 

To the extent that processing goes beyond the requirements of applicable law, our legitimate interests in operating the administrative and technical aspects of our business efficiently and effectively and in compliance with applicable law and regulation. 

Dependents and emergency contacts 

To contact in an emergency 

Our legitimate interest, and that of the relevant member of our workforce and customers, in contacting their appointed individuals in the event of a serious incident affecting our customers/colleagues/relatives. 

Website visitors 

Website and information security 

Our legitimate interest in ensuring the security of our website(s) and all information processed by such website(s). 

Website analytics  

Our legitimate interest in assessing how website visitors use our sites so that we can improve them. 



Our legitimate interest in ensuring the security of our colleagues, CCTV monitoring services, lone working monitoring services and bodyworn video monitoring services.

Domestic payment systems

Our legitimate interest in managing our business.


8 - How we share your personal data

8.1     Group companies 

8.1.1     We may share your information with other companies within the Longhurst Group umbrella of companies and with others outside the Group where required so that we can make products and services available to you, market products and services to you, meet or enforce a legal obligation or right, or where it is fair and reasonable for us to do so.  See section 5, how we use your personal data, for more information.

8.1.2     Who we share your personal data with depends on the products and services we provide to you and the purposes for which we use your personal data. For most products and services, we will share your personal data with our own service providers such as our IT suppliers, with credit reference agencies, repair contractors and agents, emergency care line providers, CCTV, bodyworn video and lone working contractors who monitor visual and audio recordings, and fraud prevention agencies. See section 5, how we use your personal information, for more information on who we share your personal data with and why. See Appendix 2 for information on the categories of our suppliers.

8.1.3     Most of the time, the personal data we have about you is information you have given to us or has been gathered by us while 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 detection and prevention or marketing purposes. For example, so you can receive the best offers from us and our partners. See section 5, how we use your personal information, for more information on who we get your personal information from and why.

8.1.4     When a Longhurst Group company receives your personal information, it will act as an independent controller of that information and may use your personal data in accordance with this Notice.  

8.2     Other ways we may share your personal information

8.2.1     We may disclose your personal data to a third party:
a) As part of a new tenancy process.
b) As part of a sale of some or all our business and assets to any third party or as part of any business restructuring or re-organisation.
c) If we are under a duty to disclose or share it to comply with any legal obligation, for security purposes and to protect rights, such as to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers.

8.2.2     Where the third party has independent purposes and means of processing your personal data, you may contact us at for more information about the identities and contact information of the third parties, the specific types of personal data shared and the purposes of sharing. We will share with you the relevant information unless the disclosure is prohibited or restricted by applicable law.

8.3     Our suppliers and service providers 

8.3.1     We may disclose your personal data to our third-party service providers, agents, contractors, subcontractors, vendors, business partners, marketing, advertising, and analytics providers, third-party platform services and other organisations (as listed below) for the purposes of providing services to us or directly to you on our behalf. See Appendix 2 for a list of categories of our suppliers.

8.3.2     We will endeavour to only share your personal data with suppliers and service providers based in the European Economic Area (EEA). The only exceptions to this are when we contract with companies that are based outside the EEA and we may use Cloud storage providers which are based outside of the EEA.

9 - Transfers outside the UK

9.1     We may need to transfer your personal data to, or access it in, other jurisdictions (including the United States) that do not include equivalent levels of data protection as the United Kingdom or the EEA.

9.2     When we transfer personal data, we will take organisational, contractual, and technical measures designed to safeguard your personal data to the levels required by local laws. This includes appropriate written data processing terms, and/or data transfer agreements, and/or other legally acceptable mechanisms according to applicable laws.

9.3     If we transfer your personal information to a jurisdiction located outside of the UK, which may not have similar data protection laws to the UK and may not be recognised by the UK Government (or other relevant regulatory body) as providing an adequate level of data protection, we will take steps to ensure that appropriate security and other safeguards are in place to ensure that your privacy rights continue to be protected as outlined in this policy.

9.4     These safeguards include imposing contractual obligations, such as the UK-approved standard contractual clauses or the international data transfer agreement (IDTA), on the recipient of your personal information.

9.5     We contract with Mailchimp which is a part of the Intuit Group for market research services and is based in the USA. Mailchimp complies with the EU-US Data Privacy Framework (DPF) and the UK Extension to the EU-US DPF regarding the collection, use and retention of personal data transfers from the United Kingdom to the United States.

10 - Security

10.1     We have in place a variety of technical and organisational security measures designed to protect your personal data and prevent unauthorised access to use or disclose it.

11 - How long we keep your personal information for

11.1     How long we keep your personal information for depends on the service we deliver to you.

11.2     To see how long we keep your data for, please see Appendix 3, Retention Summary.

12 - Your privacy rights

12.1     Data protection laws give you rights in relation to your personal data, and subject to the conditions and limitations of such law, you may have one or more of the following rights:

12.2     Accessing your personal data

12.2.1     You have the right to ask for a copy of the information that we hold about you by emailing or writing to us. We may not provide you with a copy of your personal data if this concerns other individuals or we have another lawful reason to withhold that information.

12.3     Correcting and updating your personal data

12.3.1     The accuracy of your information is important to us. If the personal data we hold about you is inaccurate or incomplete, you are entitled to request that we make corrections.

12.4     Withdrawing your consent

12.4.1     Where you have previously provided your consent and that is our legal basis for processing your personal data, you may withdraw your consent at any time.

12.4.2     Please note that if you do withdraw your consent, our use of your personal data before you withdrew your consent remains lawful.

12.5     Objecting to our use of your personal data

12.5.1     Where we rely on our legitimate business interests as the legal basis for processing your personal data for any purpose(s), as detailed under Section 5, how We Use Your personal data, you may object to us using your personal data for these purposes, except for the purposes for which we are sure we can continue to process your personal data. We will temporarily stop processing your personal data in line with your objection until we have investigated the matter.

12.5.2     If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your data.

12.5.3     Where personal data is processed for direct marketing purposes, you have the right to object at any time to such processing (including profiling to the extent that it is related to such marketing).

12.5.4     If you make such an objection, we will no longer process your personal data for direct marketing purposes.

12.5.5     You may also contest a decision made about you based purely using automated processing by contacting us.

13 - Erasing your personal data or restricting its processing

13.1     In certain circumstances, you may ask for your personal data to be removed from our systems. Unless there is a lawful reason which allows us to use your personal data for longer, we will make reasonable efforts to comply with your request. For example, if we need to retain your personal data to complete a transaction or provide you with a service.

13.2     You may also ask us to restrict processing your personal data where you believe it is unlawful for us to continue processing, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations, we may only process your personal data whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

14 - Transferring your personal data

14.1     We will transfer your personal data using a secure format when we are obliged to do so by law, or in connection with our contracts with external providers such as local authorities.

14.2     How we collect your personal data, or if your request is otherwise supported by the applicable data protection laws, you may ask us to provide you with a copy of that information in a structured data file.

14.3     We will provide this to you electronically in a structured, commonly used, and machine-readable form, such as a CSV file. We may not provide you with a copy of your personal data if this concerns other individuals or we have another lawful reason to withhold that information.

15 - Your right against discrimination

15.1     You have the right not to be discriminated against for exercising any of the rights granted to you under any applicable law in relation to your personal data. The Group will not deny you its housing or care and support services or charge you different rates or processes if you decide to exercise your rights.

15.2     Please be aware that these rights are not absolute, and the legal basis for why we process your personal data (where a legal basis is required under applicable privacy and data protection law) may affect the extent to which these rights apply.

16 - How to exercise your rights

16.1     To exercise any of your data protection and privacy rights, please email your request to us at We require you to verify your identity before responding to your request. We may ask you to provide us with additional information to verify your identity.

16.2     When you make a request, you should also provide us with enough information so that we are able to action it. We will respond to you within the timeframe required by UK law (this is usually one month).

16.3     You can have a third-party submit a request on your behalf. The third-party must provide us with evidence that it has your valid authorisation (such as signed permission from you) to verify your identity. We may also need to verify the identity of the third-party.

17 - How to make a complaint

17.1     Although you have the right to complain to the applicable data protection authority, we encourage you to contact us first at before making any complaint. We will seek to resolve any issues or concerns you may have.

17.2     You can also make a complaint to the data protection supervisory authority. In the UK, this is the Information Commissioner's Office, at

18 - Keeping you up-to-date

18.1     We will communicate with you about products and services we are 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.

18.2     Where you have given us consent to receive marketing, you can withdraw consent, and update your marketing preferences by contacting us directly. Please contact us at

19 - Changes to this notice

19.1     We may review this Notice from time to time. Customers will be notified when this Notice has been updated and a copy will also be available on the Group’s website.

19.2     If we make any changes that materially affect our practices regarding the personal data we have previously collected from you, we will endeavour to provide you with notice in advance of such change by highlighting the change on our website or, where appropriate, notify you by email. Where it is required by applicable data protection laws, we will obtain your consent to the changes.

19.3     We recommend you regularly review this Notice and check for changes.

Appendix 1

Credit reference and Fraud prevention agencies

We share information with the following for credit referencing and scoring:

  • Experian Limited

We share information with the following for fraud prevention:

  • Department for Work and Pensions
  • Local authorities – Housing Benefit and Council Tax departments.
Appendix 2

Categories of suppliers

Recipient/relationship to us 

Industry sector (and sub-sector) 

Accountancy services 

Professional services (accountancy) 

Real estate 

Real estate holding and development house sales, rental & leasing services

Local Government

Local authorities

Customer services – for Care & Support

Care and Support services

Health and Safety

Health and Safety services

Banks, payment processors and financial services providers 

Financial (banking) 

Cloud storage providers 

IT (cloud services) 

Financial auditing services 

Audit (financial) 

Government tax administration offices 

Government (tax) 

Website analytics provider (Google Analytics)

IT (website analytics)

Insurance brokers – for claims 

Insurance (broker) 

Insurance services – for claims 

Insurance (underwriting) 

IT support service providers 

IT (support and maintenance) 

Legal advisers 

Professional services (legal services) 

On-site security access control services 

Security (on-site) 


Emergency alarm and telecare monitoring services


CCTV monitoring services

Security - colleague

Lone working monitoring services

Security – colleague

Bodyworn video monitoring services

Research service providers 



Telecommunications equipment


Telecommunications service providers

Learning and Development


Emergency care line providers

Emergency care line providers

Credit reference agencies

Credit reference agencies

Appendix 3

Retention summary

How long do we keep your information?

In most cases, we hold onto your information for six years after the service we provide you ends.  For example, six years after the end of your tenancy.  Our commitment is to only retain your personal data for as long as it is needed to fulfil its initial purpose of collection.

There are instances where information might need to be kept for a longer period of time in line with our legal obligations, adherence to industry regulations, addressing complaints, potential litigation, safeguarding or care standards, in alignment with legislation regarding Right to Buy, health and safety, or other pertinent considerations.

We strive to anonymise your data whenever feasible, removing any identifiable elements. This allows us to use the information indefinitely for research or statistical purposes without the need for further notice to you.

Updated: 18 April 2024

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