Purpose of this Privacy Policy

We comply with UK data protection laws including GDPR, the Data Protection Act 2018, and related regulations. Personal data refers to information that identifies an individual. Anonymous data is not covered.

This Privacy Policy explains how we collect and use your personal data in accordance with data protection law. It explains how we use information you might provide when you contact us, interact with our services or use our website, online portal or the Housing Solutions app.

Personal data/information means any information about an individual who can be identified from the information. It doesn’t include data where the identity has been removed (anonymous data).

It is important that you read this privacy policy together with any other privacy or fair processing notice we’ll may provide to you from time to time when we’re in touch with you so you’re fully aware of how, and why, we’re using your information.

Changes to the Privacy Policy and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current.  Let us know of any changes to your information as soon as possible.

We may amend this Privacy Policy from time to time. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

This version was last updated on 24/09/2025 (v4).

Data Controller

Housing Solutions is the data controller.

Our Data Protection Officer can be contacted at:

Email: datacontroller@housingsolutions.co.uk

Address: Crown House, Crown Square, Waldeck Road, Maidenhead, Berkshire, SL6 8BY

Phone: 01628 543101

You may also contact the Information Commissioner’s Office (www.ico.org.uk) with concerns.

Depending on the way in which you use our services, we may use different methods to collect data from and about you including through:

• Direct interactions (completing forms and communicating with us including through phone calls and email)
• Website and app usage (logs and cookies –  you can read more about this in our Cookie Policy https://www.housingsolutions.co.uk/cookies .)
• Third parties and public sources;
• Obtaining services from us or report issues with our services;
• Participating in an event, activity,  competition, promotion or survey

Types of Data Collected

• Identity and contact details
• Financial and transaction data
• Technical and usage data
• Profile and communication preferences
• Statistical data (anonymized where possible)

If you’re a Tenant

We’ll use the following types of information to manage your tenancy:-

• Tenancy records to manage and support your tenancy including where additional support is provided;
• Rent and service charge account information;
• Repair, maintenance and property adaptation records;
• Customer feedback and satisfaction;
• Records of tenancy changes (e.g. mutual exchange, succession or an application to purchase);
• Information about specific issues affecting tenants/their household members (e.g. anti-social behaviour, safeguarding concerns, hoarding);
• Information about actual/suspected fraud;
• CCTV footage; and
• Information relating to how you engage with us or get involved in our work.

If you’re a Shared Owner or Leaseholder

We’ll use the following types of information to manage your lease:-

• Information about the sale/purchase/assignment of a lease or its extension or about the sale of a freehold;
• Information relevant to a lessee’s mortgage or remortgage application;
• Information relevant to service/repairs/other charges;
• Rent review information.
• Information in connection with managing your business lease/tenancy.

Equality, Diversity and Inclusion Data

We sometimes ask residents to share information about their background, such as age, sex, gender identity, disability, ethnicity, religion or belief, and sexual orientation. This is often called “protected characteristics data.”

Why we collect this information

We use this information to:

• Understand the make-up of our resident community;
• Make sure our services are fair, inclusive, and accessible;
• Identify and address where some groups may be disadvantaged;
• Comply with our responsibilities under the Equality Act 2010 and the expectations of the Regulator of Social Housing.

Collecting this data helps us design better services and ensure everyone is treated fairly.

Do you have to provide this information?

No. Giving us this information is completely voluntary. It will never affect your tenancy or the services you receive. You can choose “prefer not to say” to any question, and you can ask us to update or delete your information at any time.

Lawful basis

Under UK data protection law, this is classed as “special category data.” Our lawful bases are:

• Article 6 UK GDPR – legitimate interests (to improve our services) and legal obligation (to meet equality duties);
• Article 9 UK GDPR / DPA 2018 – substantial public interest (equality of opportunity or treatment) and explicit consent.

Due to the nature of the services we provide to you, some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we make sure it’s similarly protected by either:

• Transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; and/or
• Using specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to only those employees, agents, contractors and other third parties who have a valid purpose in receiving it. They’ll also only process your personal data based on our instructions and are subject to legal duties in how they process your information. We have put in place procedures to deal with any suspected personal data breach – if your personal information has been compromised in any way we’ll notify you without delay so you are aware and can take the necessary steps. 

How long will you use my personal data for?

We’ll only retain your personal data for as long as necessary to carry out the purpose(s) we collected it for, including any legal, accounting, or reporting requirements.

As a regulated housing association, we follow the National Housing Federation’s recommended retention periods for categories of personal information. You can read the full guidance at : National Housing Federation - Document retention and disposal for housing associations

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep certain information about our tenants (including Contact, Identity, Financial and Transaction Data) for six years after they cease being tenants for tax purposes or to bring or defend ourselves against legal claims.]

In some circumstances you can ask us to delete your data: see the “Request erasure” section of Your Legal Rights below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

You have rights under data protection law in to:

• Request access to your personal data (a "data subject access request").
• Request correction of personal data that we hold about you.
• Request deletion of your personal data.
• Object to processing of your personal data in certain situations
• Restrict processing of your personal data in certain situations e.g by suspending the processing of your personal data
• Request the transfer of your personal data to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of these rights, please contact us.

We’ll always ensure we have a lawful basis under data protection law to process your personal data.

This will generally be one of the following :-

• Legitimate interest - means Housing Solutions’ interest in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We’ll balance any potential impact on you and your rights before we use this reason.
• To operate your tenancy or lease with us (performance of contract) - means processing your data where it is necessary under the tenancy or lease. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation we’re subject to.

We may share your personal information in the following situations:

With contractors, suppliers and service providers: we may share your personal information for the purposes of providing you with a service on behalf of Housing Solutions or so that you may use our service directly. These would include : -

• Repairs and maintenance contractors
• IT and systems administration services
• Our out-of-hours service provider (currently NPA, part of Davies Emergency Response)
• Our website payment provider (currently Capita
• Debt collection services or utility services. For example, we may share this information if (as a tenant) you leave one of our properties with arrears.
• Law enforcement, government agencies, local authorities or other public bodies such as the police, fire services or medical staff.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs and other regulators or authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

If Housing Solutions is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We’ll provide notice before this happens and your personal information becomes subject to a different Privacy Policy.

We may supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.

CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates.

The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail at Experian: www.experian.co.uk/crain

• For business transfers: we may share or transfer your personal information in connection with, or during negotiations of, any merger, transfer of properties, financing, or acquisition of all or a portion of our business to another company/organisation
• With other companies that are part of the Housing Solutions Group – these currently include Housing Solutions Development Ltd, HSG Property Services Ltd and Housing Solutions Capital PLC. With other users: when you share personal information or otherwise interact in shared forums or systems, such information may be viewed by all users and may be publicly distributed outside.

We don’t provide services to anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. Our website, online portal and app are not aimed at children. If you’re a parent or guardian and you’re aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from a child under 13 without parental consent, we’ll take steps to remove it from our systems and servers.