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When everyone has a home

028 9024 5640: Housing & Debt Helpline for Northern Ireland

Housing Rights Privacy Policy

Housing Rights helps thousands of people struggling with bad housing or homelessness every year.  We do this through by providing advice, support and legal services.

When doing this, we process personal data about people who receive advice, guidance or housing support services from us, book on training courses, or volunteer with us.

We are committed to protecting your privacy and take this responsibility very seriously. We therefore take care to safeguard it. This notice outlines what data we collect, how we may use it, how we protect your data and your rights, and how you can exercise those rights.

References to 'we' or 'us' are to Housing Rights, NIC105735 Middleton Buildings, 10-12 High Street, Belfast, BT1 2BA.

We regularly check this notice to ensure we provide you with the most up-to-date information regarding our data processing activities. We strongly advise you to read it from time to time to ensure you are happy with any changes that might be made.

This privacy policy was prepared to be as comprehensive as possible, but it does not include an exhaustive list of every aspect of our collection and use of personal information. However, we would be happy to provide a copy of our policy and procedure on this if requested.

If you have any questions about this policy, please contact us using the details in the “Contact us”, section below.

This privacy policy was last updated in May 2018.

Why we collect your data

We collect personal data for many reasons, including to provide you with services, communicate with you and send you information you have requested.  Depending on how you interact with us, we may process data for the following reasons:

  1. to provide you with advice, support or legal services that you have requested or been referred to
  2. to record personal details shared during conversations with our housing helpline or advisers to help them advise and represent you fully
  3. to process personal details required for the administration of your booked training course
  4. to process a purchase of a publication on your behalf
  5. to record and contact you regarding payments you make to us
  6. to administer services we are providing to you
  7. to communicate with you regarding  our work
  8. to process donations and administer Gift Aid information for any donation you make to us
  9. to process a purchase via our website on your behalf
  10. for our own internal administrative purposes, and to keep a record of your relationship with us
  11. to manage your communication preferences
  12. to process job applications or volunteer placements
  13. to conduct surveys, research and gather feedback
  14. to obtain information to improve our services and user experiences
  15. to carry out research to find out more information about our members and customers to improve and develop our services
  16. to comply with applicable laws and regulations, and requests from statutory agencies

Information we may collect

We collect the following personal information:

  1. your full name
  2. contact details – including your postal address, telephone number(s), and email address
  3. date of birth
  4. details relevant to your case when providing you with housing advice or services (eg housing tenure, marital status, health information)
  5. your bank details if you have purchased something from us
  6. records of your correspondence and engagement with us
  7. information you may enter on the Housing Rights website
  8. photographs, video or audio recordings
  9. occupation
  10. other relevant information you share with us (eg during recruitment such as previous employers & educational attainment)

This information may be collected via:

  1. any paper forms you complete
  2. telephone conversations or face-to-face interactions
  3. digital forms completed via our website, online surveys or email
  4. third-party companies and websites such as Just Giving/My Donate
  5. publicly available sources
  6. communication via social media

We sometimes also collect sensitive, personal data about individuals. This includes information about health, religion, sexuality, ethnicity, political and philosophical beliefs, and criminal records. We will normally only record this data where we have your explicit consent, unless we are permitted to do so in other circumstances under data protection law. For example, we may make a record that a person is in a vulnerable circumstance to comply with requirements under charity law and the Code of Fundraising Practice, to ensure that we do not send fundraising communications to them.

Using your personal data

If you are receiving advice, guidance or support from us, we will need to process your data because of your specific relationship with us.

We will keep all your case information – including notes, letters and information given to us about you – in a confidential record that is specific to you. We use a secure password protected web based case management system.  This means that we can keep the information you provide us, so we are able to see the history and relevant details of your case(s). This ensures that we provide appropriate and accurate advice or support. We take information security very seriously. No one is allowed access to our system or files unless they need this to provide the service to you, or one of the other purpose discussed in this notice.

When you call our organisation, your call is recorded. This is used for training purposes, quality assurance, complaint investigations, and to make further improvements to the service we provide to you. You are informed of the recording before any data collection occurs.

To ensure that our services meet a high standard of quality, client files are sometimes checked by our quality assurance staff. Files may also be checked by external auditors if the work we do is funded by another organisation, such as a local Government department or Legal Services Agency. All auditors are bound by confidentiality policies.

We may use your data for statistical reports. These statistics will not include any information that could be used to identify any individual.

Direct marketing

We use a range of marketing activities and channels to communicate with our members, customers and supporters – including our website, direct mail, email, and telephone.

We send the following marketing materials:

  1. updates about Housing Rights work – including e-bulletins, mailings  and other publications informing you about our work
  2. events – Please note that if you sign up to a Housing Rights event, we will also send you administrative communications about how you can take part. On occasion we will also send you a reminder about the same event in future years, in case you want to participate in it again
  3. shop products – including information about products offered by our online shop
  4. volunteering – information about how you can help support us by giving up your time or using your influence to progress our aims, along with updates on the impact of your work
  5. professional services – including details of the professional services that we offer, such as training and publications

We will never share or sell your personal data to a third-party organisation for its marketing, fundraising or campaigning purposes.

You can withdraw your consent, unsubscribe from or update your marketing preferences at any point using the details in the ‘Contact us’ section below.

Any electronic communications, such as emails, will have a link to unsubscribe from future electronic communications, so you can manage your own communication preferences.

If you make any changes to your consent, we will update your record as soon as we possibly can. It may take up to 60 days for our systems to update and stop any postal communications from being sent to you. Email communications will, however, be stopped immediately. If you tell us you do not wish to receive marketing emails you may still receive transactional and service-based communications confirming and servicing other relationships you have with us (as described below).

Administrative communications

In addition to marketing communications you receive we will also communicate with you by post, telephone, and email in relation to administrative and transactional matters. For example, we will call you after you have set up a Direct Debit to confirm your details, and upon cancellation.

As mentioned above, we may still need to communicate with you for administrative purposes even where you have opted out of marketing communications from us.

Customer research and analysis

We may use profiling and database segmentation techniques to analyse your personal information, and create a profile of your interests and preferences.  This allows us to ensure communications are relevant and timely, to provide an improved experience.

Under data protection legislation, you have the right to object to your data being processed in this way.

Buying from Housing Rights

When you purchase an item from us online we will collect certain information from you – including your name, address, phone number, email address and payment details. We may use this to contact you if we have any queries regarding your purchase. Please note we use Paypal to administer payments of products purchased online

 Where you have purchased an item we may contact you again about similar products or services. We will always give you the opportunity to opt out of receiving further communications of this nature.

Visiting our website

We use cookies to tailor your browsing experience and ensure we show you more relevant information. If you don’t want cookies, you can set your browser to notify you when you receive one, then choose to decline it. Please read our Cookies Policy which is on our website for more information.

Applying for a job with Housing Rights

When you apply for a job with us, your personal data will be collated to monitor the progression of your application, and the effectiveness of the recruitment process through the statistics collected. Where we need to share your data – such as for gathering references, obtaining Access NI checks (depends on the role), or a prison clearance (depends on the role) – you will be informed beforehand, unless the disclosure is required by law. These checks are only done after a position has been offered only to the successful candidate. On the application form, you are asked to complete the referee details, and can tick permission to contact referee. If you tick yes, once offered a role, we will automatically send out reference requests. If you tick no, we will contact successful candidates for permission first.

Personal data about unsuccessful applicants is held for 12 months after the recruitment exercise is complete for that vacancy. You, as an applicant, can ask us to remove your data before this time if you do not want us to hold it. During this time, if you have been made a reserve for a post and we feel there is another suitable vacancy available, we will contact you when the vacancy arises.

Once you have taken up employment with Housing Rights, we will compile a file relating to your employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to your employment. Once your employment with us has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it from our files.

Professional contacts

We may collect data about professional contacts and partners with whom we work, or to whom we provide professional services – such as training or publications. Personal data collected in this way will be processed in accordance with data protection legislation and this policy.

We may send our professional partners information and updates about our work (primarily by email). Such contacts can opt out of receiving this information at any time.

We maintain a record of information related to MPs and other holders of public office, to enable us to undertake our campaigning activity in furtherance of our charitable aims. This will include keeping a record of contact details such as address, telephone number and email address as well as publicly available voting records and committee and group memberships.

Our legal basis for processing personal data

We need a lawful basis to collect and use your personal data under data protection law. The law allows for six ways to process personal data (and additional ways for sensitive personal data). The four ways that Housing Rights processes personal data are highlighted in bold.  This includes information that is processed on the basis of:

A a person’s consent (for example, to send you direct marketing by email or SMS)

B  a contractual relationship (for example, to provide you with goods or services that you have purchased from us)

C processing that is necessary for compliance with a legal obligation (for example to process a Gift Aid declaration)

D Vital interests,  to protect someone’s life

E Public task-the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individuals’ personal data which overrides those legitimate interests. 

F Housing Rights legitimate interests (please see below for more information)

Personal data may be legally collected and used if it is necessary for a legitimate interest of the organisation using the data, if its use is fair and does not adversely impact the rights of the individual concerned.

When we use your personal information, we will always consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair. Our legitimate interests include:

  • Charity Governance: including delivery of our charitable purposes, statutory and financial reporting and other regulatory compliance purposes.
  • Administration and operational management: including responding to solicited enquires, providing information and Housing Rights services, research, events management, the administration of volunteers and employment, and recruitment requirements

If you would like more information on our uses of legitimate interests, or to change our use of your personal data in this manner, please get in touch with us using the details in the ‘Contact us’ section below.

Disclosure of your personal data

We will not share any of your personal data to any third party – except where:

  1. the transfer is to a secure data processor, which carries out data processing operations on our behalf (please see section 13 for more information)
  2. we are required to do so by law, for example to law enforcement or regulatory bodies where this is required or allowed under the relevant legislation
  3. it is necessary to protect the vital interests of an individual
  4. we have obtained your consent

We will never share or sell your personal data to a third-party organisation for marketing, fundraising, or campaigning purposes.

Security of your personal data

We use appropriate technical and organisational measures and precautions to protect your personal data and to prevent the loss, misuse or alteration of your personal data.

Our case management system, Advice Pro is a centralised, secure web based application and it is hosted within the UK.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Transfers of data outside of the European Economic Area

We use Microsoft Office 365 and Azure products, which are multi-tenant cloud services, for our internal office use. This means that internal documents and information generated by us are stored in cloud services hosted within the European Economic Area (EEA).

Retention of your data

Whatever your relationship with us, we will only store your information for a specified amount of time and no longer than necessary.

The length of time that data will be kept may depend on the reasons for which we are processing the data and on the law or regulations that the information falls under, such as financial regulations, Limitations Act, Health and Safety regulation etc., or any contractual obligation we might have – such as with government contracts or if we have a business case, such as with research data. For business case data, we will anonymise the data so no individual is identifiable.

Subject to the above, we will typically store data relating to people to whom we provide services to for a maximum of seven years after completion of those services. Personal data about unsuccessful applicants are held for 12 months after the recruitment exercise is complete for that vacancy.

Once the necessary retention period has expired, the information will be confidentially disposed of or permanently deleted.

If you request to receive no further contact from us, we will keep some basic information about you on our suppression list to avoid sending you unwanted materials in the future.

Your rights

You have many rights under data protection legislation. These include:

  1. Right of Access

You have the right to know what information we hold about you and to ask, in writing, to see your records.

We will supply any information you ask for that we hold about you as soon as possible, but this may take up to 30 days. We will not charge you for this other than in exceptional circumstances. You will be asked for proof of identity as the person dealing with your request may not be the staff member you have met before. We need to be sure we are only releasing your personal data to you.

This is called a data subject access, and can be done by:

  • emailing una@housingrights.org.uk or telephoning 90 245640
  • writing to the Data Protection Officer, Housing Rights, Middleton Buildings, 10-12 High Street, Belfast BT1 2BA
  1. Right to be informed

You have the right to be informed how your personal data will be used. This policy, as well as any additional information or notice that is provided to you either at the time you provided your details, or otherwise, is intended to provide you with this information.

  1. Right to withdraw consent

Where we process your data based on your consent (for example, to send you marketing texts or emails), you can withdraw that consent at any time. To do this, or to discuss this right further with us, please contact us using the details in the ‘Contact us’ section below.

  1. Right to object

You also have a right to object to us processing data where we are relying on it being within our legitimate interests to do so (for example, to send you direct marketing by post). To do this, or to discuss this right further with us, please contact us using the details in the ‘Contact us’ section below.

  1. Right to restrict processing

In certain situations, you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage.

  1. Right of erasure

In some cases, you have the right to be forgotten (i.e. to have your personal data deleted from our database). Where you have requested that we do not send you marketing materials, we will need to keep some limited information to ensure that you are not contacted in the future.

  1. Right of rectification

If you believe our records are inaccurate, you have the right to ask for those records concerning you to be updated. To update your records, please get in touch with us using the details in the ‘Contact us’ section below.

  1. Right to data portability

Where we are processing your personal data because you have given us your consent to do so, you have the right to request that the data is transferred

Contact Us

If you have any questions about this policy, would like more information, or want to exercise any of the rights set out in this notice you can get in touch with us in the following ways:

  1. Email una@housingrights.org.uk
  2. Call 02890 245640