Privacy Policy

When we say ‘we’ or ‘us’ in this document we’re generally referring to those companies which form part of the Abri Group of Companies, of which Abri Group Limited is the parent company, namely:

• Abri Group Ltd
• The Swaythling Housing Society Ltd

These organisations are data controllers and in this Privacy Notice are collectively known as Abri.

We collect and process a range of data about you. Depending on the relationship we have with you, this may include:

• Name,
• Date of birth
• Current, previous and forwarding addresses
• Telephone numbers and email addresses,
• Next of Kin details (for use in emergencies)
• Your authorised contact details (when you have provided us with an authorisation to discuss your tenancy with certain other trusted individuals)
• Employment details and state benefit entitlements
• National Insurance number
• Records of anti-social behaviour (for more information please contact us and ask for a copy of our Anti-Social Behaviour Policy)
• Records relating to your interactions with our staff (including telephone recordings)
• Information concerning your obligations to us as our tenant or lessee, including rent payments and arrears, or service charges, and compliance with your tenancy contract or lease agreement
• Information concerning your welfare and ability to live independently at home
• Particular needs or conditions that our staff should be aware of when visiting your home
• Other agencies involved with your household
• Details of safeguarding risks to children or vulnerable adults (for more information please contact us and ask for a copy of our Anti-Social Behaviour Policy)
• Financial details – bank or building society account details to enable Direct Debit payments
• Responses to surveys
• Photos
• Copies of ID document

We also process special categories of information (sometimes called ‘sensitive information’) that enable us to provide services that will meet your needs, protect your interests, and also to comply with our legal obligations under Equalities Legislation. These special categories may include:

• Physical or mental health and disability details, any special adaptation needs you may have as a result of these, and your role as a carer for others in the household.
• Criminal offences, alleged criminal offences, and unspent convictions
• Equalities data, including ethnic origin, religious belief, sexual orientation and transgender status

The CCTV systems installed across our buildings and sites are for safety and crime prevention only. Clearly visible notices are provided where CCTV is used, except in the rare instances where covert CCTV is in place (directed away from public spaces) for legitimate legal reasons i.e. in cases of ongoing serious ASB, domestic violence or other criminal actions perpetrated against a particular household. The reception area and interview rooms of certain Abri corporate buildings have CCTV and optional voice recording facilities which will only be activated with your knowledge (usually by use of notices).

CCTV images can be shared with lawyers, police and other agencies working to prevent or investigate crime, improve public safety or resolve antisocial behaviour.

CCTV images may also be shared with insurance companies for the purpose of determining liability for damage or harm caused by an incident involving those shown in the footage.

CCTV images are also retained for up to eight weeks or, until enforcement action is complete, and images that are no longer required will be destroyed.

We collect information about you throughout our relationship. This includes:

• When you apply for a home
• When you sign a tenancy, shared ownership, lease or tenancy exchange agreement
• Through ongoing contact with you during a tenancy or lease
• When you access services by logging onto our website or customer portal
• Recording information from calls and on-line chats with us
• When you terminate a tenancy or the resale process
• If you make a complaint
• When dealing with anti-social behaviour (ASB) issues, which you or one of your neighbours has raised
• When we provide welfare & benefits advice or support
• When you respond to our surveys
• If you get involved with residents’ scrutiny discussions

In some cases, we may collect information about you from third parties, such as your next of kin or authorised contacts, local authorities (eg social services or occupational therapists), landlords, medical and health services, the police or neighbours (in the case of complaints or concerns raised about you).

We process personal information to enable us to manage our business of providing social and affordable housing, accommodation and services, which may include any of the following:

• Letting, renting, leasing and selling properties (including shared ownership, right to buy and right to acquire)
• Managing tenancies and leases
• To facilitate tenant mobility by enabling mutual exchange of rented properties
• Maintaining and repairing our rented or leased properties
• Collecting and receiving rent (including arrears), service charges and charges for additional services;
• Administering waiting lists
• Providing certain welfare and benefit related services, advice and support
• Maintaining our accounts and records
• Provision of customer service
• Ensuring that our properties are kept in good order
• Training and monitoring service provision
• Monitoring and resolution of anti-social behaviour and disputes
• Safeguarding of children and vulnerable adults who live in or nearby our properties
• Ensuring the protection of our staff, contractors and those other tenants or visitors to our properties who may be affected by criminal or anti-social behaviour
• Investigating complaints
• Providing education, employment and training advice (through our associated company, I2A)
• Providing independent and supported living services
• Fraud and money laundering prevention.
• Processing requests from third parties dealing with e.g. council tax, shelter, homelessness
• Better understanding your needs and those of our other tenants or people who will live in proximity to you
• For ensuring that our staff are always properly informed and equipped to provide the services you are entitled to receive, in a way that addresses both your needs and theirs.
• Making organisational improvements
• Engaging with our customers to get feedback on our current services and any improved or expanded service offers which we may provide or procure from others for your benefit in future
• Providing details of promotions, opportunities and special offers which may be of interest to you (with your consent, where appropriate)
• Getting in touch with you via phone, email, post or the customer portal
• Complying with our legal obligations, including health and safety.
• Managing legal risk and obtaining legal advice/representation where necessary
• Responding appropriately to public health emergencie

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

Where it is necessary to share information about you, we will always comply with all aspects of Data Protection Legislation. Set out below are examples of when this may occur.

Some of your information will be accessible by colleagues, with those parts of our organisation that are involved in supporting our services to you. Sometimes, we appoint third parties to do work for us which may involve them processing your data on our behalf.

Occasionally we need to share personal information we hold about you with others, including next of kin (particularly in emergencies or when we urgently need to carry out gas safety inspections and are struggling to fix an appointment with you), or with anyone who has been designated by you as authorised to receive information in specific circumstances, or to help you manage your account with us.

Sometimes, we may need to share your information with other organisations. We will only do so when reasonably necessary, and when we have a lawful basis, either because you have consented, or the Data Protection Legislation enables us to do so for another reason. Occasionally we share your information because we are compelled to do so, for example, because a court has ordered it, or because we have to do so under law. Where reasonably necessary and lawful, we may share certain information with:

• Contractors (who carry out repairs, safety work, maintenance and installations)
• Local authorities (including homelessness units, social services, occupational therapists and council tax depts)
• Agencies involved with benefits and tax credits (including the DWP and Pensions service)
• Organisations which provide educational and career-based training (always with your consent)
• Charities and voluntary agencies (always with your consent)
• Health services (including GP) (always with your consent, unless in case of a life-threatening emergency)
• Police and law enforcement agencies
• The Financial Conduct Authority and HMRC
• Probation services
• Emergency services
• Schools and examining bodies
• Anyone you have appointed as your authorised contact for management of your tenancy, or who is formally registered (by the Office of the Public Guardian) as your lawful attorney under a Lasting Power of Attorney.
• Designated Tenant Panel for review and resolution of formal complaints (always with your consent)
• Home service and care providers
• The NHS Trust which employs you if you rent accommodation from us connected to your work with the NHS.
• Other landlords (always with your consent, where a reference is being provided)
• Utilities companies
• Insurance companies
• Courts and tribunals
• The Regulator of Social Housing
• Central government departments
• Auditors
• Debt collection agencies
• Credit reference agencies, to facilitate social housing fraud checks
• Survey and research organisations
• Press and the media (always with your consent)
• Financial service providers and advisors
• Mortgage administrators and lenders
• Solicitors

We collect, use and occasionally share your information for reasons which are recognised as lawful. These include:

• the performance of: our landlord’s obligations under your tenancy, lease or shared ownership contract with us; or other service contract we may have with you.
• compliance with obligations imposed by law on us as landlords and as an organisation that processes financial payments;
• protecting the vital interests of our customers, staff or contractors when their life, health or well-being are seriously at risk;
• the performance of a task carried out in the public interest eg. safeguarding of children and vulnerable adults;
• our legitimate interest in:
  • preparing to enter into a contract with you (tenancy, shared ownership or lease) including all necessary due diligence and disclosure
  • taking due care of our housing stock,
  • ensuring that payment due for service charges, utility bills or council tax incurred while living in our housing is paid by our tenants, former tenants, lessees or former lessees
  • helping to make the communities where our tenants or lessees live safe and secure environments
  • protecting the viability of our business, so that we can continue providing affordable housing to people who need it
  • contributing to the government and local authority’s efforts to reduce homelessness within our communities
  • taking legal advice or bringing legal proceedings
  • ensuring that our staff are always properly informed and equipped to provide the services you are entitled to, in a way that addresses both your needs and theirs; and,
• When you have provided us with your consent, eg. to allow us to send you information about services and opportunities that might interest you as our tenants.

When we have collected sensitive information, we need additional special reasons for doing so and these might include:

• your express consent
• it is necessary for social protection, being intended to reduce risk to customers which flow from old age, ill-health or disability
• it is necessary for bringing or defending a legal claim
• it is in the substantial public interest, for example in respect of measuring and monitoring performance against equalities standards.

We will always keep your information in accordance with the law and regulation, and we’ll never keep your information for longer than is reasonably necessary.

Your basic tenancy or lease information (i.e. your name, date of birth and address while a tenant of any landlord within the Abri Group) will be stored permanently against any tenancies you have had with us but once your tenancy has ended, we aim to delete all other information six years after your tenancy has ended.

Recordings of standard telephone conversations are held for a period of time which will not exceed six months unless they are deemed abusive or threatening, or if they contain content which is relevant to an ongoing investigation, in which case they will be kept until all relevant investigation actions are complete.

We take the security of your data seriously, and we have internal policies, controls (electronic, physical and managerial) and procedures in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed unlawfully to others, and is only accessed by our colleagues in the proper performance of their duties. These security measures include:

• Limiting access to our building to those we believe are entitled to be there (by the use of key card passes and ID Badges)
• Implementing access controls to our technology and devices, such as firewalls, ID verification, and encryption.
• Implementing strict procedures which limit access to your data only to those staff or contractors who need to see it in order to carry out their jobs and/or deliver services to you.
• Never asking you directly for your passwords.

If you are registered with our customer portal, you are the owner of your username and password, you mustn’t share this information with anybody else.