How we use your personal information
We want you to know that when you use our organisation you can trust us with your information. We are determined to do nothing that would infringe your rights or undermine your trust. This notice explains what information we collect, when we collect it and how we use this. During the course of our activities we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will handle your information.
Who are we?
Apex Housing Association are registered as a Data Controller with the Information Commissioner’s Office (ICO) under registration number Z5150579 and we are the data controller of any personal data that you provide to us.
We take the issue of security and data protection very seriously and strictly adhere to guidelines published in the Data Protection Act of 1998 and the General Data Protection Regulation (EU) 2016/679 which is applicable from the 25th May 2018, together with any domestic laws subsequently enacted.
Any questions relating to this notice and our privacy practices should be sent to:
How we collect information from you and what information we collect
The vast majority of information that we hold about you is provided to us by yourself when you seek to use our services.
The General Data Protection Regulation (GDPR) requires all organisations that process personal data to have a Lawful Basis for doing so. The Lawful Bases identified in the GDPR are:
- Consent of the data subject
- Performance of a contract with the data subject or to take steps to enter into a contract
- Compliance with a legal obligation
- To protect the vital interests of a data subject or another person
- Performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
- The legitimate interests of ourselves, or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject
We collect information about you:
- when you apply for housing or care/support services with us, become a tenant, request services/ repairs or otherwise provide us with your personal details;
- from your use of our online services, whether to report any tenancy, repair issue, make a complaint or application or otherwise;
- from your arrangements to make a payment to us (such as bank details, payment card numbers, employment details, benefit entitlement and any other income and expenditure related information);
We collect the following information about you:
- telephone number;
- e-mail address;
- National Insurance Number;
next of kin;
- date of birth;
- social and economic information;
- Tenants/residents within supported living schemes – information relating to your health and social services involvement (if relevant)
- FairShare applicants – residential status; financial and current employment status and details
We may receive the following information from third parties:
- Benefits information, including awards of Housing Benefit/ Universal Credit;
- Payments made by you to us;
- Complaints or other communications regarding behaviour or other alleged breaches of the terms of your tenancy agreement with us, including information obtained from PSNI or other government agencies;
- Occupational Therapist reports in relation to medical adaptations;
- Tenants/residents within supported living schemes – information relating to your health, care and support and social services involvement;
- FairShare applicants – credit history information.
Why we need this information about you and how it will be used
We need your information and will use your information:
- to undertake and perform our obligations and duties to you in accordance with the terms of our contract with you;
- to enable us to supply you with the services and information which you have requested;
- to enable us to respond to your repair or adaptation request, housing application, care and support needs and investigate and respond to complaints made;
- to analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer;
- to contact you in order to send you details of any changes to our services which may affect you;
- to contact you for your views on our products and services;
- to provide care and support services to you as identified and agreed under your assessed needs;
- for all other purposes consistent with the proper performance of our operations and business.
- Analyse site visits and trends
- Determine the frequency of accessing our content
- Validate users
- Remember user preferences and setting
Sharing of your information
The information you provide to us will be treated by us as confidential and will be processed only by our employees within the European Economic Area.
To assist with the management of our activities, your information may be shared with associated companies and subsidiaries within the Apex Housing Association group, including Fairbuild Homes (NI) Limited and Apex Housing Association (Ireland) Limited.
We may disclose your information to other authorised third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:
- If we instruct repair, maintenance or adaptation works, your information may be disclosed to a consultant or contractor;
- If you are requesting a transfer or direct exchange of property, your information may be disclosed to other housing providers, local health & social care services;
- In relation to payments made or otherwise, your information may be disclosed to payment processors, N.Ireland Housing Executive; N.Ireland Housing Federation Association;
- If we are conducting a survey of our products and/ or service, your information may be disclosed to third parties assisting in the compilation and analysis of the survey results;
- In relation to the completion of house sales, your information may be disclosed to authorised surveyor or solicitors;
- If we are receiving payments from Supporting People or the Benefits Agency on your behalf, your information may be disclosed to these organisations in order to claim relevant benefits;
- If we are investigating a complaint, information may be shared with relevant regulatory bodies and local Health & Social Care Trusts and/or PSNI (depending on the nature of the complaint). Information may also be shared with mediation services, community safety wardens, NI Ombudsman and others involved in any complaint, whether investigating the complaint or otherwise;
- If we enter into a joint venture with or merged with another business entity, your information may be disclosed to our new business partners or owners;
- In meeting our legal obligations we may be required to share information with law enforcement officials, government authorities or other third parties;
- In the event of a dispute we may share information with our legal advisors;
Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.
Transfers outside the UK and Europe
Your information will only be stored within the EEA.
When you give us information we take all necessary steps to make sure that your personal information is kept secure and safe.
How long we will keep your information
We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you. After which this will be destroyed if it is no longer required for the reasons it was obtained.
Our full retention schedule is included in our Data Protection Policy and is available by contacting:
The General Data Protection Regulation gives you specific rights around your personal data.
You have the right at any time to:
- ask for a copy of the information about you held by us in our records;
- require us to correct any inaccuracies in your information;
- make a request to us to delete what personal data of yours we hold; and
- object to receiving any marketing communications from us.
If you would like to exercise any of your rights above please contact us at: DataProtection@apex.org.uk
You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information. The Information Commissioner’s contact details are noted below:
Information Commissioner’s Office – N.Ireland
14 Cromac Place
Tel: 028 9027 8757 or 0303 123 1114
You can find out more information from the ICO’s website
The accuracy of your information is important to us – please help us keep our records updated by informing us of any changes to your email address and other contact details