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Privacy Policy

Introduction

We are committed to protecting and respecting all of your personal data that you share with us. This is in line with the General Data Protection Regulation 2018 (GDPR) and the Data Protection Act 2018 (DPA), to ensure we use your information correctly. This privacy notice only applies to our website and does not cover the links within this site to other websites. If you click a link and it takes you to another website you should read and understand the privacy notice of that website as it may be different to ours. 

We are responsible for making decisions about the way the information we collect about you is used and this notice describes what types of data we collect from you, how we use it, how we share it with others, how you can manage the data we hold and how you can contact us. When referring to your ‘data’ we are referring to any information that identifies you as an individual. These identifiable categories will be discussed in more detail further down. We, as your Data Controller, are bound by the requirements of the GDPR. You agree that we are entitled to obtain, use and process the information you provide to us to enable us to provide the Services (as defined in our registration process when registering on our website) and for other related purposes.

How do we collect your data?

Our website uses cookies, online registration forms, account cookies and social media profiling. Any information you give us about yourself is handling in a secure way, and is not sold to third parties.  

What data do we collect?

We only collect data that is necessary, relevant and adequate for the purposes for which you are providing it. 

We collect data about you and your household when you use our website, including our panel solicitor and mortgage advisory service. The data we collect includes the following: 

When you use our online services such as registration forms:

  • The date and time you used our services
  • The pages you visited on our website and how long you visited them for
  • Your IP address (An IP or Internet Protocol Address is a unique numerical address assigned to your device (laptop, phone) as it logs on to the internet. We do not have access to any personal identifiable information and we would never seek this information. Your IP address is logged when visiting our site, but our analytic software (Google Analytics) only uses this information to track how many visitors we have from particular regions).
  • The internet browser and device you are using
  • Cookie information (for more information please see our Cookies Policy or visit www.aboutcookies.org and www.allaboutcookies.org).
  • The website address from which you accessed our website.
  • Internet Based Advertising: we use LinkedIn, Facebook and Twitter advertising services and as such, there are tracking codes installed on our website so that we can manage the effectiveness of these campaigns.  We do not store any personal data within this type of tracking.

We collect data about you and other members of your household when you first register your interest in buying a home from us and when you apply to live in one of our properties, including:

  • Name (including title)
  • Address (including former address(es)
  • Phone number(s)
  • Date of birth
  • Proof of identity and address documents
  • Email address(es)
  • Household information (including name(s), date(s) of birth, contact numbers);
  • Information about any disabilities or special requirements for you or other members of your household (where you have provided it)
  • Employment and earning
  • Deposit and savings
  • Details of any transactions between you and us
  • Any data within correspondence you send to us.

How do we use your data?

We will only process data that is necessary for the purpose(s) for which it has been collected, for example to send you details of properties in an area that you have told us you would like to buy a home in.

We process your data in order to create a profile of you

We analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. Where available from external sources (including social media, we make use of extra information about you to help us do this effectively. 

We process your data where you have given consent:

Where you have provided your consent, we use and process your data to:

  • Contact you from time to time about shared ownership and market sale housing developments which we think may be of interest to you (this won’t be a daily email notification)
  • Share your data with our recommended third party providers (such as mortgage advisors), so that they can contact you about their services (we will, of course, give you details about these third parties before you give your permission for us to send data to them).

You can withdraw your consent by ‘opting out’ at any time by using the unsubscribe option included in our emails, at any other time through our online portal or by getting in contact with us on the contact details below.

We process your data as it is in our legitimate interests

We use and process your personal data as set out below where it is in our legitimate interests as a business to do so. 

Processing necessary for us to support customers

  • To respond to correspondence you send to us and fulfil the requests you make to us.

Processing necessary for us to respond to understanding your needs

  • To analyse, evaluate and improve our services so that they are more useful (we will generally use data amalgamated from many people so that it doesn’t identify you personally)
  • To undertake analysis and research (including contacting you with customer surveys) so that we can better understand you as a customer and provide tailored services that we think you will be interested in
  • We will only send marketing communications to you if you have provided your consent for us to do so.
  • In some cases, we may use automated methods to analyse, combine and evaluate data that you have provided to us. We collect and analyse this data in this way so that we can continually improve our services for you 

Processing necessary for us to promote our activities and measure the reach and effectiveness of our services

  • To identify and record when you have received, opened or engaged with our website or electronic communications (please see our Cookies Policy for more information).

We process your data to ensure our services are efficient and useful

  • To verify the accuracy of data that we hold about you and create a better understanding of you as a customer
  • For network and information security purposes i.e. in order for us to take steps to protect your data against loss, damage, theft or unauthorised access
  • To comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request)
  • To inform you of updates to our terms and conditions and policies.

Our Legal Obligation

We process your personal data to comply with our legal requirements (e.g. to comply with the regulatory requirements of the Regulator of Social Housing).

When you provide us with personal information, we take steps to ensure it is handled securely. Any sensitive information (such as credit card details) is encrypted and protected with 128 Bit encryption software on SSL. You can see that you are on a secure page as a lock icon will appear on the bottom of your web browser. 

Non-sensitive details (such as your email address) are sent through your web browser, which means this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Fraud detection

  • We use data shared with us for the purpose of preventing and detecting fraud. 
  • Any personal data shared with us can be used for the purpose of preventing and detecting fraud. This includes information provided on our website, on the My Account area, or in any other way provided to us online or not.
  • The data collected can be used for the purpose of data matching and for further investigations. This involves comparing the data we hold on you with that held by third parties solely for the purpose of detecting and preventing fraud. We also use your data to further investigate fraud that we think might have been committed. 
  • This involves checking with various third parties, such as the Land Registry, banks, schools and utility companies. 

How do we share your data?

  • We do not sell your data to third parties.
  • We do work closely with our partner organisations who deliver services with us (such as mortgage applications, legal conveyancing, satisfaction surveys and market research etc.)
  • We disclose your data to legal and other professional advisors who you have instructed on the purchase of a home from us.
  • When submitting forms on our website we use a third-party software provider for automated data collection and processing purposes, they will not use your data for any purposes and will only hold the data in line with our policy on data retention.
  • We will also share your data in situations where we need to pass it on to manage any request or complaint you have made to us. For example, we will share details of any complaint with the Housing Ombudsman Service.
  • We take steps to ensure that any third-party organisations who handle your data comply with data protection legislation and protect your data just as we do. We only disclose personal data that is necessary for them to provide the service that they are undertaking.
  • We will anonymise your data or use aggregated non-specific data sets wherever possible.
  • We sometimes put YouTube videos on our website. If you watch any, YouTube process information about your activity, including cookie data, the video you watched, about your device, your IP address and location. You can view Google’s privacy policy here, which covers YouTube.
  • We have links to our social media accounts on our website, and our Twitter feed can be seen from our site. When you are interacting with our social media platforms including Twitter, Instagram and Facebook their own policies apply.
  • Google Analytics is a third-party information storage system that records information about the pages you visit the length of time you were on specific pages and the website in general, how you arrived at the site and what you clicked on when you were there. These cookies do not store any personal information about you e.g. name, address etc. and we do not share the data. You can view their privacy policy here
  • If you choose to register for and use ‘My account’, Blubrik’s software used for this self-service portal relies on the use of session cookies and will store your data in their encrypted database, this will only be used during your application process.
  • We use external companies to deliver certain areas of our business to fulfil our obligations as a landlord. This includes our website provider, Full Communications, who also serve the Greater London Authority’s online portal. If you consent, they will use your data to send you emails which are relevant to you and advertise properties to you which are relevant to your preferences. 

To achieve our stated purpose we will need to transfer personal data to third parties. The third parties we share personal data obtained on the website with are:

  • Google analytics and tools
  • Online appointment booking system; 
  • Full Communications 

We’ll only share the minimum information necessary for the contractor to carry out their services on our behalf. We’ll never sell personal information to a third party. When using our website, including when cookies are enabled, the below organisations will be a recipient of your data:

  • Our employees;
  • Google Analytics;
  • Full Communications;
  • Blu Brik Customer Relationship Manager.

How we safeguard your personal information

We take appropriate measures to prevent the loss, misuse or alteration of your personal information. We store your personal information on our secure servers, which have access control. We use a firewall, have in-house data controllers and our website is secured by encryption. The third parties we share your personal data with comply with current EU legislation and you can visit their websites to find out about their privacy policies.

How long do we keep your data for?

  • We have a data retention policy which sets out how long we keep different types of information for.
  • We follow legal requirements and best practice. Please contact us if you’d like to understand how long we retain your data for.
  • We are happy to erase your data in line with your right to erasure if the correct conditions are met.
  • For marketing purposes, we will hold your data for a period of six years with a review every three years.  You will have the opportunity to opt out or ask us to update or delete data at any point should you need to do so.

How you can manage the data we hold about you

These are your rights as an individual whose personal data we process, if you’d like to speak with us about this, please contact us.

  • Right to be informed: in this privacy notice we let you know how we use your personal data through our website.
  • Right of access: if you want to find out more about the personal information we have about you, you can make a subject access request.
  • Right to rectification: you can let us know that we’ve got incorrect or incomplete information about you, so that we update it and we’ll let you know we’ve done so.
  • Right to be forgotten: you can ask us to get rid of personal information we have about you unless we have reasonable grounds to refuse to get rid of it. If you’d like to find out what these grounds are, please use the contact form.
  • Right to restrict processing: if you ask us to stop processing your data, we’ll only keep the amount of personal data about you that we need to make sure no more processing happens.
  • Right to data portability: in some cases you can ask for a copy of your personal data and for it to be sent to another data controller.
  • Right to object: unless we have good enough legitimate grounds for processing your data, you can object to us processing it.
  • Rights with respect to automated decision-making and profiling: automated decisions and automated processing of personal data to evaluate certain things about you
  • Right to report a concern: you can report a concern to the Information Commissioner’s Office here.

Complaints

  • If you feel we haven’t handled your personal data properly, you can log a complaint with us by emailing complaints@originhousing.org.uk or by calling 0300 323 0325. 
  • You can also contact the Information Commissioner’s Office for advice on your rights.

Changes to our privacy notice

We keep our privacy notice under regular review and we will place any updates on this web page.  This privacy policy was last updated on 24 May 2018 and the version number is one, in line with the new GDPR guidelines.

How to contact us

Origin Housing is the data controller for all personal data captured and processed on originhousing.org.uk. You can contact us about data protection on 0300 323 0325, email dpo@originhousing.org.uk or you can write to us at:

Origin Housing
St Richards House
110 Eversholt St
London
NW1 1BS

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