Our privacy statement describes the categories of personal data we process and for what purposes. We are committed to collecting and using such data fairly and in accordance with the requirements of the General Data Protection Regulations (GDPR).
1.1. We take your privacy seriously and you can find out more here about your privacy rights and how we collect, use, share and secure your personal identifiable information that includes the personal identifiable information that we already hold about you now and the further personal information we might collect about you, either from you or from a third party. How we use your personal information will depend on the products and services that we provide to you.
1.2. This privacy notice is a public document available to anyone when any member of the First Ark Group obtain and use their personal identifiable information This includes: Knowsley Housing Trust, Vivark, One Ark, KHTS, Oriel, First Ark Social Investment and First Ark Limited (as well as brands such as Vivark Care and Oriel Lifestyle). It explains how we and appointed third party organisations / people use your personal identifiable information. We obtain your personal identifiable information in order to conduct our normal business operations.
1.3. Our Mandatory Data Protection Officer (DPO) provides help and guidance to make sure we apply the law to the processing and protection of your personal identifiable information. If you have any questions about how we use your personal information the Groups’ DPO can be contacted by email at firstname.lastname@example.org or by post at First Ark, Lakeview, Kings Business Park, Prescot, L34 1PJ.
See section 3 Your Privacy Rights for more information about your rights and how our DPO can help you.
1.4. This privacy notice provides up to date information about how we use your personal information and replaces any previous notices that we have published about using your personal identifiable information. We will make changes to this Privacy Notice if we make any significant changes affecting how we use your personal identifiable information.
- Who we are
2.1. The First Ark Group are a ‘Group’ of companies in this Privacy Notice, we mean other members of our ‘Group’ of companies, including holding and subsidiary companies we mean:
2.2 The First Ark Group are a ‘data controller’ of your personal identifiable information as we determine the use of this information.
- Your privacy rights
3.1 You have eight rights:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling
3.2 In brief you have the right to be informed who is obtaining and using your personal identifiable information, how this information will be retained, shared and secured and what lawful grounds will be used to obtain and use your personal identifiable information. You have the right to object how we use your personal identifiable information in certain circumstances. You also have the right to obtain a copy of the personal identifiable information we hold about you. In addition, you can ask the Group to correct inaccuracies, delete or restrict personal identifiable information or to ask for some of your personal identifiable information to be provided to someone else. You can make a complaint if you feel that the Group is using your personal identifiable information unlawfully and/or holding inaccurate, inadequate or irrelevant personal identifiable information which if used may have a detrimental impact on you and /or has an impact on your rights.
3.3 You can also make a complaint to the data protection supervisory authority, where your personal identifiable information is being held and processed. Where your personal identifiable information in held and processed in the UK, you can complain to the Information Commissioner’s Office, at www.ico.org.uk
3.4 To make enquiries for further information about exercising any of your rights in this privacy notice, then please contact email@example.com, or First Ark, Kings Business Park, Prescot, L34 1PJ or visit any of the Group websites e.g. www.firstark.com
4 What kinds of personal identifiable information we use
4.1 We use a variety of personal identifiable information depending on the products and services we deliver to you. For all products and services, we need to use your and any occupant of your home:
- Contact details – name, address, email, home and mobile telephone numbers;
- Age – date of birth;
- Identification – information to allow us to check your identity;
- Credit information – information about your credit history;
- Photograph – information to record your identity;
- On-line computer identification (IP address) – information recorded when you engage with us by email;
- National insurance numbers – information to carry out functions such as universal credit and/ or supporting people contracts;
- Next of kin
There are other types of personal information which we do not collect for the occupants of your property unless they have a direct relationship with us (e.g. applied for housing in their own right or obtain services from us directly):
- Telephone contact details
- Health – to support our housing functions and vulnerable customers;
- Race – to support our equality monitoring purposes;
- Ethnic origin – to support our equality monitoring purposes;
- Religion - to support our equality monitoring purposes;
- Sexual life; or sexual orientation to support our equality monitoring purposes;
- Convictions – to prevent and detect crime, fraud, anti-money laundering and to aid in the prosecution and rehabilitation of offenders.
There are other types of special information which we do not collect but are deemed important under the law:
- Trade union membership;
- Biometrics (where used for ID purposes)
4.2 Sometimes where we ask for your personal identifiable information to enter into a contract/agreement with you (for example tenancy, lease, application, support and/or care plan agreement) or to meet our legal or regulatory duties (for example to process housing, council tax benefit, equality monitoring and/or government or housing regulator reports), we will not be able to provide some of our housing, support or products or services without this information.
- How we gather your personal identifiable information
5.1 We obtain personal identifiable information by various means, this can be by face to face, email, telephone, text message, correspondence and or by receiving this information from others for example, a local elected member who is representing you, police, health or social care agencies and benefit agencies. We can also receive information about you from other people you know and/or are linked to you, for example a relative, a person nominated to act on your behalf or your legal representative. Some further examples are below:
- Directly from you, for example when you fill out an application, transfer or mutual exchange form or as part of your right to buy application;
- By observing how you use our housing, support, products and services, or those of other members of the First Ark Group, for example from the transactions and operation of your accounts and online services;
- From other organisations such as former housing and support providers, health and social care agencies, law enforcement agencies, debt collectors, energy or utility companies, benefit agencies and/or credit reference and fraud prevention agencies;
From other people who know you, including joint account holders and people you are linked you or live in the same community as you in regards to reports of anti-social behaviour;
- From monitoring or recording calls as part of quality and complaint monitoring. We record these calls for training and to ensure safety of our staff. We will not record any payment card details as part of our accounts and payments operations;
- From the CCTV systems for the prevention and detection of crime or to detect damage/ vandalism to our properties and to ensure the safety and security of our staff and individuals obtaining services from us.
- How we lawfully use your personal information
6.1 To provide you with our housing services we have a legal duty to confirm a person(s) have the right to reside in the country. We will need to obtain your name, contact details, date of birth, your current and previous countries of residence/citizenship, and a copy of identification documents (such as passport, home office residence papers and driving license).
6.2 We might also need health and social care information (such as physical, social or mental health information or medication) to help support our customers who have a vulnerability and/or receive
a support or care service from us.
6.3 We sometimes need to gather, use and share your personal identifiable information for particular reasons, which are set out in more detail below:
To operative and administer our housing, support and care products and services, including managing and responding to complaints:
Contact and occupation information with third parties who help us deliver our repairs, support, care and housing services. For example our repairs contractors and their appointed sub-contractors.
We use your personal identifiable information in this way because it is necessary to meet the conditions set out in the contract/agreement with you and/or to meet our legal or regulatory obligations.
To administer payments to and from your accounts or other agencies (e.g. benefit agency):
- Contact and occupation information with benefit agencies and financial advisors who as agencies or financial organisations help us to process payments to your account(s)
- To supply our appointed financial advisors information to carry our home ownership affordability tests to advise on the suitability of a mortgage;
- To prevent financial crime including money laundering, benefit fraud or illegal subletting;
We use your personal identifiable information in this way because it is necessary to meet the conditions set out in the contract/agreement with you and/or our legal and regulatory obligations.
To carry out our duties under Health & Safety and to support our vulnerable people;
- Vulnerability indicators with contractors and sub-contractors to ensure services are tailored to meet your needs
- Concerned / warning / be aware indicators with contractors and sub-contractors to ensure health and safety measures are in place. We would have informed you of this indicator and when will be applied and for how long e.g. a warning marker is applied when for a tenant with a mobility restriction, to ensure that sufficient time is given for the tenant to answer the door.
We use your personal and special identifiable information in this way because it is necessary to meet the conditions set out to meet our legal and regulatory obligations in regards to health and safety
To report or share information with agencies where it is believed you or other persons’ vital interests are at risk:
- Where you or another person is at risk of physical, mental, sexual, harm or damage.
- Where you or another person is in need of being protected as a vulnerable person from significant harm or serious exploitation
We use your personal and special identifiable information in this way because it is necessary to meet our legal and regulatory obligations and to protect your and others vital interests.
To carry out our lettings and home ownership affordability assessments and former debt decisions about you:
- Information you give about your former addresses will be used to carry out a credit history check with approved suppliers (e.g. Experian). No credit ‘footprint’ will be left as part of this process.
- Information about those you are linked with in the proposed agreement or contract with us, for example a joint tenant or owner.
- Information about how you or the person linked to you has former debts owing to us or other landlords
For this purpose, we share and receive information with and from banks, building societies, credit reference and fraud prevention agencies. The credit fraud prevention agency might add details of our search to the records they hold about you, whether or not your engagement with us proceeds.
- Automated decision making
7.1 Sometimes we use your personal information in automated processes to make decisions about you, such as credit scoring. We might also use automated processes to create a profile of you. We do this to help ensure decisions are made accurately, fairly and efficiently and to offer you products and services tailored to you. We have informed you that we were part of the Experian ‘Rent Exchange Scheme’ and share information as:
- Information about you to Experian as part of the ‘Rent Exchange Scheme’
- Our legal basis for using your personal information
8.1 We only use your personal information where it is permitted by the laws that protect your privacy rights. We only use personal information where:
- We need to use the information to comply with our legal obligations;
- We need to use the information to perform a contract with you; and/or
- It is fair to use the personal information either in our interests or someone else’s interests, where there is no disadvantage to you – this can include where it is in our interest to contact you about products or services, market to you, or collaborate with others to improve our services;
- Where we need to seek your consent (if consent is needed);
Where we have your consent, you have the right to withdraw it. We will let you know how to do that at the time we gather your consent. See section 12 ‘Keeping you up to date’, clause
12.2 for details about how to withdraw your consent to marketing.
8.2 Special protection is given to certain kinds of personal information that is particularly sensitive. This is information about your health status, racial of ethnic origin, political views, religious or similar beliefs, sex life or sexual orientation, genetic or biometric identifiers, trade union membership or criminal convictions or allegations. We will only use this kind of personal information where:
- We have a legal obligation to do so (e.g. to protect vulnerable people);
- It is necessary for us to so do to protect your vital interests (e.g. if you have a severe and immediate medical need whilst on our premises);
- It is in the substantial public interest;
- It is necessary for the prevention or detection of crime;
- It is necessary for insurance purposes; or
- You have specifically given us ‘affirmative’ consent to use the information.
- Sharing your personal information with or getting your personal information from others
9.1 We will share your personal information with the First Ark Group and with others outside the Group where we need to do that to make products and services available to you, market products and services to you, meet or enforce a legal obligation or where it is fair and reasonable for us to do so. See section 6 ‘How we use your personal identifiable information’ for more information on who we share your personal identifiable information with and why.
9.2 Who we share your personal information with depends on the products and services we provide to you and the purposes we use your personal information for. For most products and services we will share your personal information with our own service providers such as our IT suppliers, with credit reference agencies and fraud prevention agencies, See section 6 ‘how we use your personal information’ for more information on who we share your personal information with and why.
9.3 Most of the time the personal information we have about you is information you have given to us, or gathered by us in the course of providing products and services to you. We also sometimes gather personal information from and send personal information to third parties where necessary for credit checking and fraud prevention or marketing purposes, e.g. so you can recent the best offers from us and our partners. See section 6 ‘how we use your personal information’ for more information on who we share your personal information with and why.
- Transfers outside the UK
10.1 We do not transfer any personal information outside of the EEA.
- How long we keep your personal information for
11.1 How long we keep your personal information for depends on the products and services we deliver to you. We will never retain your personal information for any longer than is necessary for the purpose we need to use it for.
- Keeping you up to date
12.1 We will communicate with you about products and services we are delivering using any contact details you have given us e.g. by post, email, text message, social media, and notification on our app or website.
12.2 Where you have given us consent to receive marketing, you can withdraw consent and update your marketing preferences by contacting us by phone 0151 290 7000, email firstname.lastname@example.org or by visiting any of our websites.
- Your online activities
13.2 Find out more about cookies, by visiting any of our websites.
Lakeview, Kings Business Park
Prescot, L34 1PJ
t: 0151 290 7000