Privacy notice

Identity and contact details of the Controller

bpha Limited is a Housing Association and is a Controller of personal information for the purposes of the UK General Data Protection Regulation (‘UK GDPR’) and Data Protection Act 2018.

Our contact details for data protection purposes are:

The Data Protection Officer,
Governance and Compliance,
bpha Limited,
Bedford Heights,
Manton Lane,
Bedford,
MK41 7BJ

Email data.protection@bpha.org.uk

bpha Limited is registered with the Information Commissioner’s Office (ICO) as a Controller, and our registration number is Z8574989.

Changes to our privacy notice

We keep our privacy notice under regular review to make sure it is accurate and up to date. We will let you know through our website and our customer Talk magazine if there are changes you need to be aware of.

This privacy notice is dated March 2025.

Our use of your information

To provide you with our services we collect and use the following essential personal information about you:

Information that identifies you

• Name
• Gender
• Date of birth
• National insurance number
• Identification documents like copies of passports and driving licences
• Photographs
• Passwords.

Contact information

• Addresses
• Telephone numbers
• Email addresses
• Emergency contact or next of kin information.

Financial information

• Rent and service charge payments
• Benefit entitlements and payments
• Income and expenditure
• Account details.

Household information

• Information about who lives in your home.

We may collect additional information to provide you with specific services, to measure equality, diversity and inclusion, or for statistical reporting:

Sensitive information (including special category information)

• Racial or ethnic origin
• Religious beliefs
• Health information including any disabilities
• Details of criminal activity and legal proceedings
• Immigration status.

Other types of information we collect

• How you use our services
• Customer feedback, including satisfaction surveys and complaints
• CCTV images
• Call recordings where you contact us through our Customer Communications Centre.

Payment card information

If you use a payment card to pay rent, service charge, or other bill, your card details are passed securely to our payment processing partner as part of the payment process. We do this in line with the Payment Card Industry Data Security Standards (PCIDSS), and we don’t see or keep your card details on our systems.

How we use your personal information

Data protection laws allow us to use personal information when we have a lawful basis to do so. We use information for the following reasons:

• To manage contracts you have, or will be entering into, with us, such as a tenancy agreement or lease
• To fulfil our legal obligations
• When you provide consent for us to use your information in a specific way. Where we use consent, you can withdraw your consent at any time by contacting us
• To act in the public interest
• To protect someone's vital interests, or to prevent serious harm to a person
• Where it’s in our legitimate interests, provided it does not unfairly affect your rights.

Our legitimate interests include:

• Fraud prevention
• Ensuring system security
• Promoting our services
• Advertising and marketing our homes
• Measuring customer satisfaction
• Monitoring how customers engage with our website and systems.

If we need to use sensitive personal information (special category information), such as health-related data, we will obtain your permission first, unless it's necessary for legal claims or there is a significant public interest, such as safeguarding someone from harm.

We use your personal information in different ways dependent on your engagement with us.

Applying for a home

When you apply for a home with us, we gather information about you and anyone else who will be living with you. We need this information to make sure you’re eligible for a home and to help us find a suitable place for you, and to prevent fraud. Not providing the necessary information could impact your application.

We will ask for information about where you live now, the type of home you are looking for, we may ask for evidence if you have any health conditions, medical needs, or special family circumstances that require specific accommodations (such as a ground floor flat).

To ensure you can afford the home, we will request information about your income, expenses, and any benefits you receive. We may need to conduct checks with your previous landlord and, in some cases, contact other agencies, such as the housing benefit department, the police, or the probation service.

We may need to perform additional checks on the information you provide, which might include credit checks or verification against the electoral register.

For legal reasons, we must verify that you and any household members over the age of 18 have the right to rent in the UK. More information about this requirement can be found here. We will also take copies of identification documents or a photograph for fraud prevention purposes.

Managing your tenancy or lease with us

While you live in your home, we use your information to ensure you meet the obligations of your tenancy agreement or lease, as well as to fulfilling our responsibilities to you. This includes collecting rent and service charges and arranging repairs and maintenance. We may also use your information to address issues related to anti-social behaviour or to respond to complaints and feedback.

We may be required to share personal information with utility companies and council tax departments to ensure that bills related to your home are paid.

Improving our services and customer satisfaction

We may use your personal information to find ways to improve our services and better understand our customer’s needs, circumstances, preferences, and interests.

If you have a complaint with us, we may share limited information about your complaint with our engaged customer panels for independent review.

You may be invited to participate in optional customer satisfaction surveys. If you prefer not to receive future surveys, you can opt out via the link provided at the end of each survey or contacting us through the methods listed on our contact us page.

Keeping our homes, customers, and colleagues safe

Our schemes and offices have CCTV installed to prevent crime and anti-social behaviour and to keep our customers, colleagues, and visitors safe. We ensure that notices are installed wherever CCTV is used, and that CCTV images are kept for a limited duration and are only viewed by authorised users when necessary (e.g., to detect or prevent crime, or assisting with safeguarding concerns).

To protect lone worker colleagues, sometimes we use body worn cameras or audio recording devices which may be activated where there are challenging interactions, and our colleagues or others are at risk.

We may install noise monitoring equipment to investigate noise nuisance, and our customers and members of the public may send us images, videos, and audio files to help us investigate anti-social behaviour.

Our publications

Where you give consent, we may use your interviews, photographs, and video recordings in our magazines, newsletters, annual reports and on our website and social media channels. You can withdraw your consent for this at any time by contacting us.

We may keep your information for use in publications for up to two years but, if we have used them in any leaflets or publications, they may remain in circulation for longer.

Marketing, profiling and research, and keeping in touch

If you’ve agreed to receive promotional messages from us or asked to be included on our homes marketing lists, we’ll send you information via email or text. You can unsubscribe from these messages anytime by clicking the link at the bottom of our emails, contacting us using the details provided, or updating your preferences by contacting us.

Occasionally, we may reach out to let you know you about service changes or other important updates. You can let us know how you prefer to be contacted by contacting us or updating your preferences in my.account.

We also analyse some of your personal information to help manage and collect your rent and service charges, and we use software to prioritise assistance for those who need it most.

Keeping your information up to date

When you contact or interact with us, we may ask you to confirm some security questions and then check the contact details that we have for you to make sure that they are up to date. You can help us by letting us know whenever any of your information changes by contacting us or updating your information using my.account.

Please note that calls to our customer contact centre (0330 100 0272) are recorded for training and monitoring purposes, and these recordings are kept for six months.

Sharing your personal information

Sometimes we may need to share personal information with other people or organisations. Reasons we may share your information are:

• If you have given us permission, we will share information about your tenancy with your nominated representative (third party consent)
• We share your contact information and any safety alerts with our repairs contractors so that they can undertake repairs and servicing visits to your home
• We share information about your rent and service charges with local authorities and the Department for Work and Pensions to help with housing benefit and Universal Credit claims
• If we have concerns about an individual’s health, safety, or well-being, we may share information with social services, health providers and support agencies, including charities and other voluntary organisations
• We may sometimes need to carry out identity checks or credit searches when customers apply for a home with us. This will involve sharing information with credit reference agencies and performing affordability checks
• If there is suspected tenancy fraud (e.g., illegal subletting) we share information with local authorities and fraud prevention agencies as part of the investigation process
• We share information with the police, courts, probation services and other law enforcement agencies for the prevention and detection of crime or when taking legal action
• If there are any outstanding rent or service charge debts, we will share information with debt recovery agencies
• If there are any unpaid debts connected to your home that you are responsible for (gas, electric, or water bills, or council tax payments, for example) we will share information with utilities providers and local authority council tax departments
• We may be asked by other housing associations or landlords to give references if you move home
• We are required to share statistical information with our regulators and other government departments about the types of homes that we rent and sell and the people we provide homes to
• We share information with our auditors, financial and tax advisers, solicitors, and other professional advisers
• We share your contact information with companies that carry out surveys and research for us.

We will never sell your personal data to any third party.

Storing your information and keeping it safe

Retention

We follow legal requirements and best practice to set how long we keep different types of information.

We usually keep information relating to your tenancy or lease for six years after your tenancy or lease ends. It is then securely destroyed or deleted. This allows us to meet legal requirements and provide further services that you might need, like giving references to another landlord. However, if you still have outstanding debt or if there are other outstanding legal matters, we may need to keep your information for longer than six years.

Security

We take steps to protect any information given to us by you or other organisations. We have security measures in place and hold Cyber Essentials Plus certification – a recognised and Government backed scheme – and policies, procedures, and training to safeguard the information that we hold.

If we need to share personal information with other people or organisations to provide services on our behalf, we carry out checks to make sure they do this appropriately, and we have agreements in place to make sure your information is kept safe and secure.

Transferring your information outside the UK

We may occasionally use suppliers or service providers that are based outside of the UK. We will always make sure that there are appropriate safeguards in place before doing this and the safeguards will be listed in the contracts that we use.

Your rights and complaints

Data subject rights

Data protection law gives you certain rights over how your information is used. These are explained below:

• You have the right to know how and why we use your information, how long we keep it for, and who we share it with
• You have the right to request a copy of the personal information we hold about you. This is known as a subject access request (SAR). Using the ICO’s subject access request service is the quickest and easiest way to prepare and send your request to us. Our contact details for this service are:

Name of organisation: bpha limited.
Organisation email address: data.protection@bpha.org.uk

• You have the right to ask for information to be corrected when it is wrong or it’s incomplete. Please help us to keep our records accurate and let us know if your details change
• You have the right to ask for information to be deleted when we no longer need to keep it, or we are using your information based on your consent
• You have the right to ask us to restrict how we use your information or object to how your information is being used
• You also have the right to ask us not to profile you and you can challenge any automated decisions we might make about you.

For further information about these rights, or to exercise them, please contact us.

Complaints

If you are unhappy with how we use your personal information, you can make a complaint. You can find details of our complaints process and how to make a complaint here.

If you are still unhappy with how we handle your personal information after contacting us, you have the right to complain to the Information Commissioners Office. You can also write to the Information Commissioners Office at:

Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF

Freedom of Information Act

The Freedom of Information Act does not apply to housing associations, but we want to be accountable for what we do. We want to give you the chance to see how we carry out our business and challenge us on anything you think is expensive, unreasonable, or unnecessary.

We will review all requests for information but may refuse if:

• We feel that releasing information will put our business or customers at risk
• It concerns legal matters
• It would breach data protection or confidentiality requirements.

We also consider:

• The usefulness of our response to the requester.
• Value for money and whether the cost of providing the information is justified
• The sensitivity of the information.

The final decision about whether to share or not will rest with the executive team.