bpha respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights under the General Data Protection Regulations 2018 (GDPR) and the Data Protection Act 2018.
Purpose of this Privacy Notice
This privacy notice aims to give you information on how bpha collects and processes your personal data through your use of this website.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Who we are
bpha Limited is the controller and responsible for your personal data (collectively referred to as ”bpha”, “we”, “us” or “our” in this privacy notice).
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO by using the details set out below.
Data Protection Officer
Or use our email address: email@example.com
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, which may include:
- Telephone numbers
- Present, previous and forwarding addresses
- Date of Birth
- Marital Status
- Rent payment details
- Bank details
- Housing benefit
- Income details
- Debt details
- Employment details
- National Insurance number
- Health and care details
- Ethnicity, culture or religion
- Anti-social behaviour, violence and criminal activities
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with. In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- To provide the services you need including repairs, maintenance, rents, transfers, sales and anything to do with your tenancy and property.
- To deal with your account(s) including payments, grants and benefits or run any other service we provide to you
- To support you with money and debt advice and benefit and grant advice
- To manage applications made by you
- To provide a helpful and efficient response when customers ask for help and advice
- To deal with complaints
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with third parties for the purposes set out above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Sometimes we may have to share information for legal reasons, for example to the Police, Benefits Agency and other landlords, or if it related to anti-social behaviour, crime or fraud.
If you would like to authorise someone to access your personal data and act on your behalf, please complete a consent form in full and return to bpha. You can download the consent form at the bottom of this page. If you wish to withdraw this permission you must notify us in writing.
We will only transfer your personal data to a country outside the European Economic Area (”EEA”), provided that one of the following conditions applies:
- The country to which your personal data is transferred ensures an adequate level of protection for your rights and freedoms.
- We have your consent.
- The transfer is necessary under regulation, in the performance of our contract with you, or to protect your vital interests.
- The transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims.
- The transfer is authorised by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our Data and Document Retention Schedule which you can request from us by contacting us.
In some circumstances you can ask us to delete or remove your personal data where there is no good reason for us continuing to process it. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under the GDPR you have rights regarding the personal data that bpha process and hold about you. You have the right to:
- Find out what information bpha hold on you – please use the Subject Access Request form.
- Correct or complete inaccurate personal information bpha holds about you – please use the Changing my Information form.
- Delete data about you that bpha have – please use the Deleting my Information form.
- Move your data between landlords – please use the Transfer my Information form.
- Challenge how bpha process your information – please use the Right to Object form.
- Be notified about changes to your personal data – please use the Right to restrict processing form.
- Opt out of automated decision making – please use the Automation and Profiling Op-Out form.
If you would like to contact us then you can download the relevant request form from at the bottom of this page or call us on 0330 100 0272. We will ask you to provide proof of identity before disclosing any information. It is free to use these rights, but bpha reserve the right to charge a reasonable fee if we feel there are excessive requests.
Complete the form in full and return it to:
Data Protection Officer
Or use our email address: firstname.lastname@example.org
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
In some circumstances we can refuse to comply, if this is the case it will be explained to you. Please note that your right to see certain information may be limited. For example, if it may affect a police investigation or a criminal prosecution then we are not permitted to disclose the information to you.
If you believe our records are inaccurate, you can write to us, asking for them to be amended. If you believe we have unfairly withheld information or unfairly refused to amend our records, you can make a complaint using our standard complaints procedure. Alternatively, you can contact the Information Commissioner’s Office.