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Who are we?
We are Sanctuary Affordable Housing Ltd, part of Sanctuary Group ("Sanctuary") one of the UK's leading providers of housing, care and commercial services. Our address is Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ.
Purpose of our privacy statement
Under the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), we are required to explain to you why we are asking for this information about you, how we intend to use the information you provide and whether we will share this with anyone else.
Our data protection officer
Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing [email protected].
What we do (processing activities)
Why are we collecting your information?
To enable customers, residents and the public to raise enquiries and/or seek information about our services.
If your enquiry relates to a service failure, the information that you provide will also be used for the purpose of improving our products and services.
What information are we collecting?
The information that we collect about you will include your name and contact details, and any other information which you provide to us via email, social media message, telephone, or by completing an enquiry form from our website.
What is our lawful basis for using your information?
Under Article 6 of the UK GDPR, the lawful basis we rely on for processing this information is:
(f) Our legitimate interests or that of a third party in enabling customers, residents and the public to engage with Sanctuary Homes on the services available, seek information and /or support.
Sharing your information
Members of Sanctuary Group
Sanctuary Group is made up of a number of related companies. We will share your information with other members of Sanctuary Group where necessary to best provide the services to you.
For more information on which companies make up Sanctuary Group, please go to www.sanctuary.co.uk/about-sanctuary.
Contractors and sub-contractors
It may be necessary to share information about you with our contractors and sub-contractors to resolve your enquiry for example if you report a fault and require a repair. Our contractors and sub-contractors are contractually required to ensure that they adhere to the security requirements imposed by the Data Protection Act 2018 and the UK GDPR.
Our contractors and sub-contractors will not share your information with any other parties and will only be able to use the information when completing work on behalf of us.
Regulators and other legal obligations
We may also be required to share your information with our regulators who are permitted access to this information by law and with other organisations where we have a legal obligation to share the information with them.
Data processors and Transfers
To facilitate enquiries through our website and social media channels the following categories of data processors process information on Sanctuary's behalf:
- Website hosting partner
- Social media management providers
One of our social media management providers, Hootsuite, uses sub-processors who may process and store information in the United States of America or other countries. Where this happens, Hootsuite has standard contractual clauses in place to ensure any information transferred has adequate protections in place and is compliant with data protection laws.
For further information about what international data transfers occur at Hootsuite, please visit Privacy (hootsuite.com).
Storing your information and deleting it
Following resolution of your enquiry, your information will be retained as outlined below:
- Web forms submitted via our websites are retained for 30 days.
- Social media private messages are retained for two weeks.
- Emails are retained for a minimum of one year and are automatically deleted after three years.
- Telephone recordings are retained for 30 days. Please note not all telephone calls are recorded.
Why are we collecting your information?
To enable us to market properties we have for sale that you have expressed an interest in or that meet your specified criteria.
It may also be used for market intelligence and customer research purposes as well as allowing us to provide information on products and services which are tailored to your needs.
We may also receive personal information indirectly in certain circumstances from estate agents, sales and advertising platforms and mortgage brokers.
What information are we collecting?
We collect and process the following information:
- Name
- Address
- Contact details
- Personal requirements
What is our lawful basis for using your information?
Under Article 6 of the UK GDPR, the lawful basis we rely on for processing this information is:
(a) You have given your consent. You have the right to withdraw your consent at any time and can do this by contacting [email protected].
Sharing your information
Members of Sanctuary Group
Sanctuary Group is made up of a number of related companies. We will share your information with other members of Sanctuary Group where necessary to best provide the services to you.
For more information on which companies make up Sanctuary Group, please go to www.sanctuary.co.uk/about-sanctuary.
Contractors and sub-contractors
It may be necessary to share information about you with our contractors and sub-contractors, such as sales agents or third-party estate agents, in order to provide you with the required information relating to properties we have for sale that meet your requirements.
Our contractors and sub-contractors will not share your information with any other parties and will only be able to use the information when completing work on behalf of us.
Data Transfers
We use a third-party processor, Campaign Monitor, for some of our email campaigns and we transfer your information to Campaign Monitor for the purpose of sending e-marketing and communication emails to you. Campaign Monitor is a global business that is headquartered in Australia and uses a data centre located in the United States of America, so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data outside of the European Economic Area in this way, we ensure a similar degree of protection is afforded to it by ensuring that we use specific contractual clauses which give personal data the same protection it has in UK.
Please contact us if you want further information on the specific mechanism used by emailing [email protected]
Storing your information and deleting it
We will not keep your personal data for longer than we need it or are required to by law and no longer than 12 months post the last sale completion on a site you have expressed an interest in or that meets your personal requirements.
Why are we collecting your information?
The information that you provide to us during the course of your sales query, on your application/reservation form and during the course of your property purchase from us, is required in order to meet our legal, regulatory and contractual obligations, including verifying your identity for the purposes of preventing fraud and money laundering.
It may also be used for market intelligence and customer research purposes as well as allowing us to provide information on products and services which are tailored to your needs.
We will also collect information based on any further correspondence we have with you once you have purchased your property and to facilitate any on-going services provided by Sanctuary to you, such as but not limited to remedying defects, repairs and maintenance of communal areas, the collection of fees such as service charges, rent due on the remaining un-purchased equity.
We may also receive personal information indirectly in certain circumstances from estate agents, appointed solicitors, mortgage brokers and any third party with authority.
Without this information, we will not be able to enter into a contract with you.
What information are we collecting?
We collect and process the following information:
- Name
- Contact details
- Address, previous addresses
- Date of birth
- National Insurance number
- Identification documents
- Occupation and income details
- Employer details
- Current mortgage details
- Financial details (bank details, benefits information, bankruptcy information, monthly expenditure, debts (if applicable))
- Loan / credit agreement information (if applicable)
- Details of other properties owned (if applicable)
- Debt information, for example County Court Judgements (if applicable)
- Household member details, including date of birth, gender, name, benefits information, relationship to applicant (if applicable)
- Relationship to staff or committee member (if applicable)
- Local connection and associated family details (if applicable)
- Signature
Some of the information which we collect will be special categories of personal data (also called sensitive personal data), which includes the following information:
- Health data
- Ethnicity
In accordance with the requirements for shared ownership (Homes England or Greater London Authority) we are required to collect the following personal information about people who will be living in your household when applying for one of these schemes. As part of the application process the following information is required:
- Name
- Gender
- Date of birth
- Relationship to customer
- For shared equity applications, this also includes occupation.
Details of any disability or medical conditions is also required for any member of your household this applies to, this also includes learning difficulties. This information also applies to children in your household.
If you don't provide this information to us, we will not be able to process your property purchase.
What is our lawful basis for using your information?
Under Article 6 of the UK GDPR, the lawful bases we rely on for processing this information are:
(b) Performance of a contract
(c) Compliance with a legal obligation
(f) Our legitimate interests or that of a third party
In accordance with Article 9 (UK GDPR) the conditions we rely on for processing special categories of personal data are:
(a) Explicit consent
(b) Employment, social security and social protection law
(j) Archiving, research and statistics
Our basis in Law is Section 1 and 4, of Schedule 1, of the Data Protection Act 2018 as the processing is necessary for social security and protection, archiving, research or statistical purposes.
Sharing your information
Members of Sanctuary Group
Sanctuary Group is made up of a number of related companies. We will share your information with other members of Sanctuary Group where necessary to best provide the services to you.
For more information on which companies make up Sanctuary Group, please go to www.sanctuary.co.uk/about-sanctuary.
Contractors and sub-contractors
It may be necessary to share information about you with our contractors and sub-contractors, such as sales agents, appointed estate agents, solicitors and mortgage brokers, in order to provide you with the services in accordance with the contract between us. We will only share information about you with the contractors and sub-contractors which is relevant and necessary. The contractors and sub-contractors are contractually required to ensure that they adhere to the security requirements imposed by data protection legislation.
Our contractors and sub-contractors will not share your information with any other parties and will only be able to use the information when completing work on behalf of us.
Regulators and other legal obligations
We may also be required to share your information with our regulators who are permitted access to this information by law and with other organisations where we have a legal obligation to share the information with them.
Other organisations
We may from time to time share your information with other organisations, such as:
- Homes England, Greater London Authority, or Scottish Government as part of our auditing requirements and contractual obligations;
- appointed solicitors, surveyors and mortgage brokers and lenders who will be acting on your behalf through the sale process;
- utility companies so they can provide services to you and contact you in respect of utility charges.
Data Transfers
We use DocuSign to facilitate the signing of application and reservation documents. DocuSign are a global company who may transfer your personal information outside of the European Economic Area for further processing.
DocuSign has adopted Binding Corporate Rules to facilitate the transfer of personal information from the EEA to DocuSign outside of the EEA. You may view DocuSign's Binding Corporate Rules at https://trust.docusign.com/en-us/trust-certifications/gdpr/bcr-p-processor-privacy-code and https://trust.docusign.com/en-us/trustcertifications/gdpr/bcr-c-csb-privacy-code.
Storing your information and deleting it
We will not keep your personal data for longer than we need it or are required to by law.
We keep information relating to all actions resulting in completion of a sale including upgrades for 15 years after all obligations have concluded.
Applications which are unsuccessful or do not result in the legal completion of a property are retained for 6 years.
Why are we collecting your information?
The information that you provide to us during the course of your sales query, on your application/reservation form and during the course of your property purchase from us, is required in order to meet our legal, regulatory and contractual obligations, including verifying your identity for the purposes of preventing fraud and money laundering.
It may also be used for market intelligence and customer research purposes as well as allowing us to provide information on products and services which are tailored to your needs.
We will also collect information based on any further correspondence we have with you once you have purchased your property and to facilitate any on-going services provided by Sanctuary to you, such as but not limited to remedying defects, repairs and maintenance of communal areas, the collection of fees such as service charges.
We may also receive personal information indirectly in certain circumstances from estate agents, appointed solicitors, mortgage brokers and any third party with authority.
Without this information, we will not be able to enter into a contract with you.
What information are we collecting?
We collect and process the following information:
- Name
- Contact details
- Address, previous addresses
- Date of birth
- National Insurance number
- Identification documents
- Occupation and income details
- Employer details
- Professional qualifications
- Current mortgage details
- Financial details (bank details, benefits information, bankruptcy information, monthly expenditure, debts (if applicable))
- Loan / credit agreement information (if applicable)
- Details of other properties owned (if applicable)
- Debt information, for example County Court Judgements (if applicable)
- Household member details, including date of birth, name, benefits information, relationship to applicant (if applicable)
- Relationship to staff or committee member (if applicable)
- Local connection and associated family details (if applicable)
- Signature
Some of the information which we collect will be special categories of personal data (also called sensitive personal data), which includes the following information:
- Health data
- Ethnicity
In accordance with the requirements for shared equity (Scottish Government) we are required to collect the following personal information about people who will be living in your household when applying for one of these schemes. As part of the application process the following information is required:
- Name
- Date of birth
- Relationship to customer
- For shared equity applications, this also includes occupation.
Details of any disability or medical conditions is also required for any member of your household this applies to, this also includes learning difficulties. This information also applies to children in your household.
If you don't provide this information to us, we will not be able to process your property purchase.
What is our lawful basis for using your information?
Under Article 6 of the UK GDPR, the lawful bases we rely on for processing this information are:
(b) Performance of a contract
(c) Compliance with a legal obligation
(f) Our legitimate interests or that of a third party
In accordance with Article 9 (UK GDPR) the conditions we rely on for processing special categories of personal data are:
(a) Explicit consent
(b) Employment, social security and social protection law
(j) Archiving, research and statistics
Our basis in Law is Section 1 and 4, of Schedule 1, of the Data Protection Act 2018 as the processing is necessary for social security and protection, archiving, research or statistical purposes.
Sharing your information
Members of Sanctuary Group
Sanctuary Group is made up of a number of related companies. We will share your information with other members of Sanctuary Group where necessary to best provide the services to you.
For more information on which companies make up Sanctuary Group, please go to www.sanctuary.co.uk/about-sanctuary.
Contractors and sub-contractors
It may be necessary to share information about you with our contractors and sub-contractors, such as sales agents, appointed estate agents, solicitors and mortgage brokers, in order to provide you with the services in accordance with the contract between us. We will only share information about you with the contractors and sub-contractors which is relevant and necessary. The contractors and sub-contractors are contractually required to ensure that they adhere to the security requirements imposed by data protection legislation.
Our contractors and sub-contractors will not share your information with any other parties and will only be able to use the information when completing work on behalf of us.
Regulators and other legal obligations
We may also be required to share your information with our regulators who are permitted access to this information by law and with other organisations where we have a legal obligation to share the information with them.
Other organisations
We may from time to time share your information with other organisations, such as:
- The Scottish Government as part of our auditing requirements and contractual obligations;
- appointed solicitors, surveyors and mortgage brokers and lenders who will be acting on your behalf through the sale process;
- utility companies so they can provide services to you and contact you in respect of utility charges.
Data Transfers
We use DocuSign to facilitate the signing of application and reservation documents. DocuSign are a global company who may transfer your personal information outside of the European Economic Area for further processing.
DocuSign has adopted Binding Corporate Rules to facilitate the transfer of personal information from the EEA to DocuSign outside of the EEA. You may view DocuSign's Binding Corporate Rules at https://trust.docusign.com/en-us/trust-certifications/gdpr/bcr-p-processor-privacy-code and https://trust.docusign.com/en-us/trustcertifications/gdpr/bcr-c-csb-privacy-code.
Storing your information and deleting it
We will not keep your personal data for longer than we need it or are required to by law.
We keep information relating to all actions resulting in completion of a sale including upgrades for 20 years after all obligations have concluded.
Applications which are unsuccessful or do not result in the legal completion of a property are retained for 6 years.
Why are we collecting your information?
Information you provide to us is voluntary and will be used to support our communication and marketing activities. This may include promotional materials, press releases, social media posts, case studies and corporate documents.
Our materials may be published internally within Sanctuary as well as externally to our residents, on our social media channels and our websites.
What information are we collecting?
We currently collect and process the following information:
- Name
- Age/Date of birth
- Contact details including your email, phone number and your address
- Photos, videos or audio recordings (if applicable)
- Personal experiences (if applicable)
If you choose to provide it, some of the information which we collect may be special categories of personal data (also called sensitive personal data), which includes the following information:
- Health-related information, including disability
- Sexual orientation
- Racial or ethnic origin; and
- Religious beliefs
What is our lawful basis for using your information?
Under Article 6 of the UK GDPR, the lawful basis we rely on for processing this information is:
(a) You have given your consent. You can remove your consent at any time by contacting [email protected].
In accordance with Article 9 (UK GDPR) the condition we rely on for processing special categories of personal data is:
(a) Explicit consent
Sharing your information
Members of Sanctuary Group
Sanctuary Group is made up of a number of related companies. We will share your information with other members of Sanctuary Group where necessary to best provide the services to you.
For more information on which companies make up Sanctuary Group, please go to www.sanctuary.co.uk/about-sanctuary.
Contractors and sub-contractors
It may be necessary to share information about you with our contractors and sub-contractors, for example with an external design, website or digital agency, when creating our marketing materials. Our contractors and sub-contractors are contractually required to ensure that they adhere to the security requirements imposed by the Data Protection Act 2018 and the UK GDPR.
Our contractors and sub-contractors will not share your information with any other parties and will only be able to use the information when completing work on behalf of us.
Regulators and other legal obligations
We may also be required to share your information with our regulators who are permitted access to this information by law and with other organisations where we have a legal obligation to share the information with them.
Other organisations
With your consent we may from time to time share your images and information provided with our partners to support our communication and marketing activities.
Data processors and Transfers
To facilitate our communication and marketing activities, information is shared with the following categories of data processors who process information on Sanctuary's behalf:
- Photographers and videographers;
- Website and digital agencies;
- Marketing and PR agencies;
- Media organisations;
- Printing companies;
- System providers (in circumstances of technical IT support).
Storing your information and deleting it
We will not keep your personal data for longer than we need it or are required to by law.
We will retain the information you provide for 5 years, unless you contact us to withdraw consent earlier than this date.
We may from time to time seek to ‘refresh’ your consent, at which point we would retain your information for a further 5 years from the date consent was refreshed.
Why are we collecting your information?
Data protection laws aim to empower individuals and give them greater control over their personal data through several rights including:
- Right of access – referred to by Sanctuary as a DSAR (Data Subject Access Request), gives individuals the right to obtain a copy of their personal data from us, as well as other supplementary information.
- Right to rectification – to have inaccurate personal data rectified, or completed if it is incomplete. This right is not absolute and in certain circumstances we can refuse a rectification request.
- Right to erasure – the right to have their personal data erased. This right is not absolute and in certain circumstances we can refuse an erasure request.
- Right to restrict processing – to restrict the processing of their personal data. For example, Sanctuary could continue to store personal data but not use it. This right is not absolute and in certain circumstances we can refuse a request.
- Right to data portability – to obtain and reuse their personal data for their own purposes across different services. The right only applies to information an individual has provided to Sanctuary and where the lawful basis for processing is consent or performance of a contract. Paper records are excluded from this right.
- Right to object – the right to object to the processing of their personal data in certain circumstances. Individuals have an absolute right to stop their data being used for direct marketing. The right effectively allows individuals to stop or prevent organisations from processing their personal data, though is not absolute and in certain circumstances we do not have to comply.
- Rights related to automated decision making and profiling – restricts organisations from making solely automated decisions, by enabling individuals to request human intervention or challenge a decision that has been made.
Sanctuary is committed to protecting the rights of data subjects and ensuring compliance with all applicable data protection laws in the UK. The information we collect, and process will be used to administer your data subject rights request.
What information are we collecting?
To facilitate your request, we will collect and process the following information:
- Name
- Contact details, such as an address, email address and telephone number
- Identification documentation
- Details of the scope of the request
- Third party authority data (where applicable)
What is our lawful basis for using your information?
Under Article 6 of the UK GDPR, the lawful basis we rely on for processing this information is:
(c) Compliance with a legal obligation - using your information is necessary for us to comply with a legal obligation to which we are subject in accordance with UK data protection law.
Sharing your information
Members of Sanctuary Group
Sanctuary Group is made up of a number of related companies. We will share your information with other members of Sanctuary Group where necessary to best provide the services to you.
For more information on which companies make up Sanctuary Group, please go to www.sanctuary.co.uk/about-sanctuary.
Other organisations
We may share your information with other organisations where relevant in order to comply with your request of erasure, restriction, objection or rectification where we had previously shared that information with partner organisations.
Storing your information and deleting it
We will not keep your personal data for longer than we need it or are required to by law.
Following completion of your request or any subsequent complaint to the Information Commissioners Office, the case file will be retained for one year before deletion.
Can we use your information for any other purpose?
In limited circumstances, we may use your information for a purpose other than those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.
Security and your rights
Security of your information
The information that you provide will be stored securely. Our technological and organisational security measures and procedures reflect the seriousness with which we attach to the confidentiality, integrity, and availability of your information.
Only relevant members of staff will access the information you provide to us.
Your rights
In relation to the information which we hold about you, you are entitled to:
- Ask us for access to the information;
- Ask us to rectify the information where it is inaccurate or is incomplete;
- Ask us to erase the information and take steps to ask others who we have shared your information with to also erase it;
- Ask us to limit and restrict what we do with your information;
- Object to our use of your information and ask us to stop that use;
- Ask us to provide the data you have provided us in a structured, commonly used, and machine-readable format (for example, a CSV file) in order transmit the data to another data controller;
- Challenge the decision of any automated decision-making and/or profiling that is applied to your personal data as part of the processing;
Our obligations to comply with the above rights are subject to certain exemptions.
To exercise any of the rights referred to above, you should contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing [email protected].
How to complain
If you have any concerns about our use of your personal information, you can contact our Data Protection Team on [email protected].
You also have the right to complain to the Information Commissioner's Office (the 'ICO') if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.