Our Privacy Notice

We take your privacy very seriously, so we want to make sure you understand your privacy rights and how we use your information.

The Guinness Partnership Privacy Notice

This privacy notice covers the services provided by The Guinness Partnership.
To learn more about how Guinness Care uses and protects your data, take a look at the Guinness Care Privacy Notice.

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Information about the Guinness Partnership

The Guinness Partnership Ltd, 30 Brock Street, Regent’s Place, London, NW1 3FG will be responsible for determining the use of your information.

In this privacy notice, ‘we’, ‘us’ and ‘our’ mean The Guinness Partnership Limited and its subsidiary companies within our Group. Depending on which of our products and services you ask us about or use, different companies within our organisation will process your information. You can find out more about the companies within our Group, by clicking here.

We’re committed to protecting the personal information we collect about you. This privacy notice explains what happens to the information you are providing to us.

Scope of this Privacy Notice

This privacy notice applies to you if you ask us about, or use our services in relation to general rent properties. It describes how we handle your information, regardless of the way you contact us (for example, by email, through our website, by phone and so on). We will provide you with further information or notices if necessary, depending on the way we interact with each other, for example if you are contacted with an offer of further support we may give you privacy notices which apply just to a particular type of information which we are collecting and using through that process.

For customers of Guinness Care please see the Guinness Care Privacy Notice

For Outright Sales, Shared Ownership, Right to Buy and Right to Acquire please see the Guinness Homes website.

The Data Protection Officer

Our obligations under Data Protection Regulations are overseen by the Information Management Governance and Risk Team who can be contacted on informationmanagement@guinness.org.uk

The Guinness Partnership has appointed a Data Protection Officer to monitor our compliance with the Data Protection Regulations.

If you have any concerns, our Data Protection Officer can be contacted at dataprotectionofficer@guinness.org.uk or by writing to:

Data Protection Officer
The Guinness Partnership
Bower House
1 Stable Street
Hollinwood
Oldham
OL9 7LH

What type of information do we hold?

We collect ‘standard personal data’, special category (previously sensitive) personal data and information about any criminal convictions you may have had.

Standard personal information

Some of the information we may hold about you is categorised as standard personal information. This includes:

  • contact information, such as your name, username (when registering online), address, email address and phone numbers;
  • your age, your date of birth and national identifiers (such as your National Insurance number or passport number);
  • information about your employment;
  • details of any contact we have had with you, such as any complaints or incidents;
  • financial details, such as details about your payments, your bank details or financial circumstances;
  • Information in relation to any criminal convictions you may have had
  • information about how you use our products and services, such as disrepair claims; and
  • information about how you use our website or other technology, including IP addresses or other device information (please see our Cookies Policy for more details).

Special category information

Other types of data we may collect from you is more sensitive, and is considered to be special category information. This includes:

  • Disability or other health information
  • Race
  • Ethnic Origin
  • Religion

Why we need your personal information

We will only ever collect the minimum amount of personal data to provide effective services to you in order to:

  • assess your application for housing
  • provide suitable accommodation for you
  • manage your tenancy
  • check you are eligible for social housing
  • check you have the right to rent
  • ensure that there are no unacceptable risks posed to our customers, staff and contractors
  • process your payments to us and to reclaim these when overdue
  • to ensure utility charges are directed to those responsible for paying
  • offer support to customers to maintain your tenancy and stay in your home
  • avoid risks of homelessness,
  • at your request to involve you in Guinness initiatives and the opportunity to feedback and shape Guinness services and
  • ensure we are fair and transparent with all applicants.

Conditions of use

We need a lawful reason to use your information, for the majority of your personal information we will use one of the following conditions:

  • consent – for example to keep you updated or involved in Guinness initiatives. We will never ask for consent where if you do not consent would put you at a disadvantage.
  • necessary to take steps or for the performance of a contract – if you have applied for a home or we have an agreement with you, we will process your personal information to fulfil that agreement (that is to provide you and your household with amazing service). Without this we will not be able to process your application
  • legitimate interests – there will be from time to time a need for us to process your personal data in our or a third parties legitimate interests. Further information can be found in this Privacy Policy
  • if it is required by law.

We will process special category information to ensure that there are no risks posed to you or your household. This could include processing for the purposes of:

  • health information – to ensure your home has any necessary adaptations so that you can live without further risks to your wellbeing
  • information on your religion, ethnic origin and sexual orientation – to monitor diversity and equality of treatment of customers.

Legitimate interests

We will also process your personal information if it is in our legitimate interest to do so, including managing some aspects of our relationship with you, for marketing, to help us improve our services to you, and in order to exercise our rights or handle complaints. More detailed information about our legitimate interests is set out below.

Legitimate interest is one of the legal reasons why we may process your personal information. Taking into account your interests, rights and freedoms, we have carried out Legitimate Interest Assessments which allow us to process your personal information including:

  • Communicate with you by text message to keep you updated on our service delivery
  • To offer you further support, including referrals to external agencies, to help you stay in your home
  • Carry out customer surveys with a third party to help us improve services to you
  • To identify and investigate fraud, corruptions and/or bribery
  • To engage with contractors when carrying out a planned maintenance programme of work
  • To trace former tenants, if we need to contact you if you still have arrears
  • To supply your details to utility companies when you move in and out of your home to ensure correct payment of utility bills
  • In our efforts to prevent homelessness by making local homelessness teams aware if you are in the process of being evicted.
  • To record some telephone calls for the purpose of monitoring quality and training.

If you wish to object to us using your information for any of these legitimate interests please contact us:

Information Management Governance and Risk Team 
The Guinness Partnership
Bower House
1 Stable Street
Hollinwood
Oldham
OL9 7LH

We will need to be sure that it is you making the request so you will need to pass some data protection checks or we may ask for two forms of identity if we have any doubts.

We will consider each and every request and respond within one month. If your request is particularly complex we may extend this, by exception, for up to a further 2 months.

Who we share your data with, and who we receive it from

We will share information across employees within the Guinness Partnership Group to enable us to meet your needs to assess your application, manage your tenancy, offer appropriate support,  resolve disputes between you, Guinness and/or a third party and improve your customer experience.  This would include:

  • Our Lettings team
  • Our Customer Liaison Team
  • Our Customer Accounts Team
  • Our Finance Team
  • Our Customer Service Centre Team
  • Our Customer Support Team
  • Our Tenancy Enforcement Team
  • Our Customer Insight and Experience Teams

So that we can provide effective services to you we will be required to share and receive your information with/from external organisations and people:

  • People you have authorised to act on your behalf
  • The main tenant if you are not the main tenant but living in the household
  • Your Local Authority to ensure your needs are fully met
  • Your previous landlord
  • External health professional, Now Medical, to assist in assessing your medical circumstances to ensure your home meets your needs
  • Policy in Practice to assess your financial circumstances and benefit entitlement where required
  • Trust I.D. to verify your identification to check your right to rent
  • British Gas when you move in and leave the property to ensure continuation of utility supplies to your home and to ensure utility charges are directed to the correct individual
  • Third party contractors whom carry out repairs and maintenance to your home.
  • Any specialised support agencies you are involved with
  • Our solicitors to provide advice relating to your tenancy
  • When investigating complaints made by you and others
  • When you call us your call may be recorded for quality and training purposes and stored by Verint
  • Voluntas or Kwest to carry out customer surveys on our behalf
  • Experian if you are a former tenant in arrears
  • Esendex to send text messages to you about your tenancy
  • Barclaycard to process your payments to us
  • The relevant Court in any legal proceedings
  • Surveymonkey in order to carry out electronic surveys
  • Your Councillor or Member where they are representing you and your interests.
  • Third party IT providers that enable us to provide services to you

In some cases we may have a duty to disclose your information to:

  • other housing associations
  • our regulators  and government departments such as the Department of Works and Pensions
  • fire services, health authorities or medical staff
  • utility services if you leave an unpaid bill when moving house
  • the police and other law-enforcement agencies to perform their duties for the purpose of crime prevention or detection, if we have a legal obligation to do so or it is required by a Court Order.

We won’t share your personal information with anyone who claims to represent you unless we’re satisfied that you have appointed them or they act in some recognised official capacity.

Marketing and preferences

We may use your personal information to send you marketing by post, by phone, through social media, by email and by text.

We can only use your personal information to send you marketing material if we have your permission or a legitimate interest as described above.

If you don’t want to receive emails from us, you can click on the ‘unsubscribe’ link that appears in all emails we send to you. If you don’t want to receive texts from us you can tell us by contacting us at any time. Otherwise, you can always contact us here to update your contact preferences.

You have the right to object to direct marketing. Please see the section about your rights for more details.

We will need to retain a small amount of your information so that we know you have objected to being contacted in this way.

Recording calls

As part of our commitment to providing the best possible service to our customers we may record telephone calls to and from our customer service centres. This helps us to provide you with a better service.

We record calls:

  • for staff training purposes, to help us improve the quality of our customer service and to ensure the information we provide is consistent and accurate
  • to ensure we’ve not missed any important information you have provided
  • to ensure we have an accurate record of your call, which may be needed to support any transactions that take place over the phone or if there is a dispute.

We understand your personal information is important and we’re committed to protecting your privacy. We store the recordings securely for 6 months and destroy them after this period, unless they’re part of a dispute, in which case we reserve the right to keep the call recordings as part of the dispute resolution.

You can request access to and the correction of personal information we hold about you. Unless we have lawful reason for withholding this information we’ll provide you with access. Find out how you can request access to this information.

Freedom of Information

The Guinness Partnership Limited is not a public authority as defined by the Freedom of Information Act 2000 and therefore is not required to respond to requests made under the Act. Wherever possible we publish corporate information in order to be transparent about our activities.

How we keep your information safe

We apply appropriate measures to ensure your personal information is secure.  For example, we have systems in place so that access to personal information is restricted to authorised individuals on a strictly need-to-know basis.

When we need to share personal data with our contractors and third party suppliers, we have contracts with them that sets out their responsibilities

To help us ensure confidentiality of your personal information we will ask you (and any of your representatives) security questions to confirm your identity when you call us and as may be necessary when we call you. We will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so or where we have received a clear verbal instruction from you (as a one-off circumstance).

We also make sure all staff complete mandatory Data Protection training so they understand their responsibilities to protect your data.

Transferring Information outside of the European Economic Area (EEA)

We deal with many international organisations to help us manage your tenancy and provide services to you. We will try our best to ensure that your personal information is not transferred outside of the EEA, however, sometimes your information will be. Not all countries outside the EEA have data-protection laws that are similar to those in the EEA and if so, the European Commission may not consider those countries as providing an adequate level of data protection.

We take steps to make sure that, when we transfer your personal information to another country, appropriate protection is in place, in line with data-protection laws. Often, this protection is set out under a contract with the organisation who receives that information and we will make sure they have good information security practices in place to protect your information. For more information about where your information is stored, please contact us at informationmanagement@guinness.org.uk

How long we keep your information

We have a number of different time periods that we may keep your information for. These are based on the following criteria:

  • How long you have been a customer and when your tenancy ends
  • How long it is reasonable to show we have met the obligations we have to you under your agreement with us
  • If there is a time period set by law
  • Any time period allowed for us to make or defend a legal claim
  • Any recommended time periods set by our regulators or professional bodies
  • Any relevant proceedings that may apply

If you would like any further information about how long we keep certain types of your information, please get in touch, informationmanagement@guinness.org.uk

Your rights

Data Protection law gives you greater control as to how we can use your information. To enable this you have the right to request us to take action in relation to your information. You have the following rights:

  • Right of access – the right to request details as to how we use your information and to be provided with a copy of that information.
  • Right to Rectification – the right to have inaccurate data corrected
  • Right to erasure – the right to have certain information about you deleted
  • Right to Restriction – the right to request us to limit the use of your personal information in certain circumstances
  • Right to Object – the right to object to us using your information for a task carried out in the public interest, where we have informed you that we are processing in our or a third parties legitimate interests or if we use your information for direct marketing
  • Right to Data Portability – the right to request certain types of information to be provided to you or transferred to a third party in an electronic, machine-readable format. Currently this will be provided in a .csv format.
  • Right to Withdraw Consent – if we have asked for your consent to process some of your personal information, you have the right to withdraw this at any time. We will never ask for consent for providing a service to you or if you would be disadvantaged if you did not want to consent.
  • Automated Decision Making – we currently do not make any decisions relating to you in a solely automated fashion. i.e. without any human involvement. If we do we will tell you and you will have the right to request us not to unless it is strictly required to enter into (or performance of) your contract, required by law or you have provided your explicit consent.

Please Note:
These rights are not absolute and will be considered on a case by case basis except where you withdraw consent or object to direct marketing. In each case we will let you know in our correspondence with you whether we can comply with your request and provide a full explanation if we cannot comply.

How to request access to your data

When you make a request we need to be sure that it is you applying. You will need to either pass our data protection checks or we may ask you to provide 2 forms of identification if we have any doubts.

We will consider each and every request and respond within one month of receiving a valid request. If your request is particularly complex we may extend this, by exception, for up to a further 2 months.

If you would like to request access to your personal data you can do this via our online form here.

You can also request access to your personal data or to exercise any of your other rights, by contacting us at:

Information Management Governance and Risk Team 
The Guinness Partnership
Bower House
1 Stable Street
Hollinwood
Oldham
OL9 7LH

Or use any of the following methods:

It would be really helpful if you could provide as much information as possible to help us assess and progress your request.

What to do if you're not happy with how we handle your data

If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer on dataprotectionofficer@guinness.org.uk  who will investigate the matter.

If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can make a complaint to the Information Commissioner’s Office (ICO).

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

Call 0303 123 1113

Visit the Information Commission website at www.ico.org.uk