Purpose and lawful basis
Our purpose is to assess your application for a home with us. This will entail us assessing your suitability, requirements and right to rent.
The lawful basis we rely on to process your personal data is article 6 (1) (b) of the General Data Protection Regulation (also known as GDPR), enables us to process your information in order to enter into a contract with us – this is your Tenancy Contract.
We have a legal obligation to carry out right to rent checks on your identification documents under the Immigration Act 2014. This is then made lawful under Article 6 (1) (c) of the UK GDPR.
We will collect information of your health to ensure your new home is suitable for your needs. This is collected under our social protection responsibilities as a social landlord under Article 9 (2) (b) of theUK GDPR and the Data Protection Act 2018, schedule 1 part 1 (1).
We collect other ‘sensitive’ information such as:
- Ethnic origin
- Sexual orientation
Collecting such information will allow us to monitor and review the diversity and treatment of our customers, in accordance with our ‘substantial public interest obligations’ (Article 9 (2) (g) of theUK GDPR and the Data Protection Act 2018 Schedule 1 Part 2 (8)).
If you declare a criminal conviction during this application this will be assessed and processed as a substantial public interest in order to ensure there are no unacceptable risks posed to customers, staff or contractors under Article 10 of theUK GDPR and Schedule 1 part 3 (35) and Schedule 1 Part 2 (10).
Why we need to use it?
In our role as a registered social landlord, we need to make sure that applications meet our letting criteria and that any offer of a home appropriately meets your needs as a Guinness customer.
How long we keep it?
If your application is unsuccessful, we will only retain your information for 6 months from when it was declined.
If your application is successful and you become a Guinness customer your information will become part of your customer file. It will also be retained for 6 years once you have stopped being a Guinness customer.
You have the right to access your personal data held in your application file by us. (Access)
You also have the right to have inaccurate data corrected and incomplete data completed. (Rectification)
You have the right to request us to pause the use of your data only if you have contested the accuracy whilst we verify your application or to stop it’s deletion in the case of a legal claim. (Restriction)
You have the right to receive, or have transferred to another organisation, information you have provided to us in a re-usable electronic format. (Data Portability)
Who we share the information with?
In order to process we use a number of third parties to assist in our application process:
- Trust ID to identify your verification.
- Policy in Practice to assess your financial circumstances.
Depending on your circumstances we may be obliged to share and work with other external organisations such as:
- Your Local Authority including Social Services – Adult and Children’s Services, Safeguarding Teams
- Any relevant Health Professionals
- Department for Work and Pensions
- Law Enforcement
All information through this process is held within the EU in accordance with Data Protection law.