Transparency and Privacy Policy

Transparency

Cross Keys Homes (CKH) aims to be open with our customers and will routinely share information relating to performance, policies, procedures, and decision making with customers and other stakeholders as part of our wider objective of being accountable for what we do.  Although CKH is not currently covered by the Freedom of Information Legislation; we will not routinely withhold information where a request is neither commercially sensitive and can be fulfilled without unreasonable levels of employee cost in relation to the benefit of the data to the requestor.  Any request which relates to information relating to our customers will be considered against relevant requirements of prevailing data protection legislation and our objective to safeguard individual’s privacy. 

Privacy Policy 

CKH collects information about you as a part of your application for services or when you enter into a contract with us, such as a tenancy agreement or for the provision of care or a LifeLine. CKH takes your right to privacy and the security of information very seriously. The basis, under which we will collect, store, process (use), and share your information is explained in more detail in our Privacy Notice and the Government has set out legislation which provides in detail for you rights.  Cross Keys Homes is required to comply with those rights.  Cross Keys Homes Limited is registered with the Information Commissioners Office (registration number Z8738837) and more information regarding the laws on data protection can be found on the ICO’s website: https://ico.org.uk/for-the-public/

Details about how we manage and process personal data areas are set out in the Privacy Notice below, but in summary:

We collect personal data relating to you directly from you and also occasionally it may be provided to us by third parties with whom you have a separate relationship (for example a local authority or the department of works and pensions).

We use your data to provide housing and other services to you, to correspond with you and to meet our legal obligations.

We only provide your personal data to third parties for our limited business purposes, or to which you have specifically requested a referral, or as otherwise permitted or directed to by law. We do not share your data with third party advertisers.

We store data for specified periods for our limited business purposes.

You have certain rights, prescribed by law, in relation to the processing of your data, such as rights to request access, rectification or deletion of your personal data.

You can contact us to enquire about any of the contents of this privacy notice by emailing the Data Protection Officer at DPO@Crosskeyshomes.co.uk or by writing to the Data Protection Officer at our head office address.

Privacy notice 

This Privacy Notice sets out what you can expect to happen when CKH processes personal information.  It applies to the information we process for tenants and service users. It also sets out the main legal basis for the processing of personal information.

About the personal information we collect

When we collect information about you, either in person or via a referral or written application, it will be made clear to you how that information will be used.  The information we collect is to enable us to establish and manage a contract or relationship with you and may include, but is not limited to:

  • Names and dates of birth of you and the people in your household

  • Contact details for you ( phone/ mobile / email)

  • Racial or ethnic origin

  • Contact details of individuals or organisations assigned to support you

  • Information relating to health conditions

  • Information relating to convictions, proceedings and criminal acts

  • Photographs

Generally the information we hold will have been provided by you, however, we may also hold information which has been provided to us by third parties, such as agencies dealing with any benefits, or support workers.  You have a right to access the information we hold on you and, if you identify something that is inaccurate, a right to have it corrected.

As well as collecting this information at the beginning of your relationship with CKH, we aim to keep it up to date as your circumstances change.  It is important that you contact us if there is a change which might be relevant to how or to which services are provided to you. 

How we store your information 

We generally store information on secure computer systems which are protected by appropriate technical security arrangements to prevent unauthorised access. Our core data is hosted within the EEA. In the event that we or any third parties who process data on our behalf transfer data outside of the EEA we will require that transfers will only be made to countries for which the European Commission has made an adequacy provision.   We aim to ‘scan’ documents wherever possible and destroy paper based originals.  Where it is necessary to hold personal information in a paper format, these will be held in secure office accommodation.

We will only retain personal information about you, so long as is necessary to support a legal basis.  You have a right to request the erasure and / or correction of information held about you and can do so by contacting the Data Protection Officer by emailing DPO@Crosskeyshomes.co.uk or sending your request to Cross Keys Homes, Shrewsbury Avenue, Peterborough PE2 7BZ.

The basis under which we process your information

Data protection legislation requires a ‘legal basis’ for the processing of personal information.  Our main basis for processing personal data are where it is necessary for fulfilling the terms of a contract or agreement we have made with you (for example the use of data in making arrangements to repair or maintain the property that you are living in), or otherwise for the purposes of protecting the legitimate interests of CKH or a third party. (for example in collecting your rent or ensuring utility companies can recover amount due to them) We may also process data to fulfil a legal obligation placed upon us or in the prevention of fraud, crime against Cross Keys Homes or a third party.  This may also link to the way we will share information we hold about you.

There may be occasions where we rely on your consent to use your data, particularly when dealing with special categories of data.  Where this is the case, you have the right to withdraw your consent.

On certain occasions we may process your data to protect the vital interests of you or another person, for example in the event of an urgent health and safety matter.

We may also use your data in support of improving our products and services and this may include contacting you and requesting feedback on service performance. The legal basis of this is our legitimate interest.

How we share your information

There are a number of circumstances which may lead us to share your data, in particular where we have sub -contracted to another organisation for the provision of a service to you.  A common example is for the maintenance and repairs works to your home.  As a minimum, the data we provide to a sub-contractor will be your name and contact details, however, we may also provide information on issues relating to your physical or mental health where this is necessary for the safe and appropriate delivery of service.  For services which do not relate directly to your housing, such as care, LifeLine or support services, we will make clear when you apply if and how your data will be shared with other organisations.

 Whenever we provide information about you in this way, we will put in place a data sharing agreement with the service provider which obligates them to maintain a high level of security over personal data that we share with them, and to only use it for the intended purpose.

We may also share information where it is in the legitimate interests of CKH to do so, for example, in the prevention of fraud or crime against us, or to support the collection of monies owed by you to us or a third party that might otherwise hold CKH liable.  The most common example in this case is with utility companies. We may also provide your data to partner organisations who will contact you on our behalf for independent performance feedback. We do not share data with third party advertisers 

We will also share information with law enforcement and government agencies or public bodies where we are legally obliged to do so; this may be in relation to matters of suspected crime or fraud including benefit or taxation issues. CKH takes tenancy related fraud very seriously and will cross check available data in order to investigate suspected fraud. CKH may take action against anyone who has presented misleading or inaccurate information in order to gain access to housing. Occasionally we may be required to share data with public bodies for statistical purposes.

Your rights under Data Protection legislation

Data protection legislation, covered by the General Data Protection Regulation and Data Protection Act (2018) provides the following principal rights for individuals:

  1. The right to be informed - this relates to being informed how we will use the data that you have provided. 

  2. The right of access - you have the right to request part of or all of the information that we have on a housing database and document management systems via a subject access request.

  3. The right to rectification - if you note that any of the information we hold is incorrect you have the right to request that this is changed. 

  4. The right to erasure - where CKH no longer has a legitimate reason to hold information about you, you have the right to request that this is deleted.

  5. The right to restrict processing - for example where there is a dispute regarding the accuracy of data.

  6. The right to data portability - if you leave CKH you may wish for your records to be made available to your new provider this can be arranged by contacting CKH.

  7. The right to object – you have the right to object to the use of your data where there is no legal basis for its processing.

  8. Rights in relation to automated decision making and profiling - CKH does not use any information to complete automated decision. We may use anonymised data to analyse and shape our services.

Where you have concerns regarding the use of your personal data you can contact the data protection officer at DPO@Crosskeyshomes.co.uk or by writing to the Data Protection Officer at our head office address.You also have the right to make a complaint with the Information Commissioner’s Office if you believe that your data has been used inappropriately or a decision made about your data has not been satisfactory.

Where a suspected or actual data breach is reported; CKH will investigate  this in a timely manner in accordance to the data protection guidance.

For more information on our responsibilities and your rights under the data protection legislation, please visit: https://ico.org.uk/for-the-public/

Finding out about the information we hold about you

You can ask to see the personal data we hold about you by making a ‘subject access request’ (SAR).  When you do this we will provide copies of the personal data that we hold about you, such as name, contact details, health information and any other personally identifiable information.  It will help us to respond effectively if you provide some detail of the information you require.  You will need to provide proof of identity and we will respond to subject access requests within 30 days.

If the information you require relates to a single or specific event, such as a repair or a copy of your tenancy agreement, you can request this information via our Customer Services team on 01733 385000 or via email customerservices@crosskeyshomes.co.uk

To make a subject access request or if you have any questions regarding CKH’s privacy policy, please contact the Data Protection Officer by emailing DPO@Crosskeyshomes.co.uk or sending your request to Cross Keys Homes, Shrewsbury Avenue, Peterborough PE2 7BZ. 

Applying to work at Cross Keys Homes

If you submit an application to work for us we will use your personal information to process your application and to produce and monitor recruitment statistics. We will not take up references without your prior permission. We will not share or disclose your information unless you have given us your consent or we are required to by law. Where we are required to carry out a Disclosure and Barring Service check we will comply with the law and your rights when carrying out these checks.

We retain personal information relating to unsuccessful applicants for no longer than 12 months, for use in the event of an appeal. We produce statistical information to assist with recruitment analysis.

Visiting our websites

When you visit one of our websites, we collect standard internet log information for statistical purposes.

  • We use cookies to collect information in an anonymous way, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. See the bottom of this page for more information on cookies.

  • We do not make any attempt to identify visitors to our websites. We do not associate information gathered from our sites with personally identifying information from any source.

  • When we collect personal information, for example via an online form, we will explain what we intend to do with it.  If you send us an email message or complete an on-line form, we will use your email/postal address and any information you provide to deal with and respond to your query or comments. This information may be disclosed to the appropriate office of Cross Keys Homes in order to deal with or respond to your message.

Our websites contain links to various third party websites. We are not responsible for the content or privacy practices of any external websites that are linked from our sites.

Applying to work at Cross Keys Homes

If you submit an application to work for us we will use your personal information to process your application and to produce and monitor recruitment statistics. We will not take up references without your prior permission. We will not share or disclose your information unless you have given us your consent or we are required to by law. Where we are required to carry out a Disclosure and Barring Service check we will comply with the law and your rights when carrying out these checks.

We retain personal information relating to unsuccessful applicants for no longer than 12 months, for use in the event of an appeal. We produce statistical information to assist with recruitment analysis.

Calling Cross Keys Homes

On some of our service lines, eg repairs, LifeLine, complaints and customer service we record calls.  This is to allow us monitor our services, transactions and for training purposes. 

How we use your contact details - telephone number and/or email

Text messages and contact via telephone provide a direct way to contact and share information with you about the services we can deliver to you. It can also help you receive important promotional/marketing messages which may interest or help you.

We may use your telephone number that you have provided us to keep in contact with you by text. 

Operational SMS/text/email messaging and calls

If you supply us with your telephone/email contact details, we may use them to call or send you operational text/email messages.

Examples of operational messages include:

  • Confirming a repair and/or a time and date for a repairs contractor to visit

  • Confirming a home visit

  • Confirming your rent/account payments and/or balance details

  • Sending a reminder about an appointment

  • Asking you to contact a named person

Use of cookies by this site

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

The tables below explains the cookies we use and why.

Table of first party cookies

First Party Cookies

Cookie

Type

Expiry

Linked Info

Functions

CFID

CFTOKEN

JSESSIONID

Persist

Persist

Session

2 hours

2 hours

Session end

Username

When a user logs in, maintains Authentication state.

VOPECRA

Persist

Never

Anonymous

Remembers when a user has elected to accept cookies.

 

Table of third party cookies

Third Party Cookies

Cookie

Name

Type

Expiry

Functions

Google Analytics

_utma

_utmb

_utmc

_utmz

Persistent

2 years

30 mins

End of session

6 months

These cookies are used to collect information about how visitors use our websites.  We use the information to compile reports and to help us improve the site.  The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

Click here for an overview of privacy at Google.

Google Translate

googtrans

Session

End of session

Stores your chosen language (if you decide to change it from English).  This means that you do not have to select your chosen language every time that you load a new page.

Click here for an overview of privacy at Google.

Google Maps

PREF

NID

Persistent

6 months

These cookies are used to remember Google Maps preferences.

Click here for an overview of privacy at Google.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.