Privacy Notice

Fortis Living’s Privacy Notice

This privacy notice applies to customers of the Fortis Living Group including tenants, leaseholders, shared owners, applicants for housing and people using our aids and adaptations service. It lets you know what happens to any personal data that you share with us, or any data that we may collect from or about you. It applies to all products and services and instances where we collect your personal data.

This privacy notice applies to personal information processed by, or on behalf of Fortis Living, Fortis Property Care (FPC) and Care and Repair Worcestershire (CRW).

Changes to this privacy notice

We may change this privacy notice from time to time by updating the Privacy Notice page on our website in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website – https://www.fortisliving.com/ or log in to your online account.

Fortis Living and our Data Protection Officer

Our contact address is Fortis Living, Festival House, Grovewood Road, Malvern, WR14 1GD.

We are a data controller of your personal data. We are registered with the Information Commissioner’s Office for the processing of personal data. To see the details of our registration visit www.ico.org.uk.

We have a dedicated data protection officer (DPO). You can contact the DPO by emailing dpo@fortisliving.com or by writing to the above address, marking it for the attention of the Data Protection Officer or visit https://www.fortisliving.com/contact-us.

 

  1. What personal information we process
  2. How we obtain your personal information
  3. How we use your personal information
  4. The legal grounds for processing your personal information (including when we share it with others)?
  5. 3rd Parties and organisations we share information with
  6. Data sharing with Welsh Water
  7. How and when you can withdraw consent
  8. How your personal information is kept secure
  9. How we share your information with fraud prevention agencies
  10. What to do if you need to make changes to your personal information
  11. Providing your personal information to us
  12. How we monitor and process your personal information
  13. Automated decision making
  14. How long we retain your personal information
  15. Your rights under data protection laws
  16. Your right to object
  17. Your right to request access to your personal information
  18. Requesting information from CCTV
  19. Marketing preferences and what they mean
  20. Contacting us

 

 

1. What personal information we process

Personal information that we’ll process in connection with providing you with an efficient and effective landlord service or appropriate advice and support, if relevant, includes:

  • Personal and contact details, such as title, full name, contact details and contact details history
  • Your date of birth, gender and/or age
  • Details of joint tenants, leaseholders or applicants
  • Family and household members, so we know who is living in the property, and can adapt any services to meet their needs
  • Records of your contact with us such as through our telephone call centre and online forms
  • Property addresses and occupation dates you have rented, leased or bought currently or in the past with Fortis Living or its predecessor organisations Festival Housing, Stanhope Court Housing Association and Worcester Community Housing
  • Information associated with managing your tenancy, lease or application including bank details; payments, visits, contacts, letters, interviews or legal enforcement actions
  • Marketing messages about our homes and services to you and analyses of that data, including history of those communications, whether you open them or click on links and analysing data.  Messages may include company news, community events, health and fitness events, safety messages, low cost home ownership opportunities, universal credit reform and other Government led policy changes
  • Information we obtain from third parties, if relevant, see section 5 below for more details
  • Fraud, debt and theft information, if relevant, including details of money you owe, suspected instances of fraud or theft, and details of any devices used for fraud
  • Criminal records information, if relevant, to manage, risk assess and adapt services due to any known criminal or anti-social behaviour activity 
  • Information about your health or if you are a vulnerable customer , if relevant
  • Information about your property, such as location, value, number of rooms, property type, permissions given and building work you’ve had done
  • Financial details about you, if relevant, such as your household income, source of income, details of your savings,borrowings and loans, and details of other expenditure
  • Information about your employment status, if relevant
  • Information about your property occupier status, such as whether you are a tenant, live with parents or are an owner occupier of the property where you live at the time of your application
  • Your nationality, if relevant 
  • Information about your marital status, family, lifestyle or social circumstances, including religion, ethnic origin, sexuality to monitor that our service provision is not discriminatory and reflects the diversity of our local communities
  • Insights about you and our customers gained from analysis or profiling of customers
  • Where relevant, information about any guarantor which you provide in any application
  • Third party transactions; such as where a person other than the account holder makes a payment, contacts us or acts on your behalf
  • Records of your internet browsing activity if you access Fortis Living’s Public Wi-Fi services including site names, category and device names and IP addresses.

 

2. How we obtain your personal information

We’ll collect personal information from the following sources:

  • From you directly, and any information from family members, associates or guarantors
  • Information generated about you when you use our homes and services including our public Wi-Fi services
  • From a 3rd Party organisation such as other Registered Social Landlords, local authorities, utility companies, social services, NHS, Police, Fire and Rescue Services. This list is not exhaustive.
  • Business partners (for example, property maintenance contractors, Worcestershire Telecare ) or others who are a part of providing your homes and services or operating our business
  • From other sources such as fraud prevention agencies, credit reference agencies, other lenders, HMRC, DWP, publically available directories and information (for example, telephone directory, social media, internet, news articles), debt recovery and/or tracing agents and other organisations, police and law enforcement agencies.

 

3. How we use your personal information

We use your personal information, including any of the personal information listed in section 1 above, for the following purposes:

  • Assessing an application for a tenancy, lease or service, including considering whether or not to offer you the tenancy, lease or service
  • Managing the tenancy, lease, application or service request you have with us
  • Updating your records, tracing your whereabouts and recovering debt
  • To monitor and to keep records of our communications with you and our staff
  • To develop and/or test the performance of our homes, services and internal processes
  • To improve the operation of our business and that of our business partners
  • To comply with, and follow guidance and best practice under any change to rules and requirements by governmental and regulatory bodies
  • For management and auditing of our business operations
  • To carry out checks at fraud prevention agencies where relevant
  • For market research and analysis and developing statistics
  • Assessing and profiling aspects of your home’s performance such as energy efficiency  and condensation
  • For direct marketing communications and related profiling to help us to tell you about relevant services and events including company news, community events, health and fitness events, safety messages, low cost home ownership opportunities, universal credit reform and other Government led policy changes
  • To provide personalised services to you, such as tailoring our homes and services and our digital offerings
  • Sharing your personal information with business partners and services providers when you hold a lease or tenancy to help provide landlord services
  • To facilitate the sale, merger or take-over of one or more parts of the Fortis Living group of companies.

 

4. The legal grounds for processing your personal information (including when we share it with others)?

We rely on the following legal bases to use your personal information:

  • Where it is needed to provide you with a property or services, such as:
    • Assessing an application for a tenancy, lease or service, including considering whether or not to offer you the tenancy, lease or service
    • Managing the tenancy, lease, application or service request you have with us
    • Updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate)
    • Sharing your personal information with business partners and services providers when you hold a lease or tenancy to help provide landlord services
       
  • Where it is in our legitimate interests to do so, such as:
    • Managing your tenancy, lease or service request, updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate)
    • To perform and/or test the performance of, our products, services and internal processes
    • To follow guidance and recommended best practice of Government and regulatory bodies
    • For management and audit of our business operations
    • To carry out checks at fraud prevention agencies where relevant
    • To carry out monitoring and to keep records of our communications with you and our staff
    • For market research and analysis and developing statistics
    • Assessing and profiling aspects of your home’s performance such as energy efficiency and condensation
    • For direct marketing communications and related profiling to help us to tell you about relevant services and events
    • To inform utility and council tax companies of occupants and occupancy dates and meter readings to ensure accurate billing can take place
    • For some of our profiling
    • Where we need to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations
    • Where we contact you through automated text, email or other electronic messaging to remind you of appointments, payments due or to take part in customer satisfaction surveys
       
  • To comply with our legal obligations
     
  • With your consent or explicit consent:
    • For some direct marketing communications
    • For some of our profiling and other automated decision making
    • For some of our processing of special categories of personal data such as about your health, if you are a vulnerable customer or some criminal records information
    • For some of our statutory and regulatory returns
    • For a public interest, such as:
      • Processing of your special categories of personal data such as about your health, criminal records information (including alleged offences), or if you are a vulnerable customer
    • For your vital interests where you may be physically or legally incapable, such as:
      • Providing personal details, health and vulnerabilities in the event of a medical emergency where you are unable to provide those details yourself.

         

5. 3rd Parties and organisations we share information with

As stated in section 2 and 3 above we may source or share personal information with 3rd parties.

Below, is a list of the types of organisations with whom some data sharing occurs where it is relevant to do so and for the reasons stated. Please note , your personal information will only be shared with an organisation where it is relevant to you.

Third party sharing

Type of Organisation

Reason for Sharing Data

Legal Basis for Processing Data

Asbestos Survey Provider

Asbestos Surveys

Performance of Contract, Legitimate Interest, Legal Obligation

Choice Based Lettings scheme Provider

Allocation of properties within Fortis Living / Local Authority Lettings Policy

Statutory & Legal obligations, Legitimate Interests of Fortis Living

County Courts

Application for Money Order or Judgement, Application for Court Order, Undertaking or Injunction

Performance of Contract, Legitimate Interest, Legal Obligation

Data Protection Regulator

In response to Queries and complaints from Customers and Members of Public

Positive Consent by Recipient

Direct Debit Service Provider

Provision of Direct Debit Service

Performance of Contract, Statutory & Legal obligations, Legitimate Interests of Fortis Living

Energy Utility Companies

Correct Billing Dates / Prevention & Detection of Fraud

Statutory & Legal obligations, Legitimate Interests of Fortis Living

Fire & Rescue Services

Identification of properties with  Oxygen bottles / Hoarding Issues

Public Interest / Vital Interest / Legitimate Interest

Governmental Departments

CORE Letting & Sales data, HMRC

Statutory & Legal Obligations

Positive Consent

Health Authority

Provision and monitoring of a Falls response service, Occupational Therapy Assessments

Performance of Contract, Legitimate Interest

Housing Ombudsman

Response to complaint made to the Housing Ombudsman

Positive Consent by Recipient

Inland Revenue

Collection of Tax , Prevention and detection of fraud

Statutory & Legal Obligations

Local Authorities

Council Tax Assessment,  Housing Benefit Assessment, Homelessness Investigations, Environmental & Other Statutory Nuisance Investigations, Private Sector Aids & Adaptations

Statutory & Legal obligations, Legitimate Interests of Fortis Living

 Maintenance Contractors

Provision of Property Improvement Works

Performance of Contract, Legitimate Interest

Online Fraud Prevention Service Provider

Prevention & detection of Tenancy Fraud

Legitimate Interests of Fortis Living

Online Marketing Service Providers

Marketing of Fortis Living Homes & Services

Positive Consent by Recipient

Out of Hours Contact Service Provider

Provision of Out of Hours Repairs & Emergency Contact Service

Performance of Contract, Legitimate Interest, Vital Interests of Data Subject

Payment Service Providers

Receipt and detail of Payments made to accounts through  AllPay, Post Office and Capita Payments

Performance of Contract, Legitimate Interest

Police Forces

Prevention & detection of Crime / Management of Tenancy Breaches

Public Interest / Vital Interest / Legitimate Interest

Registered Social Landlords

Performance of contract for Repairs Service

Performance of Contract, Legitimate Interest

Water Utility Companies

Correct Billing Dates / Prevention & Detection of Fraud

Statutory & Legal obligations, Legitimate Interests of Fortis Living

Web Service Provider

Provision of Online Tenancy Account

Performance Of Contract

In addition we may share and/or receive data from:

  • Other organisations and businesses who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions
  • Market research organisations who help us to develop and improve our products and services

If your hosuehold has entered a new tenancy, purchased a low cost home ownership property, or bought your property through the Right to Buy or Right to Acquire, your personal informaion will have been shared with the Government for research and statistical purposes.  The data helps Government understand better the social housing market and inform social housing policy.

The information is provided via CORE (COntinuous REcording). It is anonymised so no names, dates of birth or contact details are included.  It will not effect any benefits or services that you get.  It is transferred securely via a Government Portal where appropriate organisational and technological safeguards are applied in accordance with Data Protection requirements and guidelines.

 

6. Data sharing with Welsh Water

Changes to The Water Industry (Undertakers Wholly or Mainly in Wales) (Information about Non-owner Occupiers) Regulations 2014 that came in to effect from the 1st January 2015 mean that there is a legal obligation on all landlords( whether based in Wales or not) with properties supplied by  Welsh Water to share some personal information with them. If you would like to see the regulations click here.

Fortis tenants living in the Shropshire and Hereford areas whose water is supplied by Welsh Water will have data relating to their occupancy passed directly through to Welsh Water from 31st May 2016

This applies to most postcodes beginning with HR1, HR2, HR3, HR4, HR5, HR6, HR7, HR8, HR9, SY7 and SY8.  It does not apply to leaseholders and shared owner occupiers of properties in those postcode areas.

The details shared are:

  • Full name of every occupant in a rented property
  • Address of the property
  • Date of birth of the occupant (s)
  • Date the tenancy started (when the occupant moved in).

Should you end your tenancy, Welsh Water will also be notified of the end date of your tenancy within 21 days of the termination date.

No other personal data will be passed across.
 

7. How and when you can withdraw consent

When we are relying upon your consent as stated in Section 4 to process personal information, you can withdraw this at any time by contacting us using the details at the bottom of this page. Examples of where you can withdraw your consent are:

  • For some direct marketing communications
  • For some processing of special categories of personal data such as your ethnicity, religion, sexuality, health, if you are a vulnerable customer or some criminal records information
  • For some of our statutory and regulatory returns
  • Where we contact you through automated text, email or other electronic messaging to remind you of appointments.
     

8. How your personal information is kept secure

We have put in place appropriate operational, technical and security measures to reduce the risk of your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This includes use of encryption where relevant. 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.  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 and our business partners are based in the UK but sometimes your personal information may be transferred outside the European Economic Area. If we do so, we’ll make sure that any transfers will be done securely and only after assessing the adequacy of local data protection laws and regulations.

 

9. How we share your information with fraud prevention agencies

Fortis Living is a member of the National Anti-Fraud Network. This means that where we suspect fraud may be taking place we will process personal data in accordance with the data protection laws through this network with the purpose of preventing and detecting the fraud.

 

10. What to do if you need to make changes to your personal information

You should tell us so that we can update our records using the details in the Contact Us section of our website, by calling our Contact Centre on 0330 123 0700 or by logging on to your Online Account, where relevant. We’ll then update your records where appropriate.

 

11. Providing your personal information to us

We’re unable to provide you with a tenancy, lease or landlord service if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.

 

12. How we monitor and process your personal information

In this section monitoring means any; listening to, recording of, viewing of, intercepting of, or taking and keeping records of calls, email, text messages, social media messages, in person (face to face) meetings and other communications.

We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.

 

13. Automated decision making

Currently, no decisions are made about you using only technology, where none of our employees or any other individuals have been involved.

 

14. How long we retain your personal information

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

  • For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
  • For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
  • Retention periods in line with legal and regulatory requirements or guidance as detailed in Fortis Living’s Data Retention Policy

 

15. Your rights under data protection laws

These rights don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not.

  • The right to be informed about the processing of your personal information
  • The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
  • The right to object to processing of your personal information
  • The right to restrict processing of your personal information
  • The right to have your personal information erased (the “right to be forgotten”)
  • The right to request access to your personal information and to obtain information about how we process it
  • The right to move, copy or transfer your personal information (“data portability”)
  • Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you

You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/. You can also contact us using the details below.

 

16. Your right to object

You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us using the details below.

 

 17. Your right to request access to your personal information

The current Data Protection law provides individuals with rights over how their personal data is processed. These rights entitle you to a confirmation that your data is being processed; confirmation on how and why your data is processed; the purposes for which it is used; and to whom your data may be disclosed.

You have a right to see your own personal data. Please note that this does not necessarily mean you will see copies of documents that contain your personal data. Although, if the easiest way to provide the relevant information is to supply copies of original documents, we will do so where possible.

To enable us to respond efficiently to your request and for more information on your rights and timescales please download and complete a Data Request Form. pdf 300KB from our website. The form can also be obtained by emailing  dpo@fortisliving.com or contacting us using the details below.

 

18. Requesting information from CCTV

Fortis Living operates and controls a number of CCTV systems. Images are continuously captured and stored on these systems for the purposes of crime prevention, reduction of anti-social behaviour and public safety. Images are stored digitally for a minimum of 30 days.  Fortis Living has registered this data processing activity with the Information Commissioner’s Office.

If you have a query about any of our CCTV systems please complete the CCTV Enquiry

 

19. Marketing preferences and what they mean

We may use your phone numbers, email address and social media or digital channels (for example, Facebook, Google and message facilities in other platforms) to tell you about relevant services and events including company news, community events, health and fitness events, safety messages, low cost home ownership opportunities, universal credit reform and other Government led policy changes according to your marketing preferences.

You can opt out of any email or text marketing by following the unsubscribe links.  If you receive a marketing call from us, you can ask the person who called you to opt you out. You can also write to us at: Fortis Living, Festival House, Grovewood Road, Malvern, WR14 1GD, marking it for the attention of the DPO.

 

20. Contacting Us

If you have any questions about this privacy notice, or if you wish to exercise your rights you can contact the DPO, by emailing dpo@fortisliving.com, or by completing our online enquiry form on our Contact Us page.

Our contact address is Fortis Living, Festival House, Grovewood Road, Malvern, WR14 1GD, marking it for the attention of the DPO.