How Persona use and protect personal information that you give us when you use this website.
This privacy notice will help you understand how we collect, use and protect your personal information. If you have any queries about this privacy notice or how we process your personal information, please contact our Data Protection Officer: DPO@Homegroup.org.uk or get in touch with us by one of the other methods set out at the end of this notice.
Who we are
The organisation responsible for processing your personal information is Home Group Limited, charitable registered society no. 22981R, of 2 Gosforth Park way, Gosforth Business Park, Newcastle upon Tyne, NE12 8ET. This means that we are a data controller under the General Data Protection Regulations (also known as GDPR) and the Data Protection Act 2018. Persona is the sales brand and registered trade mark of Home Group Limited.
What information we collect about you
The personal information you have provided, we have collected from you or we have received about you from third parties may include:
• name, address and address history, date of birth, and gender (and proof of your identity/photo ID)
• your National Insurance Number
• contact details, including telephone number and/or email address
• financial information, including pay slips, bank details and credit/debit card details (although we do not retain complete payment card information)
• details about your family and dependents (e.g. your marital status and number of children) and anyone authorised to act on your behalf if applicable
• information about your living circumstances (e.g. your employment details, income details and home ownership)
• profile data including your preferences and the choices you might make linked to your home purchase application
• general feedback and survey responses about what you like or don’t like about our properties and associated services • aggregated data such as statistical or demographic data which does not identify you individually • information about which marketing or advertising campaigns you may have seen or participated in linked to our properties and developments • information about any defects which may be reported before or after you move into one of our properties
How we collect information about you
We may collect information about you in the following ways: • when you apply for one of our properties by completing an application form either manually or on-line • when you register to receive information from us • when you call, write, email, text or meet with us or respond to a survey or enter a competition • automated technologies or interactions – when you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal information from you by using cookies and other similar technologies • when you make a complaint or provide feedback • when we take photographs at our events, at our properties and in our communities for general publicity use (we will only use photographs in which you can be identified if you have given us your written consent) • when we receive information about you from third parties including estate agencies • feedback you provide when you visit one of our properties or respond to one of our market research surveys
What we use your information for and the legal basis for processing
We process information about you in order to enable you to purchase a property from us and/or in order to improve the services we are able to provide in relation to viewing or buying one of our homes.
The legal basis for processing your information is usually that the processing is necessary for a contract we have with you or in relation to discussions before entering into that contract.
In other instances, we may have a legitimate interest to process your information for our internal business and administrative functions. Other types of legitimate interest we might have in processing or sharing your personal information may include preventing loss of revenue and fraud prevention.
The table below sets out the broad categories of information we process and the legal basis for processing it.
Using your personal information for automated decision making and profiling
We use your shared ownership payment history when we participate in the Rental Exchange Project with Experian. Rental payment history is used to build a credit score to enable you to gain access to more affordable finance should you so wish. The information is held by Experian in a secure database which can be accessed by lenders and other service providers when you apply for a loan or service that requires a credit check or proof of identity. Shared Ownership customers’ rental payment history will be shared with Experian unless you ask us not to do so. You can request that we stop sharing your rental payment history with Experian by emailing DPO@Homegroup.org.uk.
Who we share your personal information with
Where relevant, given the nature of the services provided to you, we may also share your information with the following categories of third parties: • our contractors and sub-contractors and other organisations acting on our behalf, including our maintenance contractors, , our out of office telephone service contractor, our market research contractor, customer communication platform providers (such as Microsoft Dynamics and Twilio), on-line payment solution providers (such as Allpay and Capita). Individuals can refuse to participate in the market research without prejudice and can opt out of future research by contacting DPO@Homegroup.org.uk • Estate agents who we may employ to provide a ‘hosting’ service at our properties • local authorities, • government agencies and departments and regulatory bodies (for e.g. Help To Buy) • the police and other emergency services. • utility companies and council tax offices to ensure billing details are correct estate agents, mortgage brokers, financial advisors, surveyors and valuers relating to a property sale • auditors • tracing agents, debt collection companies and credit reference agencies • other bodies for the prevention or detection of fraud We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We only permit our third party service providers to process your personal information for specified purposes and in accordance with our instructions.
Security of your information
We are committed to ensuring that your information is kept secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and operational procedures to safeguard and secure the information we collect online.
When you make a payment online, for example when you pay a reservation fee, we use a third party on-line payment solution provider such as Allpay or Capita to process the payments. These companies use an SSL (Secure Socket Layer) technology to protect your personal information. SSL is currently the preferred method to securely transfer credit card and other sensitive information over the internet. This encryption ensures that information sent during any transaction is protected against any unauthorised interception.
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.
Processing your information outside of the EEA
We will not transfer or store your personal information outside of the European Economic Area (EEA) unless:
• the country that we send the information to is approved by the European Commission as providing an adequate level of protection for personal information, or • the recipient has agreed with us standard contractual clauses approved by the European Commission, obliging the recipient to safeguard the personal information, or • another situation exists where the transfer is permitted under applicable data protection legislation.
If you choose not to give personal information
We may need to collect certain personal information by law, or under the terms of a contract we have with you. If you choose not to give us this personal information, it may in certain limited circumstances delay or prevent us from meeting our obligations to you. It may also mean that we cannot perform the services you have asked for. In some circumstances, it could mean that we will need to terminate our relationship with you. We will always tell you at the time we try to collect such personal data, if your refusal to provide that data may impact on our ability to provide services to you.
Using your personal information for marketing
We may use your personal information to tell you about relevant products and services. This is what we mean when we talk about ‘marketing’.
The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
We will only send you electronic marketing messages if we have your consent to do so and you can ask us to stop sending these marketing messages by following the unsubscribe link in any marketing email you receive.
Whatever you choose in relation to marketing, we may still need to contact you for other reasons to enable us to provide the products and services you have asked for and to tell you about changes to your existing contract with us.
We may ask you to confirm or update your marketing and contact choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.
If you change your mind about your marketing contact preferences you can update your choices at any time by following the unsubscribe link in any marketing email you receive or by contacting DPO@Homegroup.org.uk.
How long your personal information is kept
We will only keep your information for as long as necessary to fulfil the purpose we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and in accordance with our retention and disposal guidelines. Please contact DPO@Homegroup.org.uk to request a copy of our Retention Guidance.
Under the legislation you have the following rights in respect of your personal information:
• to obtain access to, and copies of, the personal information we hold about you i.e. to make a Subject Access Request (SAR)
• to require that we cease processing your personal information if the processing is causing you damage or distress • where we rely on your consent to process your personal information, you can withdraw your consent at any time by contacting your Persona host • to require us not to send you marketing communications • to require us to erase your personal information • to require us to restrict or for you to object to our data processing activities • to receive from us the personal information we hold about you which you have provided to us in a reasonable format specified by you, including for the purposes of you transmitting that personal information to another data controller (right to data portability) • to require us to correct the personal information we hold about you if it is incorrect
Please note that these rights may be limited by the legislation and we may be entitled to refuse requests where exceptions apply. You can find out more about your rights from the Information Commissioner’s Office: www.ico.org.uk.
Should you wish to exercise any of your rights, please contact our DPO by email DPO@Homegroup.org.uk or by using the contact details below.
Visitors to our website
Our website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Our website is not intended for children and we do not knowingly collect information relating to children.
If you provide any personal information relating to a third party (for example a joint purchaser or person living with you), you confirm that you have their consent to provide to us their personal information.
Customers who contact us via social media
When you contact us via social media such as Facebook or Twitter, we use a third party system such as Conversocial to manage your queries. The system keeps a record of the conversation so that we can effectively manage customer service.
How to complain
We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about how we use your personal information very seriously. We encourage you to contact us with any concerns about how we collect and use your personal information. We would also welcome any suggestions for improving our procedures and policies.
This privacy notice does not provide exhaustive detail of all aspects of our collection and use of personal information. We are happy to provide any additional information or explanation needed.
Any requests for additional information should be sent to our Regional Sales Managers, or to our office address below:
South - Krete Luca –firstname.lastname@example.org North – Christopher Bond – email@example.com
Any complaints will be dealt with in accordance with our complaints policy. You also have the right to make a complaint to the Information Commissioner’s Office at any time: www.ico.org.uk.
Changes to this privacy notice
We keep this privacy notice under regular review. This privacy notice was last updated on 27th February 2019.
How to contact us
If you want to request information about our privacy notice or exercise any of your data protection rights, please contact us in any of the following ways:
• Email our Data Protection Officer: DPO@Homegroup.org.uk • Email your Persona host (non-urgent enquiries) • Telephone our central sales team (urgent enquiries): 0800 030 8888 • Write to our Data Protection Officer at:
Persona 2 Gosforth Park Way Gosforth Business Park Newcastle upon Tyne NE12 8ET