Privacy Policy
A legal disclaimer
Elm Tree Housing – Customer Privacy Policy
1. Purpose of the Policy
1.1. The Customer Privacy Policy outlines what you can expect from Elm Tree Housing when we collect your personal information in order to deliver services to you.
1.2. This policy explains how we collect your personal information; what data we collect; why we collect it and our legal basis for doing so; how we protect your information; and what rights you have in relation to the personal information we hold about you.
1.3. As a Data Controller, Elm Tree Housing takes your privacy seriously. We are committed to handling your personal data securely, respectfully, and in accordance with applicable Data Protection Law — including the UK General Data Protection Regulation (UK-GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR).
We have appointed a Data Protection Officer who you can contact to exercise your rights under Data Protection Law:
📧 dataprotectionofficer@elmtreehousing.org.uk
2. Scope of the Policy
2.1. All staff, representatives, and contractors of Elm Tree Housing are required to comply with this policy when handling customer data.
2.2. This policy applies across all Elm Tree Housing operations and any subsidiaries or partners we may work with in delivering services.
2.3. We regularly review and update this Privacy Policy, and the latest version will always be available on our website.
3. Detailed Policy Content
3.1. Information We Collect
We collect a range of personal information including:
- Full name, contact details, date of birth, National Insurance number, bank details, ID documents, employment status, housing needs, financial information, photographs, CCTV images, guarantor details, references, and complaints.
- Special category (sensitive) data such as health and accessibility needs, racial or ethnic origin, religious beliefs, and sexual orientation, where applicable.
3.2. How We Collect Your Information
We gather information directly from you and also from:
- Local authorities and government departments
- Previous landlords
- Healthcare providers
- Our own internal systems
3.3. Why We Collect Your Information
We process your personal data to:
- Deliver housing services and support
- Assess and process housing applications and eligibility
- Manage tenancies and leases
- Maintain and repair properties
- Prevent fraud or illegal subletting
- Assist with crime prevention and security
- Verify your identity
- Provide additional services like tenancy or financial advice
- Meet legal and regulatory requirements
- Improve our services through feedback and performance monitoring
We process this information on the basis of legitimate interest, contractual necessity, legal obligation, or — in the case of sensitive data — with your explicit consent.
We do not use your data for automated decision-making.
3.4. Sharing Your Information
We may share your data with trusted third parties who work on our behalf, including:
- Repairs and maintenance contractors
- Utility providers
- Local authorities and other housing associations
- Debt recovery or fraud prevention services
- IT and cloud system providers
All such parties are contractually required to comply with data protection laws. We do not sell your data.
If you wish to opt out of marketing communications, we will honour your request.
3.5. Sending Information Overseas
Elm Tree Housing operates entirely within the UK. We do not transfer personal data outside the UK.
If we use cloud-based services with overseas servers, we ensure appropriate legal safeguards (such as Standard Contractual Clauses) are in place.
3.6. Data Retention
We keep your data only for as long as necessary, in line with our Data Retention Schedule, which complies with statutory and legal requirements.
When no longer needed, your data will be securely deleted or destroyed.
For more information, please contact:
3.7. Security Measures
We have strict technical and organisational measures in place to protect your personal information from:
- Unauthorised access
- Accidental loss
- Unlawful processing
We limit access to those who have a genuine business need and always verify your identity before discussing your account.
In the event of a data breach affecting you, we will notify you within 72 hours of becoming aware of the incident.
3.8. Your Rights
You can exercise the following rights:
- Access your data
- Correct inaccurate or outdated information
- Request deletion (where we no longer have a legal reason to retain it)
- Restrict processing in certain cases
- Object to processing
- Data portability – request a copy in a machine-readable format
- Withdraw consent, where consent is the legal basis for processing
3.9. Complaints
If you're not satisfied with how we’ve handled your data, you can raise a complaint with the Information Commissioner’s Office (ICO):
4. Applicability
4.1. This policy applies to all Elm Tree Housing customers.
4.2. All employees handling customer data must comply with this policy.
4.3. Third parties processing data on our behalf are also required to comply.
5. Definitions
5.1. Personal Data: Any information relating to an identifiable individual.
5.2. Special Category Data: Sensitive information such as health, race, religion, or sexual orientation.
5.3. Processing: Collecting, storing, using, or destroying personal data.
Policy Impact
An Equality Impact Assessment has been completed and confirms this policy does not negatively impact any customer groups.
It is available in multiple formats:
- Online via our website
- Hard copy by request
- Summary version also accessible