Privacy notice

Processing Purpose

Legal basis for Processing

Applications for rented properties

When you apply to live in an Extracare Village, we collect information directly from you and from relevant third parties, about you and your household, in order to assess your eligibility and suitability for the application you have made.

We receive your contact details and housing need information from the Local Authority if you have been nominated by them and we take up references from former landlords.

Some decisions are made automatically about your eligibility, based on the answers you provide in your application, but you will always be given the opportunity to challenge the decision.

This processing is necessary for being considered for, and for signing up to, a tenancy agreement, which means entering into a contract with us. We need to know that you are eligible, and that you can afford the property, and/or sustain your tenancy and we may need to offer you additional support as part of your tenancy.

If you provide us with special categories of data, such as health, in your housing application, we will process this data only as far as it is necessary for us to manage your application and ensure you are housed appropriately and safely, in line with our legal and statutory obligations as a housing provider and employer.

In some cases, we will process information about criminal offences and convictions, where it is necessary to do so in order to protect the safety and wellbeing of individuals and our communities.

When we ask for information about race/ethnic origin, religion, health, or sexual orientation, this is where it is necessary for us to monitor and improve equality of opportunity and treatment, in the substantial public interest, and it is optional for you to provide this information.

 Shared Ownership applications

When you apply to purchase a share of an ExtraCare home, we collect information directly from you and from relevant third parties, about you and your household, in order to assess your eligibility and suitability for the application you have made.

We will communicate with your solicitor and mortgage provider to facilitate the purchase.

This processing is necessary for entering into a purchase agreement with us. We need to know that you are eligible and can afford the property.

In some cases, we will process information about criminal offences and convictions, where it is necessary to do so in order to protect the safety and wellbeing of individuals and our communities.

When we ask for information about race/ethnic origin, religion, health, or sexual orientation, this is where it is necessary for us to monitor and improve equality of opportunity and treatment, in the substantial public interest, and it is optional for you to provide this information.

Outright Sales

When you apply to purchase a share of an ExtraCare home, we collect information directly from you and from relevant third parties, about you and your household, in order to assess your eligibility and suitability for the application you have made.

We will communicate with your solicitor and mortgage provider to facilitate the purchase.

This processing is necessary for entering into a purchase agreement with us. We need to know that you are eligible and can afford the property.

In some cases, we will process information about criminal offences and convictions, where it is necessary to do so in order to protect the safety and wellbeing of individuals and our communities.

When we ask for information about race/ethnic origin, religion, health, or sexual orientation, this is where it is necessary for us to monitor and improve equality of opportunity and treatment, in the substantial public interest, and it is optional for you to provide this information.

CORE reporting

So that the Ministry of Housing, Communities and Local Government (MHCLG) can produce statistical information, we report information to them about our lettings and shared ownership sales via the CORE (Continuous Recording) system. The information provided does not include your name or full address, but it does contain special categories of data.

The processing of this information by the MHCLG is necessary for the performance of a task in the public interest and so far as the data includes special categories, the MHCLG states that the processing is necessary for reasons of substantial public interest. The data is used to compile statistics on the use of social housing, including reviewing equality of opportunity and treatment.

Please see the CORE website for more details.

ExtraCare customers

When you are an ExtraCare customer, we will collect information from our interactions with you, including any complaints or allegations that are made by you, or about you, and we process this information to allow us to manage our relationship with you, collect your rent, and provide you with tenancy or sales related services appropriate support services and to manage any complaints or alleged ASB or similar issues.

This will involve sharing information with, and receiving information from, third parties, as explained below.

Where crimes have been committed or alleged, we share information with the police and other agencies with investigative and prosecution powers.

Where we have concerns about anyone requiring safeguarding for any reason or requiring protection from financial abuse due to a mental or physical health issue, we share information with the relevant authorities in order to help the people concerned.

We share rent information with local authorities for the purposes of administration of appropriate benefits;

Where local authorities require information for council tax, we confirm tenancy information to allow the correct tax to be paid.

We share information with debt collection agencies so they can collect debts on ExtraCare’s behalf.

We sometimes share information with utilities companies so they can collect debts on bills.

Personal data is shared between teams internally at ExtraCare, but is only shared, accessed and used on a need-to-know basis, to enable relevant teams to carry out their tasks.

Most of the information we collect and use as part of our ongoing interactions with you is necessary for the performance of your contract and is linked to ensuring both you and ExtraCare are complying with the requirements of the contract.

We have a legal obligation to keep business and financial transaction records as appropriate.

We will offer you further support based on both our and your legitimate interests to enable you to sustain your relationship (tenancy/shared ownership relationship) with us to the best of your ability.

If we contact you by email or text to let you know about our services, we will do so based on either our legitimate interests of keeping you updated about the services you receive from ExtraCare, or based on your consent where we are contacting you about new services.

If we refer you to an external agency for further support, we will do so only with your consent to pass your details on to them, unless we believe there is an overriding lawful basis for the referral without your consent.

When we share information for the reasons explained, we will do so on the basis of the fact it is necessary to protect individuals and communities, is for a task in the public interest (crime, benefits and tax payment) or for the legitimate interests of debt collection.

Volunteers

If you are a volunteer we will usually collect your name and contact details and where/how you volunteer for the Charity. Where it is appropriate, we may ask for additional information.  We mainly use your data to:

The lawful basis for processing your data if you are a volunteer is our legitimate interest in order to Administer your volunteering activity. This is used to keep a record of your relationship with us; ensure we know how you prefer to be contacted and to understand how we can improve our services and information.

Our support services

ExtraCare does not just provide housing, we also provide support to people who need it, through our specialist services, some of which are linked to your tenancy and some of which are standalone, for example help with money management, getting back into work, or more general day to day support.

We process your data as part of providing this support on the basis of our contract with you, where it is tenancy-linked support, or on the basis of it being necessary for complying with our legal obligations or carrying out a task in the public interest.

Where we process special categories of data, or criminal information, about you as part of providing this support, we do this where it is necessary to protect individuals in line with our legal and statutory obligations as an employer and as a housing and support provider. Where this (or another) basis is not appropriate, we will ask for your consent.

Emergency situations

Unfortunately, there will always be emergency situations that negatively impact on our customers, employees and wider communities, and we will respond as appropriate and as quickly as possible in order to protect people and property. Whether we are responding to fire, flood, crime, safeguarding issues, pandemic, or any other emergency situation, ExtraCare will treat people’s health and wellbeing as a priority, which we acknowledge includes protecting personal data and ensuring it is handled lawfully and securely.

Processing of data in the immediate response to emergency situations is done only where it is necessary to protect individuals and communities, on the basis that we are acting under employment or social protection law, or in the public interest / substantial public interest.

Equality of treatment & opportunity

ExtraCare is dedicated to treating everyone fairly and providing equal opportunities, regardless of differences in race or ethnic origins, religious or philosophical beliefs, physical or mental health or sexual orientation. In order to monitor and improve performance in this area, we collect information about race, beliefs, health and sexual orientation from customers and employees, if you are happy to provide this information.

The processing of these special categories of data is necessary for a task which is in the substantial public interest, specifically for the purposes of identifying and monitoring equality of opportunity and treatment between different groups of people, with a view to enabling equality to be promoted or maintained.

Sharing your data with our ‘Processors’

When ExtraCare uses other companies to supply goods or services on our behalf, sometimes we need to share relevant information with those suppliers and contractors so they can carry out that work. They are known as our ‘Processors’ and are legally bound by contract to act only on our instructions regarding your personal data, and not use it for their own purposes.

The relevant legal basis for each Processor we use will be dependent on the type of work they are carrying out for us, and our legal basis for undertaking the processing that is linked to that work.

For example, we carry out emergency repairs work on the basis of our contract with you, and in some circumstances the repairs may be contracted out to contractors who need your address etc. in order to carry out the repair. This makes the contractor our Processor.

The contracts we use with Processors comply with Article 28 of the General Data Protection Regulation (GDPR), which rules how Processors are appointed, and sets out their relevant responsibilities.

Sharing your data with other contractors

Sometimes, we share personal data with suppliers, contractors or consultants where they process the data on the basis of their own knowledge and expertise, not just acting on our instructions. For example, solicitors. In these cases they are not our Processors, but instead are Data ‘Controllers’ in their own right.

As Data Controllers these organisations have their own legal obligations and responsibilities to handle your data lawfully and safely and are also bound by contract to comply with their data protection obligations.

We share information with contractors etc. who are Controllers only when it is necessary for us to carry out our tasks in the public interest, to carry out our legal obligations, or for our legitimate interests of outsourcing the provision of some services and of providing appropriate support, to enable us to run the business efficiently. We do not share your data with any Controllers that we are not confident will protect your data, and therefore we protect your rights, freedoms and interests.

Insurance

If you are an ExtraCare insurance customer, we will process your information so we can provide you with a policy and to manage any claims you make, which may involve sharing information with third parties about the circumstances in order to assess the claims.

This processing is necessary for the performance of your insurance contract. If it is suspected that a claim is not legitimate, we will process information to protect our business from fraudulent claims, which breach the insurance contract.

Complaints

In order to investigate and respond to complaints or allegations against ExtraCare or an employee or customer of ExtraCare, or complaints and allegations made about neighbours, or any other topic, we will usually require contact details and information about the complaint from you or your representative. We will request the minimum amount of information from you, and only use it for the purposes of the investigation.

Customer complaint related processing is done on the basis of it being necessary for us complying with the terms of your contract with us. For complaints from non-customers, depending on the nature of the complaint, the processing is necessary for us to comply with our legal obligations or for carrying out our tasks in the public interest. If special categories of data are processed (including health, race, religion, sexual orientation) it is on the basis of being necessary for defending a legal claim or for acting in the substantial public interest. This includes responding to elected representatives such as MPs, who have raised a matter on your behalf.

General contacts

For members of the public who are not customers but come into contact with ExtraCare in another way, such as to make an enquiry, we will collect information from our interactions with you, so that we can provide you with the information you have requested.

We process this information on the basis that it is necessary for our legitimate interests of responding to your enquiry, complaint or allegation, as appropriate. If we need to process any special categories of data in order to handle the issue, we do so with your explicit consent, or on the basis of it being necessary for a task in the substantial public interest, such as reviewing equality of opportunity and treatment.

Business contacts

Contact details for people, organisations and companies we work with is personal data and we treat it accordingly. We will use it only as part of our relationship with your organisation, whether we work in partnership or have a customer/supplier relationship.

This processing is based on our legitimate interests of managing business relationships appropriately. We use the data only for the purposes explained, keep the data secure and safe, and protect your rights, freedoms and interests.

Surveys and feedback

In order to understand our customers’ experiences and improve our services and products, we will contact you at various “touch-points” during our relationship with you and ask you to complete a survey and give us feedback, by email, text or over the telephone. We contract with specialist companies to carry out surveys on behalf of ExtraCare, which involves sending them your contact details and they gather your responses for us. You can opt out of this sort of contact if you prefer.

ExtraCare, and the specialist companies we work with, process data in order to ask for your feedback, based on our legitimate interests of improving our customer services and products.

Marketing

We will send you information that we think will be useful or of interest to you about the services we provide, whether they are paid for services or free of charge. We will sometimes make decisions about what information to send based on your profile, for example your age if we are letting people know about age-related services such as our over 55s schemes.

Meta Pixel: We use Meta Pixel on our website to understand and deliver ads tailored to your interests on Facebook. This technology allows us to measure the effectiveness of our advertising by understanding the actions users take on our website. The data collected by Meta Pixel is anonymous and does not contain personally identifiable information. By using our website, you consent to the use of Meta Pixel for these purposes. For more information on how Facebook collects and uses data, please review Facebook’s Data Policy.

ExtraCare will send you marketing materials on the basis of our legitimate interests of increasing our customers’ knowledge of other relevant services and products.

We will only send you emails or texts (electronic direct marketing) with this type of information if we have your consent to do so. If you have provided consent, you can with draw this at any time. For commercial services or products, which includes where you have bought, or entered into negotiations with us, for a similar service or product, this is regarded by the law as implied consent. However, every time we send an email or text you will have the option to unsubscribe from similar marketing messages.

We will have regard to the ICO’s Code of Practice on Direct Marketing in determining our approach. We will respect people’s choices not to receive direct marketing from us. We will not use ‘bought in’ lists of potential targets unless the respective individuals on the lists have consented to their data being shared with ExtraCare for the relevant purpose beforehand and will ensure we have either specific consent, or that we can rely on the ‘soft opt in’ for any electronic marketing communications we send to customers or potential customers.

Exercising of Data Protection Rights

If you approach us about exercising any of your Data Protection rights, such as accessing copies of your data, or objecting to the way your data is being processed, we need to obtain relevant information from you in order to identify that you are the data subject in question or acting on their authority.

When we fulfil requests such as these, specialist staff members will review the documents in question in order to fulfil the request lawfully, which will include redacting information about third parties.

The information processed to check your identity and to fulfil your request is only used for these purposes and is kept securely.

This processing is carried out as necessary for us to carry out our legal obligations of upholding your Data Protection rights.

Recruitment

If you apply for a job with ExtraCare, we collect information about your suitability via our trusted recruitment partner organisations.

Most of this processing is on the basis that it is necessary for an employment contract, or entering into an employment contract, with ExtraCare.

Employees

We collect and process information about current and former employees as part of managing your relationship with ExtraCare.

Most of this processing is on the basis that it is necessary for managing your employment contract with ExtraCare, and for us to fulfil our legal obligations under employment law in relation to current and former employees.

Please see the Employee Privacy Notice on the Extracare website and Sharepoint for more details.

Supporters

If you support us, for example you make a donation or buy something from our shops, we will usually collect: your name; your contact details; your bank or credit card details (In order to process your donation, for example); whether you have agreed to receive marketing material from us. Where it is appropriate, we may ask for additional information. 

We mainly use your data to: provide you with the service or information you have asked for; administer your purchase or donation, including processing gift aid; keep a record of your relationship with us; ensure we know how you prefer to be contacted; understand how we can improve our services and information.

The lawful basis for processing your data is our legitimate interest.

CCTV

ExtraCare uses CCTV in our offices and in some of our housing/schemes for the safety and security of premises, colleagues, customers and any third parties. CCTV footage can be disclosed to those organisations acting on official authority, including the police.

We process data from CCTV for the purposes of our legitimate interest of protecting our premises, and for carrying out tasks in the public interest/substantial public interest by protecting our people and supporting investigations into crime and fraud, for example.

Telephone calls

Phone calls to our main telephone number are recorded so that we can monitor the quality and content of calls.

This processing is on the basis of our legitimate interest of providing good customer service, as well as protecting our colleagues and other people from any problems or issues arising from ambiguity in phone call conversations.

Website

We collect information you submit through our website, and through the use of Cookies. Please see the Cookies section below for more details.

Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback.

This information is processed for our legitimate interests of responding to any enquiries you make through our website, and to help us understand and analyse the effectiveness of our website.

Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘About Hotjar’ section of Hotjar’s support site.

If you wish to tell Hotjar not to collect your data, please see Hotjar’s ‘Do Not Track’ page.