Privacy Policy

This Privacy Policy is published in conjunction with our Fair Processing Notice and cookies statement(s) to help you to understand how we collect, use, and protect your personal information. If you have any queries about either document, or how we process your personal information, please contact:

Head of Governance

CityWest Homes Ltd

21 Grosvenor Place

London

SW1X 7EA

email: governance@cwh.org.uk

Handling Personal Data

CityWest Homes Ltd (CWH) handles personal information in compliance with Data Protection legislation and General Data Protection Regulations (GDPR). We recognise the importance of the correct and lawful processing of personal data in maintaining confidence in our operations. We fully endorse and adhere to the principles set out in legislation.

As a provider of services for Westminster City Council (WCC), CWH collects, holds and processes a considerable amount of information, including personal information about residents, people it provides services to, and other people. It does this to provide its services in the most effective and efficient way that it can.

CWH recognises that it has a duty to people whose information it holds to treat that information responsibly, keep it safe and secure, and process it correctly and proportionately. This document broadly explains what information we collect, the purpose for processing, categories of personal information and who we may share it with. Information we collect

There are various reasons why we need to collect personal data.

We will collect personal details appropriate to the service you require. In some areas, this may simply mean registering your name, address and email details. Similarly, we may need information because of legal requirements.

We may also collect additional information from you if you complete any other forms on our website, or if you contact us with comments or specific requests.

We may contact you to let you know about new online services, or get your feedback on how we're performing. In any event, we will only require information that is absolutely necessary and does not constitute an invasion of privacy.

Please note that calls to Customer Services may be monitored or recorded.

Use of personal information

CWH will endeavour to safeguard the privacy of its customers and website visitors.

We will not use the personal information you provide us with for marketing purposes unless you actively consent for us to do so.

We may pass your details on to third party service providers who are contracted to Westminster City Council (WCC) or CWH in the course of providing our services, or dealing with your request(s). These third parties are obliged to keep your details securely, will use them only to fulfil your request(s).

Please note we will continue to apply the same level of care to safeguard your privacy and use of your information across all our services..

For more information about how we process personal data please see our Fair Processing Notice.

Information to improve our website

We collect web statistics automatically about your visit to our site based on your IP address. This information is used to help us track what people are doing on the site so that we can improve it. We don't use this information to identify you as an individual and you will remain anonymous, unless you're asked to identify yourself by completing a form or an online transaction.

Use of IP addresses and cookies

Cookies enhance your experience using our website. 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 more efficiently, as well as to provide information to the owners of the site.

We use cookies to audit the use of our website and help us to customise the website for your visit. We do not store or transmit any personally identifiable data on these cookies. You can change your cookie setting at any time in the security settings in the browser you use to access the internet. Please note however, that rejecting all cookies may impact your enjoyment or use of this website.

We collect IP addresses (a unique string of numbers that identifies each computer) only for the purposes of system administration and to audit the use of our site. We do not link IP addresses to anything personally identifiable, which means that while your user session will be logged you will remain anonymous to us.

Please see our separate cookies statement for more detail. If you have any questions about our use of cookies or about how we collect and store your data, then please contact governance@cwh.org.uk. For more information on cookies and how cookies work, please visit http://www.allaboutcookies.org/

External Links

The website may contain links to third party websites such as WCC’s, which are outside our control and are not covered by these terms. You understand and agree that if you access such third party site using the links provided, the operators of those sites may collect information from you which will be used by them in accordance with their own privacy policies.

Your use of the third party websites will therefore be governed by the privacy policies of those sites and not by this Privacy Policy. CWH shall not be responsible for the actions of any third party website operators.

Your rights to access your personal information

Under Data Protection legislation you have the right to ask to see the information which CWH holds about you and why it is held

You also have additional rights that refer to how we hold and use your information. Consequently, under certain circumstances, by law you have the right to:

  • withdraw consent and the right to object and restrict further processing of your data; however, where legally enforceable this may affect service delivery to you;
  • request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it;
  • request your data to be rectified if it is inaccurate or incomplete;
  • have your data transferred or copied should you move to another authority;
  • not be subject to automated decision-making including profiling.

If you want to see the information we hold about you then you must ask for the information in writing and give your full name and address. You should send your request to:

Governance Team

CityWest Homes Ltd

21 Grosvenor Place

London

SW1X 7EA

email: governance@cwh.org.uk

Where it is appropriate for CWH to respond directly to requests for access to personal data, we aim to comply as quickly as possible. We will ensure that we deal with requests within 20 working days of receipt, unless there is a reason for delay that is justifiable under Data Protection legislation.

Last updated:  24th May 2018

Fair Processing Notice

This Fair Processing Notice is published in conjunction with our Privacy Policy and cookies statement(s) to help you to understand how we collect, use, and protect your personal information.

Handling Personal Data

CityWest Homes Ltd (CWH) handles personal information in compliance with Data Protection legislation and General Data Protection Regulations (GDPR). We recognise the importance of the correct and lawful processing of personal data in maintaining confidence in our operations. We fully endorse and adhere to the principles set out in legislation.

As a provider of services for Westminster City Council (WCC), CWH collects, holds and processes a considerable amount of information, including personal information about residents, people it provides services to, and other people. It does this to provide its services in the most effective and efficient way that it can.

CWH recognises that it has a duty to people whose information it holds to treat that information responsibly, keep it safe and secure, and process it correctly and proportionately. This Fair Processing Notice broadly explains what information we collect, the purpose for processing, categories of personal information and who we may share it with.

To understand how your own personal information is processed you may need to refer to any personal communications you have received, check notices CWH has published or contact us directly to ask about your personal circumstances.

Personal data

This Notice applies to the handling of personal data. This is data relating to a living individual who can be identified from the data, or from that data and other information which we hold or which is likely to come into our possession. It includes any expression of opinion about an individual or any indication of our intention in respect of them.

Personal data will therefore cover basic details such as name, address, telephone number, email address and date of birth.

CWH’s registration as a data controller

CWH is a ‘data controller’ under the Act. CWH holds information for the reasons given to the Information Commissioner and may use the information for any of those reasons.

Our contact details are:

Head of Governance

CityWest Homes Ltd

21 Grosvenor Place

London

SW1X 7EA

email: governance@cwh.org.uk

CWH has notified the Information Commissioner’s Office (ICO) that we will process personal data to enable us to provide our services to our customers, to maintain our own accounts and records and to support and manage our staff.

The ICO describes the processing in a register which is available to the public for inspection at http://www.ico.org.uk/. CWH’s entry on this register can be viewed here.

Our pledge

CWH's commitment will be to ensure that the data is:

  • processed lawfully, fairly and in a transparent manner;
  • collected for a specific and legitimate purpose - iIt will not be used for anything other than this stated purpose;
  • relevant and limited to whatever the requirements are for which they are processed
  • accurate, and where necessary, kept up to date. Any identified inaccuracies will be amended or removed without undue delay;
  • stored for as long as required, as specified on our data/document retention policy;
  • secured with appropriate solutions, which protect the data against unauthorised or unlawful processing and against accidental loss, destruction or damage.

CWH will ensure that it meets the conditions necessary for processing personal data lawfully and will ensure this is adequately recorded. There are a number of ways that processing can be lawful.  Consent is one method, but it is important to know that consent is not always required and CWH can lawfully process personal data as long as a condition is met.  You can find out more about the conditions on the ICO website.

As a wholly owned subsidiary of WCC, we have a duty of care to our residents. This includes ensuring that we are delivering the services which meet both individual and community needs. In order to monitor our performance, we may ask questions that include information which the law defines as sensitive.

When seeking sensitive personal data, for example, ethnic origin or disability, we will always try to explain why we want the information and how we intend to use it. In some instances, we will need sensitive information to give you the right service, for instance where you require special help due to a disability.

Why CityWest Homes collects personal data

We collect personal data in the administration of the Landlord’s responsibilities and the delivery of services managed by CityWest Homes, e.g. for the following purposes;

  • To legally identify customers and for contact purposes, including informing, consulting and gaining feedback about our services;
  • To ensure we are not discriminating against anyone because of their age, gender, disability or ethnic origin;
  • So that we provide services that meet our customer’s needs;
  • For audit and monitoring purposes; to improve our standards of customer service;
  • Where WCC requires us to collect information for service performance reporting purposes (although these reports are anonymised).

How we collect your information

In order to deliver our services, as well as pursue other lawful/legitimate interests on behalf of our residents and service users, we collect information about individuals in a number of ways, for example, by letter, email, face-to-face, telephone, online forms, social media and through referrals made by third parties, and other key stakeholders acting jointly or on behalf of CWH or WCC.

Processing information fairly and lawfully

CWH processes information only where:

  1. a) the law allows us to; or
  2. b) you have given your consent; or
  3. c) we have received a court order

CWH will process (that means collect, store and use) the information you provide in a manner that is compatible with Data Protection legislation. We will endeavour to keep your information accurate and up to date and not keep it for longer than is necessary. In some instances the law sets the length of time information has to be kept, but in most cases CWH will use its discretion to ensure that we do not keep records outside of our normal business requirements - i.e. providing a service to you.

Our aim is not to be intrusive, and we won't ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to make sure it can't be seen, accessed or disclosed to anyone who shouldn't see it.

We are keen to ensure that we are providing our customers with services that they need. To support this legitimate interest, you may receive occasional e-mail or SMS messages from CWH on matters that we consider may be of interest to you.

Our Privacy Policy sets out our commitment to you when you access our services via the Internet.

Data sharing

CWH will sometimes need to share information with other organisations such as WCC, our partners, third party contractors, government bodies, the police, health and social care organisations, housing associations, and landlords.

We will only share information where it is appropriate and legal to do so. We may also share information, for example, if there is a risk of serious harm or threat to life, for the prevention and detection of fraud or crime, or if we are required to do so by any court or law.  Where this is necessary, we are required to comply with all aspects of Data Protection legislation.

For example, we may pass your personal data onto the people who provide services for us, such as a repairs contractor. These providers are obliged to keep your details securely, and use them only to fulfil your request.

We will not use your information for third party marketing purposes.

If you would like to know more or have any concerns about how your information is being processed please contact the Head of Governance at governance@cwh.org.uk.

Retaining information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We may also anonymise some personal data you provide to us to ensure that you cannot be identified, and use this data to allow CWH to effectively target and plan the provision of services.

Marketing

CWH will only contact individuals who are customers of CWH’s products and/or services, or who have otherwise provided their active consent (which may be withdrawn at any time).

Your rights to access your personal information

Under the Act you have the right to ask to see the information what CWH holds about you and why. You have the right to request a copy of the information that we hold about you.

You also have additional rights that refer to how we hold and use your information. Consequently, under certain circumstances, by law you have the right to:

  • withdraw consent and the right to object and restrict further processing of your data; however, where legally enforceable this may affect service delivery to you;
  • request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it;
  • request your data to be rectified if it is inaccurate or incomplete;
  • have your data transferred or copied should you move to another authority;
  • not be subject to automated decision-making including profiling.

If you want to see the information we hold about you then you must ask for the information in writing and give your full name and address. You should send your request to:

Governance Team

CityWest Homes Ltd

21 Grosvenor Place

London

SW1X 7EA

email: governance@cwh.org.uk

Where it is appropriate for CWH to respond directly to requests for access to personal data, we aim to comply as quickly as possible. We will ensure that we deal with requests within 20 working days of receipt, unless there is a reason for delay that is justifiable under the Act.

Changes in your personal circumstances

You must notify us immediately if there are any changes in your circumstances and personal details so we can maintain an accurate and up to date record of your information.

Contacting CWH – call recordings

There are various ways in which CWH may be contacted: by letter, face to face, email, telephone, online forms, voicemail, social media. In all cases we are committed to protecting the personal data you provide. When contacting us by phone, in line with our policy, calls to Customer Services may be recorded. The recording is needed to quality manage the performance of our customer service advisers, to ensure the quality of service information provided, and to measure and improve the quality of the customer experience. Recordings are retained for a specified timeframe and then deleted in line with our policies.

Personal information collected via online forms

Our policy is to respect and protect the privacy of anyone who visits our website. Where we ask you for personal information via an online form, this information will only be used for the purpose indicated and will be held in a secure manner. It will not be used for any other purpose without your permission and will not be kept for longer than necessary. If you are concerned about providing your personal information online please contact us and we will arrange alternative means for you to provide this information.

Website privacy policy

Use of IP addresses and cookies

Cookies enhance your experience using our website. 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 more efficiently, as well as to provide information to the owners of the site.

We use cookies to audit the use of our website and help us to customise the website for your visit. We do not store or transmit any personally identifiable data on these cookies. You can change your cookie setting at any time in the security settings in the browser you use to access the internet. Please note however, that rejecting all cookies may impact your enjoyment or use of this website.

We collect IP addresses only for the purposes of system administration and to audit the use of our site. We do not link IP addresses to anything personally identifiable, which means that while your user session will be logged you will remain anonymous to us.

Links to other websites

CWH is not responsible for the content or reliability of linked websites. Linking should not be taken as an endorsement of any kind. We cannot guarantee that links will work all of the time and we have no control over the availability of the linked pages.

Complaints about how we process your personal information

You have a right to complain to us if you think we have not complied with our obligations for handling your personal information. In the first instance, an individual should contact CWH. Complaints should be addressed to:

Head of Governance

CityWest Homes Ltd

21 Grosvenor Place

London

SW1X 7EA

email: governance@cwh.org.uk

If you are not satisfied with our response you have a right to complain to ICO. You can report a concern by visiting the ICO website.

Changes to our Fair Processing Notice

As we create new services, this may generate a need to amend this Notice. Any changes with regard to how CWH processes your personal data will be posted on this page.

Last updated:  24th May 2018