Karbon Privacy Statement

This information includes your: 

• name (including any previous names) 
• date of birth; 
• gender; 
• nationality; 
• residential status; and 
• national insurance number. 

This type of information may have been collected when you were accessing a service or applying for/entering into a contract with Karbon. 

In order to access or influence some Karbon services, enter or be in a contract with us, and for legislative requirements, it may be necessary to collect your special category information. 

This type of information includes, for example, details on your: 

• marital status; 
• race; 
• ethnicity; and 
• physical or mental health medical needs. 

In order to be offered a contract of employment or tenancy; for a legislative requirement; or to manage anti-social behaviour cases, it may be necessary for you to declare any spent and/or unspent criminal convictions, offences or behaviours and in some instances agree to have a DBS (Disclosure and Barring Service) check. If we ask you for this information, we will always let you know at the time why it is necessary.

This is the information that you have given us so that we can contact you and includes: 

• telephone numbers; 
• email addresses; 
• alternate postal addresses; and 
• Next of kin details. 

If you set up an online account with Karbon this would refer to the username, password and answers to the security questions you would have used in order to manage your online account. 

This is information about the device you have used to access a website, platform, wifi service or portal. This information is usually collected through cookies and can include the IP address, MAC address, source and destination traffic information, operating system and browser; if accessing through a smartphone this can also include the phones unique ID. 

This is information you voluntarily share with us about your experiences with Karbon, and includes unsolicited comments, suggestions and feedback which is typically collected in surveys, user groups, contact forms, website or social media comments and emails. 

The information is used to improve services; know more about our tenants/communities or establish if there are any gaps in what we are doing. Individuals can provide feedback voluntarily at their discretion. 

This refers to any information that is part of your profile on a third-party platform such as Facebook or Twitter, that you allow to be shared with us, this is usually your name and profile picture but may also include your date of birth and email address

There are occasions where we obtain information from other sources about you, depending on the purpose this will include personal information, special category information and contact information and this information may be used for the purposes set out above. These sources might include local authorities and health services; the Police and Courts; out of hours providers and contractors; previous employers or fellow tenants or residents, for example. 

At our premises 

At our offices and some of the premises that we manage, we operate surveillance camera systems including door entry systems, this is done in order: 

• to help deter and/or detect crime, anti-social behaviour or breaches of contract; 
• to provide evidential material for court or alleged misconduct and/or holding disciplinary hearings; 
• to help reduce the fear of crime; 
• to provide assistance in the overall management of public safety;  
• for staff monitoring and safety; and 
• to enhance community safety. 

The locations where there are surveillance camera systems will be clearly marked by appropriate signage at entranceways and near the camera locations. These systems will record images and/or sounds, which will always be indicated on respective signage. 

In our vehicles 

Our vehicles are equipped with forward-facing ‘Dash Cams’ operation of these camera systems is done: 

• for the protection and safety of our staff and the wider community; and 
• to provide evidence for road traffic incidents and disciplinary actions. 

Of your home 

If you contact us to discuss an issue you are having or request a repair to your home, our customer relationship team may ask you to show us the relevant part of your home on a video call or send us pictures.  Our customer relationship team may then take a screenshot of the video call or save the pictures you send to your file.   

We will always make you aware during the video call if we take a screenshot or when making the request for pictures that the images will be stored on our systems.  We will not keep the images for longer than necessary and in any event in line with our retention policy. 

Promotional recording of images and sounds 

There may be occasions where your image or voice is captured for the purposes of promotional materials.  

Consent for this will be obtained at the point of capture and you are able at any time to ask us to stop using your images or sounds in promotional materials whilst being aware that we may be unable to remove them from already published materials or videos, at no time does this diminish your data protection rights.

There may be occasion when sound monitoring or video recording systems will be used covertly and signage will not be present as: 

• telling someone that we are making the recording would seriously prejudice the reason for making the recording; or 
• there is good cause to suspect that an illegal or unauthorised action(s) or breach of contract, anti-social behaviour or crime and disorder is/are taking place or about to take place. 

We will comply with the requirements of the Regulation of Investigatory Powers Act 2000 (RIPA) when operating covert surveillance camera systems.  
 
We will only carry out such recording for a limited and reasonable amount of time consistent with the objectives of the monitoring and only to detect a specific activity.  
 
We will fully document all covert recordings showing who made the decision to use covert monitoring and why. 

Calls received by or made to Karbon may be recorded, this is done to provide an exact record of a telephone conversation in order to: 

• Help identify colleague training needs, improve performance and the customer experience; 
• Help protect colleagues from abusive or nuisance calls; 
• Provide assurance of Karbon’s quality standards and policy adherence; 
• Support call levelling sessions and individual feedback; 
• Ensure Karbon complies with regulatory procedures and to provide evidence in the event of a dispute or complaint; 
• Ascertain and demonstrate that calls are accurately transcribed onto the case management system; 
• Be used as evidence in the event that a colleague’s conduct is deemed unacceptable; 
• Demonstrate transparency; and 
• Prevent or detect crime or safeguarding requirements. 

Our employees are provided with identification cards that allow them access to our offices. Visitors to our offices are also provided with cards that allow them access on a temporary basis. These cards track the location of the card user by recording the buildings and areas they access and at what time. 

For safety and staff training purposes as well as resource management, our work vans have tracking devices installed that record location information as well as dashcams that show locations visited. Our business mobile phones and IT equipment are set up with location settings enabled, which mean they track their users’ location data. 

You may find that environmental or appliance monitoring equipment is present in your property. This equipment is used by Karbon to monitor the performance and status of the appliance within your property and does not monitor you.   

For instance, monitoring equipment on a boiler will be able to provide us with information such as the boiler’s location (address), the temperature it is set at, the humidity and temperature of the room the boiler is in and if there is an error code being displayed by the boiler. This will allow us to provide you with a faster response to any problems you might have with your boiler or other appliances and aims only to provide you with a better standard of service. 

Calls/meetings held via Microsoft Teams may include external parties as well as staff, these calls/meetings may be recorded for staff training, customer service and/or record-keeping purposes.   

Participants are made aware of the recording and the recording will not be kept for longer than necessary and in line with our retention policy.

Calls/meetings for recruitment purposes held via Microsoft Teams may include external parties as well as staff. These calls/meetings may be recorded for staff training and/or record-keeping purposes. Participants are made aware of the recording and the recording will not be kept for longer than necessary and in line with our retention policy. 

Calls/meetings held via Microsoft Teams for the purposes of investigations, grievances, disciplinaries or People & OD purposes may include external parties as well as staff.  

These calls/meetings may be recorded under the legitimate interest lawful basis for record-keeping purposes in our investigations/grievance/disciplinary, People & OD processes with further freely given explicit consent given by all parties both before the recording and at the start of the recording.  

Whilst using the systems provided by Karbon, individuals may directly or indirectly share information about themselves, friends, family members, associates or third parties on systems that are managed by Karbon.  

In order to apply for, enter into or allow us to manage a contract you have with Karbon it will be necessary to use the information you gave to us in an application form, or CV. 

This may include special category information as well as your contact information and information on your unspent criminal convictions and offences. 

In order to maintain your account with us, we may use the information that was given to us when the account was initially set up - which could be from your application form, and it would include your personal information and contact information. 

There are some services provided by Karbon that as well as requiring the use of your personal and contact information also require the use of your special category information or information about your unspent criminal convictions, offences or behaviours, or information about your property. 

For instance, in order for us to provide you with services to assist you in the sustainability of your tenancy, it may be necessary for our welfare rights team to process your special category information to establish your benefit entitlements. 

Customer services can be provided through different means e.g. in person, by email, through Teams, by Social Media or over the phone. During these interactions we may collect and use your personal, special category and Karbon account information to validate your identity, we will also use your contact information to respond to your enquiries and analyse response to look for trends.  

Queries and complaints will be recorded by our staff in order to resolve or answer them.  If you wish to make a complaint, you will be guided through our complaints process by a staff member.  Karbon may use some of your location data and personal information that relates to your opinion of the services we have provided to you in considering your complaint.  We will record your customer satisfaction data and combine this information with that of other Karbon customers to give us a better picture of the services we are providing and allow us to deliver better services to our customers. 

If you make a complaint or query via a Councillor or Member of Parliament and ask them to get in touch with us on your behalf, it will be expected that you have already given your consent to them for them to do this.  

In order to encourage and obtain customer/visitor engagement and feedback we may get in touch with you using your contact information to collect your opinions about the services we offer or have provided to you. 

Karbon undertakes some customer segmentation processing activities by dividing our customer base into groups based on common characteristics. These activities are led by Karbon’s aim to improve our customer service performance and to provide our customers with effective and appropriate services. 

These processing activities allow us to deliver a better service to you by understanding your preferences better or by providing you with certain services based on your personal information characteristics (including your special category personal data such as your age, health or vulnerability data). 

Karbon may also place tags or notes on your records in our databases that reflect your preferences or help us to better understand your needs as our customer.  We may then analyse your characteristics to make decisions about you in a process known as profiling. 

These activities will never be undertaken on your personal information alone and will never be used to diminish the services provided to you. 

Our customers are able to report their need for a repair at their property by filling in a form on our MyKarbon customer portal. This is an automated process that allows you to self-diagnose the problem(s) you are encountering and request our help.

Depending on your MyKarbon profile, some options may be unavailable to you. For example, some of our customers are responsible for paying for repairs under their tenancy agreements so may not be able to access the same booking system as those whose repairs are undertaken by Karbon at no extra cost. None of the automated processes undertaken by the MyKarbon repairs reporting system prevents any of our customers from arranging repairs but will redirect you to the right resource for your circumstances to ensure you receive the best service we can provide. 

We may also cross-reference the information that you have given us in our various methods of customer engagement (customer portals, mobile device applications, social media chat, messaging services or telephone services) to enable better automated decisions. 

We occasionally run competitions through our websites or third-party platforms such as Facebook or Twitter.

Entry to these requires the use of your personal and contact information, which you provide on the lawful basis of your consent to be entered into the competition. If you win a competition, you will be contacted for your consent before we post your details on our websites or social media platforms.

We may process your information and send you communications to fulfil our contractual or legal obligations as a social housing provider, this could include messaging on route for an appointment.

We will usually ask you to confirm a primary contact for when we want to get in touch with you and will try to follow your preference unless there are extenuating circumstances that prevent us from doing so. You can confirm this primary contact preference using the MyKarbon customer portal or by letting one of our customer service team know, who can update your preferences for you. 

These communications may include some of the following: 

• Rent reviews; 
• Service changes; 
• Repairs appointments; 
• Annual reports; and 
• Building information. 

We may also process your personal information for carefully considered and specific purposes if we have a genuine and legitimate reason to do so and we are not harming your rights and interests. 

This may include some of the following: 

• Postal communications which we think will be of interest to you; 
• Messaging to confirm/remind customers of requests/appointments; and 
• Email newsletters about our activities, performance, and support services 

These communications are designed to: 

• Demonstrate how we are supporting the communities we serve; 
• Raise awareness of the support services we provide; 
• Allow us to enhance the services we provide to our customers and stakeholders; and 
• Keep our customers and stakeholders informed with our activities to ensure a better experience and relationship. 

You can ask not to receive some communications, but there are some items that we are legally obliged to send you irrespective of whether or not you want us to. 

In order for us to send you direct marketing materials, you have to have given us consent as it requires the use of your personal and contact information. As with all forms of consent it can be withdrawn or amended at any time. 

Please note that if you have participated in a competition or promotion that involved a third party and you agreed to receive marketing information from them, you will need to contact them directly to withdraw consent from receiving further direct marketing materials from them.

In order to improve, tailor and personalise your experience on our websites, platforms and portals, we may collect and use your technical computer and account login information. 

If you do not want Karbon to do this you will need to change your preferences in your browser settings, please be aware that you will have to change this preference on each device that you use and it will mean that you have to complete login information on every visit. 

This information is used for website and service improvement, and although your device may be identified from this data, we use it in the format of anonymous analytics. 

For legal compliance and monitoring purposes we may use your personal and special category information. 

An example of this is for equality and monitoring purposes where we would collect information on your gender, ethnicity and race. We ask for this information on the basis of your consent. You are not obliged to give us equality and diversity information. 

In order to keep our office buildings safe and secure, we limit access to the buildings by implementing an identification card access system.  The identification cards record location information to allow us to maintain an awareness of who accessed which of our office buildings and when. 

For safety and staff training purposes, our work vans have tracking devices installed that record location information.  Our business mobile phones and IT equipment are set up with location settings enabled, which means they track their users’ location data. 

In order to maintain the day-to-day operation and security of our website/platforms/portals and conduct demographic studies, we may process your technical computer information, such as your IP address and location data, and consumer feedback. 

In order to provide a service to you, it may be necessary for Karbon to appoint a contractor, an example of this would be carrying out your annual gas service when the contractor would need to know your name and address as well as your contact information in order to organize and carry out an appointment as well as correctly completing the Gas Safety Certificate. 

Where there is a statutory obligation or legal requirement to do so, Karbon may share your personal information with utilities companies, we also have the legitimate interest in advising a utility provider of a change in tenancy. 

In order to deliver services to you under a contract Karbon has with another third-party housing association, we may need to use the information you gave to us in an application form or contact form, through our MyKarbon customer portal, in tenancy/leaseholder agreements or through our customer call centres, emails, correspondence or telephone conversations between you and our staff members. 

We may appoint a research company to carry out research on our tenants or communities in order to improve a Karbon service; know more about our tenants/communities or establish if there are any gaps in what we are doing, on these occasions if contacted individuals can refuse to participate in the research. 

In order to act on your behalf and organise services it may be necessary to share your information with Local Authorities, examples of this include the ordering of bins, benefit entitlement queries and accessing support services and occupational health. 

The information that would be shared on these occasions is dependent upon the local authority service that is being accessed but will include your personal and contact information. 

If we are contacted by a Councillor or Member of Parliament who is acting on your behalf, we will need to share your information with them in order to answer the complaint or query you have raised with them, on most occasions it will be assumed that you have already given the required consent to do this however if deemed necessary, we will contact you for consent. 

There may be occasions where we need to share your personal, special category and contact information with the Emergency Services. 

This will need to happen if you are involved in an incident where Emergency Services are involved or if it is required in case of an emergency situation i.e. the emergency information box in sheltered courts. 

In order to ensure that you are able to apply and access the support, services, contract and accommodation that you are entitled to, it may be necessary to share your personal and special category information with Doctors and other medical professionals.

We will need to share your information with solicitors, loss adjusters, insurance providers/brokers/consultants, claims inspectors or valuers in order to progress an insurance/disrepair claim, property/land purchase or complaint with Karbon. 

We will need to share your information with solicitors or data protection practitioners in order to obtain advice or have them act on our behalf for items relating to data protection including Subject Access Requests (Right of Access), Erasure Requests (Right to be Forgotten) and Amendment Requests (Right to Rectification). 

We will need to share your information with solicitors in order for us to obtain advice or have them act on our behalf for issues relating to disciplinary or employment matters involving former, prospective or current colleagues or for housing related matters such as possession proceedings, anti-social behaviour, boundary issues or ombudsmen complaints. 

Your information will be shared with our 'out of hours' support teams to ensure that if you do need to contact us outside of our business hours we are able to manage your query efficiently. 

If you are involved in any form of court action, Karbon will share your information with the court involved. 

There are occasions where it may be necessary for Karbon to share your information with its regulatory authorities, when this does occur the minimum of information required to carry out the requirement is shared. 

When you obtain a social housing tenancy or purchase a social housing property from Karbon, the Ministry of Housing, Communities & Local Government requires Karbon to complete a Continuous Recording of Social Housing lettings and Sales (CORE) log. Further details on this process and what happens with your information can be found in their Privacy Notice. 

In order to assess our services, we regularly have audits carried out which to be managed correctly required us on occasion to share your personal information. 

By law there are occasions where we have to disclose your information, for instance, if it is necessary to comply with legal proceedings or in order to protect the safety or rights of Karbon, its customers or the public. 

In the event of a merger/acquisition of part or the whole of Karbon the partner/acquirer would have access to the information obtained by Karbon and this information could be transferred as part of a reorganisation or similar event if permitted by and carried out in accordance with applicable law.

You have the right to ask us not to process your information where we process it on the lawful basis of a legitimate interest, including for direct marketing purposes. We will ask you when we collect your personal information if we can use your information for such marketing purposes or if we can disclose your information to any third party for such purposes. You can opt-out of receiving such marketing at any time without prejudice. 

You have the right to access the information that we hold about you, to know what we hold, what format it is in and to have a copy of it if you wish. This is called a Subject Access Request. This is a more formal process than, for example, simply requesting a second copy of your rent statement. Our staff will explain when your enquiry falls under the Subject Access Request process. 

If the information we hold on you is incorrect you have the right to ask us to correct it without undue delay and free of charge. 

In order for us to correctly manage your request, you will be required to specify the information that is incorrect and what it should be replaced with. 

There may be occasions where we require additional information in order to process your request - such as a name change needing proof of the change of name. 

You can exercise this right at any time by contacting us at data.protection@karbonhomes.co.uk 

You have the right to request that all information held by Karbon which identifies you is deleted. 

There are occasions though where we may be compelled to maintain your information due to specific legislative or regulatory requirements, examples of this are the requirement to keep a copy of invoices in case of an HMRC investigation, or if you have held a contract with us we will retain that information. 

You can also make this request at any time by contacting us at data.protection@karbonhomes.co.uk 

You have the Right to Complain to our data protection supervisory authority which is the Information Commissioners Office (ICO), if you feel that we have not dealt with your request for information properly or you have a concern about the way in which we are handling your information. 

The first step before contacting the ICO would be to first contact us and allow us to help rectify your issues however if this fails or you remain dissatisfied the ICO can be contacted online at: https://ico.org.uk/make-a-complaint/your-personal-information-concerns/ on the phone by calling: 0303 123 1113 or you can write to them at: 

Information Commissioner's Office 

Wycliffe House 

Water Lane 

Wilmslow 

Cheshire 

SK9 5AF 

There are occasions when it will be necessary for Karbon to get your consent to process your information, when this does happen it will be clear for what purpose we are requesting the consent and you are able to amend or withdraw it at any time.