The Karbon Homes Group (‘Karbon’) (‘we’, ‘us’, ‘our’) respects an individual’s right to data privacy and data protection in line with the General Data Protection Regulation (GDPR).

This Privacy Statement (version 2.7) is to advise you of how Karbon will collect, store, use, share, protect, and otherwise process your personal data. If you have a tenancy or other written agreement with us it may contain further information about our processing of your information.

Personal data is information that identifies you, and includes which it called special category personal data, such as information about your health, or religious and political beliefs. For the purposes of this Privacy Statement, personal data and special category personal data is collectively known as ‘information’.

We reserve the right to make changes to this Privacy Statement at any time and we recommend that you regularly review this Privacy Statement to ensure that you are aware of any changes to how your information may be used. If you are a tenant or resident, you may also be separately notified of changes to how we process your information.

Karbon is the controller (meaning the company who is responsible for and controls the processing) of the information that you supply it with and on occasion this information may be shared with a third party who will act as a Data Processor to carry out a specified function on behalf of Karbon.

If you have any requests concerning your information or any queries with regard to this Privacy Statement please contact us.

The Data Protection Business Partner for Karbon is Jill Johnson.

 

What does this Privacy Statement apply to?

This Privacy Statement applies to personal/ special category information (collectively known as ‘information’) that we collect from or about our staff, customers or visitors to our premises, websites, wireless networks, platforms or portals.

The methods in which we collect this information are:

  • The Karbon Homes website and mobile site
  • The York Housing Association website and mobile site
  • Third party social platforms such as Facebook and Twitter
  • Karbon portals
  • Our wireless networks
  • Customer call centres
  • Application forms
  • Employment Contracts
  • Tenancy / Leaseholder Agreements
  • Personal interviews
  • Surveys
  • User groups
  • Contact forms
  • Telephone conversations
  • Emails
  • Surveillance Camera Systems

We also process some information using third party social platforms such as Facebook and Twitter.

We also collect information from other sources. For instance, we may hire a third party organisation to collect information on our behalf to conduct tenancy surveys, and this would be done in order to provide us with additional information on our tenants in order to shape service delivery. We may also get information about you from third party referrals.

What information is being collected?

Your relationship with us determines what information we collect from you.

We aim to limit the amount of information we process to that which is reasonably necessary to provide you with our services.

We will not combine information given for one purpose with other non-compatible purposes.

The types of information that we collect from you can be categorised as:

Personal Information

This is information includes your:

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

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

Special Category Information

In order to access some Karbon services 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.

Criminal convictions, offences and behaviours

In order to be offered a tenancy; and to manage anti-social behaviour cases, it may be necessary for you to declare any 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.

Personal Contact Information

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

Account Login Information

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.

Technical Computer Information

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.

Customer / Visitor Feedback

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.

Social Network Information

This refers to any information that is part of your profile on a third party platform such as Facebook and 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. Information on social media will not be used by Karbon outside of the social media platform you contact us via, unless you request us to contact you otherwise.

Third Party Information

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; previous employers or fellow tenants or residents, for example.

Images and Sounds

At our offices and some of the premises that we manage, we operate surveillance camera 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 entrance ways and near the camera locations. These systems will record images and / or sounds, which will always be indicated on respective signage.

Covert Recordings

There may be occasion when surveillance camera 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.

Call Recordings

Calls received by or made to the Group may be recorded, this is done to provide an exact record of a telephone conversations 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 the Groups quality standards and policy adherence;
    • Support call levelling sessions and individual feedback;
    • Ensure the Group 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 colleagues conduct is deemed unacceptable;
    • Demonstrate transparency; and
    • Prevent or detect crime or safeguarding requirements.
Use of your information

The purpose for which you are interacting with us establishes the lawful basis that we will use to process your information under data protection legislation.

At a minimum the information will be needed for at least one lawful basis and may need to be shared with third parties to fulfil the purpose for which we are processing it.

The lawful basis are:

  • The information is processed in order to perform a contract that we have or have had with you or a contract that you are wanting to enter into with us. This includes: verifying your identification and Right to Rent; administrating the agreement between us (including the application process, breach management and tracing your whereabouts to contact you or recover debt); and providing you with services under the contract (e.g. managing your account, communicating with you, providing you with updates, dealing with complaints, notifying you of any changes and managing our repairs and maintenance service).
  • The processing of the information is necessary for our legitimate interests or that of a third party. This would include: updating you on the activities of the Group; communicating with and understanding your needs and requirements – tailoring our services and products to suit; verifying your identity; preventing fraud and money laundering and for managing and auditing our business operations.
  • It may be that in order to comply with a legal obligation we may need to process your information. This will include when you want to exercise your Rights under Data Protection legislation as well as establishing and defending the Groups legal rights. It also applies to activities relating to the prevention, detection and investigation of a crime including the carrying out of fraud prevention checks and for our compliance with our legal and regulatory responsibilities
  • There are some occasions where we may need to rely on your consent to process your information. This may happen if you have opted in to one of our marketing mailing lists or if you have sent a CV in to the Group regarding employment opportunities. You control the consent that you give us and you can change or withdraw consent at any time.
  • On rare occasions, when a life is at risk, it may be necessary for the Group to share your information under the lawful basis of vital interests. An example of this is your child is at risk and we are contacted for your details we will share your information with appropriate third parties to speed up the situation and enable relevant permissions to be granted.

Additional lawful basis of processing will be in place when processing your special category information or information relating to criminal convictions and offences.

 

Information about other individuals

If you want to act on behalf of someone else we need to have the consent of that person to do this. To be able to act as an ‘Authorised Person’ for someone else you have to consent to us processing your information for this purpose. This consent by either party can be amended or withdrawn at any time.

In acting as an Authorised Person you confirm that you are acting on their behalf and have consent to discuss their information subject to any restrictions that they have imposed.

Monitoring

We may monitor and record communications with you (such as telephone conversations and emails) for the purposes of quality assurance, staff training, fraud prevention and dispute resolution.

What do we use your information for?

The following describes the various purposes for which Karbon might process your information and the different types of information that might be collected from you.

Please note that not all of the uses will be relevant to every individual.

Contracts

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.

Tenancy Management

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.

Service Provision

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.

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

Customer services can be provided through different means i.e. in person, by email 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.

Queries and complaints will be recorded by our customer service team in order to resolve or answer them.

Customer / Visitor Engagement

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.

Competitions and Promotions

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.

Communications

We may process your information and send you communications to fulfil our contractual or legal obligations as a social housing provider.

These communications may include some of the following:

  • Rent reviews
  • Service changes
  • Repairs appointments
  • Annual reports
  • 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
  • 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
  • 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.

Direct Marketing

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.

Website Improvement and Personalisation

In order to improve, tailor and personalise your experience on our websites and platforms 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.

Monitoring Requirements

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

An example of this is for equality & 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.

Other General Purposes 

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.

Protecting your personal information

We are committed to ensuring that your information is secure.

At all times Karbon takes both technical and organisational measures to protect the confidentiality, integrity and security of personal information, irrespective of the method of collection.

Refusing to give us personal information

There are occasions where you may not want to share with us your information or you may want to withdraw previously given consent to hold information. This is well within your Rights however it may impact upon the service we are able to provide you and we will have to record the refusal or withdrawal of consent.

Please note that there are some items of information that you cannot refuse or withdraw consent from if you wish to enter into or remain in a contract with Karbon, or we are processing your information to meet a legal obligation.

Disclosing your personal information

We will never share information with any third party that intends to use it for direct marketing unless specific consent has been given by you for this purpose.

Karbon may share information gathered by one part of the Group with another part of the Group which it has control through direct and indirect ownership (collectively known as Karbon) as defined in section 1159 of the UK Companies Act 2006.

There are occasions where we will need to share your information with selected third parties, on these occasions Karbon will have a Data Sharing Agreement in place which ensures that the third party keeps information private, secure and processed only in the way specified by Karbon.

Information will only be shared with the following types of third parties:

Contractors

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.

Research Companies

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.

Local Authority Departments

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.

Councillors / MPs

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 your query, when necessary consent will be obtained for this purpose.

Emergency Services

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.

Solicitors / Insurance Providers / Valuers

We will need to share your information with solicitors, insurance providers or valuers in order to progress an insurance claim, property purchase or complaint with Karbon.

Out of Hours 

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.

Court

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

Regulatory Authorities

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 the Group, the Ministry of Housing, Communities & Local Government requires the Group 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.

Auditors

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.

Legal and Business Transfers

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.

Internet Based Transfers

Given that the Internet is a global environment, using the internet to collect and process personal information necessarily involves the transmission of information on an international basis. We only use internet and data hosting providers outside of the EEA where there is an additional safeguard to ensure the security of information we process, as set out in chapter V of the GDPR.

Accessing and amending your personal information

You have rights under the GDPR regarding the information Karbon Homes processes about you. These rights include:

Right to Object

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.

Right of Access

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.

Right to Rectification

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 info@karbonhomes.co.uk

Right to Erasure / Right to be Forgotten

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 is 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 info@karbonhomes.co.uk

Right to Complain

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

Consent

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.

Tracking Technology

Cookies

We use cookies in order to gain an understanding of how you use our website and platforms. Cookies can contain your IP address, operating system and browser address.

By having cookies stored on your device it enables us to improve and personalise your experience, if you want to you can turn off cookies in your device’s browser, however, this may impact upon your experience and require you to log back into certain areas on each visit.

For further information on cookies, view our Cookie Notice.

Spamming

Spamming is where unsolicited e-mails are sent to you containing advertisements or marketing related materials without your consent.

Karbon will not send you spam emails and we will not share your email address with third parties for them to use in this way.

If for some reason you believe you have received spam e-mail from Karbon please contact us at info@karbonhomes.co.uk

Where we store your personal information

All information you provide to us is stored on our secure servers in the UK. Any payment transactions will be encrypted.

The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) by one of our suppliers. Such suppliers may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. Where this is the case, your data will be protected by an appropriate safeguard providing equivalent data protection measures to those in the UK. In most cases, this safeguard is the model data transfer clauses authorised by the European Commission.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

How long do we keep your personal information

We will only keep your information as long as is reasonably necessary and in line with our Document Retention and Disposal Schedule. This does mean that your information may be retained for a period of time after you have stopped using Karbon services or the website/platforms.

Children

In accordance with the GDPR, Karbon will take care of the personal data of children, and recognise children above the age of 13 are generally capable of exercising their own data protection rights.

Links to third party sites

On occasion our website/platforms may have links to third party sites. Visiting these sites is done at your own risk and we do not control or have any responsibility or liability for the content or practices of any third party site, application or feature.

Please check the relevant third party’s privacy policies before you submit any personal information to these websites.

Contacting us

Karbon Homes registered office is: Number 5, Gosforth Park Avenue, Newcastle upon Tyne, NE12 8EG.

Phone: 0808 164 0111

Email: info@karbonhomes.co.uk

Legal notice and version control

On occasion, Karbon will make amendments to this Privacy Statement. We recommend that you check this Privacy Statement regularly to see the changes and how they may affect you.

Changes to this Privacy Statement

On occasions we will make amendments to this Privacy Statement. We recommend that you check this Privacy Statement regularly to see the changes and how they may affect you.

Version Updated version effective from
1.0 28.04.2021
Contacting Us

Karbon Homes registered office is: Number 5, Gosforth Park Avenue, Newcastle upon Tyne, NE12 8EG.

Phone: 0808 164 0111

Email: info@karbonhomes.co.uk