Sage Housing – Privacy Notice
The privacy of your information is important to us at Sage Housing Ltd (“Sage”) and we are committed to handling your information securely, respectfully and in line with data protection laws. Our privacy notice tells you what to expect when Sage processes your personal information (‘personal data’) which we collect when you become one of our customers or each time you contact us.
‘Personal data’ is any information which relates to an individual who can be identified from that information. ‘Processing' includes the collection, recording, storage, use, disclosure or destruction of personal data. We are a “data controller”. A data controller determines the purposes and means of processing personal data.
Who we are and our contact details
We are Sage Housing of 4th Floor, Manning House, 22 Carlisle Place, London, SW1P 1JA You can find out more about us at http://www.sagehousing.co.uk.
For further information, please contact our Data Protection Officer by emailing email@example.com.
The information we collect
We will make every effort only to collect the personal information we need from and about you. The type of information we collect will vary depending on the service we offer to you.
The information will be collected directly from you, but we may also obtain information from another person or organisation if you have given permission for them to share it with us. This could include a local authority, your previous landlord, your doctor or other health professional. In addition, we may also obtain your information from available public sources.
Types of information we collect
Personal data such as your name, address, date of birth, email address, phone number, gender, marital status, disability, race, religion, employment status, National Insurance Number and next of kin details for you and your family. We also hold data about your credit risk, rent account, rent payments, benefit status, bank account details, credit reports and contact with us about rent arrears and agreements you have made to repay arrears.
Special category personal data. This is sensitive personal information, for example, your racial, or ethnic origin, religious beliefs, other beliefs, sexual orientation, health information, political opinions and so on. Sage would only collect your sensitive personal information where there is a clear need for us to do so, such as to assess what services are relevant to you or to offer appropriate support to you. Before collecting any sensitive personal information about you we will always try to make it clear to you what information we are collecting and the reason for collecting it, and explain your choices in respect of providing this information. If you have any questions please ask us.
Criminal offence data. This is data relates to criminal convictions and offences or related security measures. Sage collects this data to ensure appropriate services can be provided. Before collecting any criminal offence data about you we will always try to make it clear to you what information we are collecting and the reason for collecting it. If you have any questions please ask us.
Why do we process your data?
Under data protection legislation we can only use your data for certain reasons and where we have a legal basis to do so. The bases on which we typically process your data are:
In most cases we have a legal basis for processing the data because you have a tenancy agreement or lease with us (or are applying for one).
We may need to process your data in order to assess your suitability for a home or provide you with services you need such as repairs and maintenance, tenancy advice, mutual exchanges, allocation of homes, complaints etc.
We may also be required to process your data in order to comply with a legal obligation under UK or EU law such as checking your right to rent a home in the UK.
We collect data from applicants in order to be able to assess their suitability for a home. If you are unsuccessful in your application we won’t use your data for any other purpose.
What sorts of personal information do we hold?
We use the information we collect from or about you (as applicable) in various areas of work, including:
Assessing and processing housing applications, sales of shared ownership properties, service eligibility and complete tenancy sign-ups
This information is required as we will be unable to accept an application for services without it. Information on household members is required as it is also in our legitimate interests to know who will be living in our premises and to ensure the property offered is adequate for the needs of the household. We assume any information you provide about household members is provided with their full knowledge and you should direct your household members to this policy.
Managing your tenancy or lease
The provision of this information is a ‘contractual requirement’. Without this information, we may be unable to manage or provide your services. For example, we would not be able to discuss changes to your service if we do not hold you contact details. Please speak to us if you have any concerns.
Confirming your eligibility for housing and prevent fraud and illegal sub-letting
We need to be able to verify your identity to provide services to you. Processing for the purpose of fraud prevention is required in order to meet our legal obligations.
Meeting your needs in our service delivery
Where processing information about you or your household members, we may have a legal or contractual obligation to process this information for example to provide inclusive services.
It is also in our legitimate interests to ensure that service delivery meets the needs of our service user and their household.
Managing the legal process if you apply to buy your home or want to access another home ownership route
This information is required to manage the legal process needed in preparation for entering into contractual relations.
Assisting with personal security and prevention and detection of crime
This information may be required to meet legal obligations and our legitimate business interests around health and safety and crime prevention.
Understanding how we’re performing
It is in our legitimate interests to understand how we are performing so we can meet our objectives.
Keeping in touch with you
We may wish to communicate with you and keep you up to date with events and news about the organisation which we think will be of interest or use to you.
Prevention and detection of crime, and regulatory purposes
We do this to meet our legal obligations and to further our legitimate interests.
How do we collect data about you?
The information we hold about you comes from you or your household members, for example when you filled in your original application and signed up to your tenancy. We will also have any letters or emails you have sent to us, records of calls to the office and any feedback or permission forms you have completed.
Who might we share your information with and why?
Sage operates through contracting with managing agents that are responsible for managing relationships with tenants on a day-to-day basis. This means that we will share information with the particular agent that is responsible for managing the home in which a tenant lives.
We will not disclose personal information about you to other parties except where we have a legitimate interest or other legal basis for doing so or where you have given us your consent to disclose (if required).
Your data may be shared within Sage where it is necessary for staff to carry out their duties or to provide services to you. We may share your data with our contractors and suppliers so that we can carry out repairs and maintenance to your home or provide other services.
There may be situations in which we have or choose to share some of your information with other third parties including (but not limited to):
Where we share data with a third party organisation or statutory agency we will ensure that the organisation or agency understands how the data is to be used, what information is to be shared and when it will be destroyed. We may provide more detailed information to you about any data sharing that takes place, or you can ask us for more information about it.
In some cases we may be legally required to provide information to one of these other organisations – for instance, in certain circumstances we may be required to provide information about housing benefits to a local authority or central government department.
Our staff are trained in data protection and know the importance of keeping your data safe and secure.
We don’t normally send data overseas
Our business is based solely in the United Kingdom, and so we do not ordinarily send data overseas. We may sometimes make use of cloud-based systems located outside of the EU to support the management of our business. Where this happens, we will ensure that there are appropriate safeguards in place to protect your data.
Sage is required by law to comply with UK Anti Money Laundering Regulations (AML Regulations).
Whether you are a new or existing customer, we may therefore need to verify your identify and your source of funds.
We may do this by:
We use TransUnion credit reference agency to undertake identity checks. You can find out how TransUnion uses and shares personal information, the type of information they hold, where it comes from and the legalities of how it is handled by using the following link:
With your consent (or because you have used or been interested in similar services from us previously), we may use your personal data in order to send you information about our services, promotions and events that we believe may interest you. We don’t buy in lists of customers or contacts where information is about an individual.
If you are or represent a business, you may also receive an email from Sage because we obtained your contact information from a reputable third party agency.
We collect your basic identification and contact details. This may include for example your name, company, telephone number, and email address.
If you decide to opt-out of our marketing, we will no longer use your personal data for this purpose. You may opt out (or opt back in) at a later date. You have a right at any time to stop us from contacting you for marketing purposes.
You can easily change or withdraw consent our marketing messages by clicking the 'unsubscribe' link at the bottom of each marketing email.
You may also choose to stop receiving direct marketing communications from Sage at any time by sending notice of your decision to Sage using the following contact details firstname.lastname@example.org.
How long we keep your data for
We only keep your data for as long as we need it for the purposes we collected it for. For tenants and leaseholders this is up to 6 years after the end of your tenancy or lease, in case of any contractual claims or references.
For unsuccessful applicants we keep your data no longer than 6 months after a decision has been made on your application in case there are any questions or complaints that arise from our decision.
Please contact us if you would like any more information.
Protecting your data
We take the protection of your data very seriously. We have procedures in place to protect your data from loss, misuse, disclosure, abuse or destruction.
Where we share your data with third parties, such as contractors, we provide written instructions to them to ensure that your data is held securely and in line with data protection legislation. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not normally undertake “automated decision making”
We do not normally undertake ‘automated decision making’ – that is decisions made about individuals without any human involvement.
The law on data protection gives you certain rights in relation to the personal data we hold about you. These are:
SARs need to be made in writing and we ask that your written request be accompanied by proof of your address and identity. If you require specific information, it is helpful if this is clear in your request, for example, information from a particular time period or about a specific correspondence. If someone is requesting information on your behalf, they will need written confirmation from you to show you consent for us to release this and proof of ID (both yours and theirs).
We will provide a copy of the information requested free of charge. However, we can charge a ‘reasonable fee’ when a request is manifestly unfounded or excessive, particularly if it is repetitive. We may also charge a reasonable fee to comply with requests for further copies of the same information.
We will seek to provide you with the information you have asked for within one month to provide you with the information requested, although in certain circumstances it may take longer to provide you with some or all of the information you have asked for and we will try to keep you updated about this as promptly as we can.
Making a complaint
If you are concerned about the data we hold, how we are processing it or if you would like to see the data we hold about you please contact us at email@example.com.
If you remain dissatisfied, you have the right to refer the matter to the Information Commissioner. The Information Commissioner can be contacted at:
Helpline: 0303 123 1113