Jigsaw Homes Group Limited recognises the importance of respecting your personal privacy and the need to have in place appropriate safeguards surrounding the processing of personal data. Carrying out our role as landlord, service provider and employer, requires us to collect, store and use personal data about a range of data subjects; including tenants, residents, employees, partners and other third parties.
As a company who has access to and controls your personal data (a ‘Data Controller’) we are required to provide you with certain information about how we collect, store, destroy and otherwise deal with (also known as ‘process’) your personal data. We have in place, and will continue to develop, measures that promote strong privacy and security of that personal data, so that:
- Your privacy rights are understood and upheld
- The risk of identity related crime is diminished
- The Group earns and retains a reputation for trustworthiness and transparency
- The requirements of data legislation on ‘data controllers’ are complied with.
In doing so, we have developed a range of internal policies and processes which ensure robust data protection arrangements are in place to protect your personal data. We also undertake regular monitoring and reporting, provide regular training to all our employees and are registered with the Information Commissioner’s Office (‘ICO’). In addition:
- We are committed to safeguarding the privacy of our website visitors. For more details on how we treat information that we gather about your activities on our websites please view our Web Privacy Policy here
- The Group uses closed circuit television (CCTV). For more details please view our CCTV Policy here
- We also collect data on behalf of CORE. For more details, please view their privacy notice here.
To download a copy of this Privacy Notice, please click here.
The Data Controller is the company that decides the purpose for and the way in which any personal data is processed, Jigsaw Homes Group Limited and certain of its subsidiaries are data controllers registered with the ICO and details of all of the subsidiaries are set out below.
Jigsaw Homes Group Limited
ICO registration number: Z832622X
Registered as a Community Benefit Society with FCA registration number: 29433R
Housing Regulator registration number: LH4345
Jigsaw Homes Midlands
ICO registration number: Z1599688
Registered as a Community Benefit Society with FCA. Registration number: 8378.
Housing Regulator registration number: L4532
Jigsaw Homes North
ICO registration number: Z1657414
Registered as a Community Benefit Society with FCA registration number: 16668R
Housing Regulator registration number: LH0131
Jigsaw Homes Tameside
ICO registration number: Z1599674
Company number 3807022
Charity Commission number 1146435
Housing Regulator registration number: LH4266
Jigsaw Support
ICO registration number: Z6749053
Registered as a Community Benefit Society with FCA registration number: 8241
The registered office address for the above companies is:
Cavendish 249
Cavendish Street
Ashton-under-Lyne
Lancashire
OL6 7AT
In most cases the Data Controller will be the landlord responsible for your personal data as a tenant or the company who you are in receipt of any other services from. If you are in any doubt as to who your Data Controller is please get in touch with our Data Protection Officer.
The Data Protection Officer for the Jigsaw Group is contactable via email on dpo@jigsawhomes.org.uk and in writing at:
Cavendish 249
Cavendish Street
Ashton-under-Lyne
Lancashire
OL6 7AT
We hold personal data such as your household’s names, dates of birth, contact details and records of any transactions such as payments or requests for information as well as sensitive personal data such as income information, gender, ethnicity, religion or other beliefs, sexual orientation and medical history.
We may collect information about you in a variety of ways including (and this list is not exhaustive):-
- we receive a nomination from a local authority or referring partner
- you complete various forms, and contracts (such as application forms, tenancy agreements, employment support programmes, etc.)
- you apply to become a customer; we obtain information to determine your housing needs and in order to help us assess your application we may take up references from other housing providers/private landlords, your mortgage lender (if you own/have owned your own home), the Police, the Probation Service, support workers, social workers, mental health workers and credit reference agencies
- you become a customer including when you select an offer of one of our properties; we will also need your bank details, benefit and council tax information
- you request any of our services
- you apply for one of our home ownership products
- you voluntarily complete our customer surveys
- you provide feedback or make a complaint
- you make an application and become a member of staff
- you make an application and become a Board member
- our officer/agents/contractors attend appointments with you
- you contact us or use our services and we note any action taken, for example logging repairs, so that we have a record of what happened
- we engage in other aspects of routine contact with you
- we work with support agencies and third parties which relates to you
- we have contact with people associated with you such as family, friends and neighbours
- you use of our websites, social media sites and self-service portal
- we take photographs, audio sounds, videos and comments at events organised and/or hosted by Jigsaw or one of the companies within the Jigsaw Homes Group. The photographs, audio sounds, videos and comments may be used by us in a variety of online/offline platforms and may be provided to the media for publication in local or national media outlets. Distribution of these materials may be geographically diverse to promote the products and services of Jigsaw Homes Group. The material may be edited to enable use in a variety of formats but this will not change the sentiment of the views expressed therein. If you do not wish your image/material to be used by us in this way, please make this known to a Jigsaw employee at the event you are attending or, if it is after you have attended the event, by emailing comms@jigsawhomes.org.uk.
- we record calls to and from our landlines in Connect (our contact centres). All telephone calls made to our Contact Centre are recorded and are used to train and coach staff and improve the services that we provide to you
- we may collect data about your energy usage via 3G apps in the equipment we install in your home
- where we have CCTV cameras to record events in public areas and we monitor and collect visual images and audio for:-
- security reasons
- prevention and detection of crime; and
- staff safety and monitoring purposes.
If you provide us with personal information relating to members of your family or your associates, we will assume that you do so with their knowledge and consent. The Group may use mobile phone footage, still photographs or audio recordings supplied by residents to assist it in taking action against alleged perpetrators of anti-social or criminal behaviour.
It is important that you notify us of any changes to your personal information as soon as possible so that we can contact you easily.
Members of the Jigsaw Homes Group may share with other members of the Group personal information that they collect about you
Processing personal data is lawful if the data subject (e.g. you as our customer) has given consent or where the processing of personal data is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Processing of your data is lawful if you apply for housing with us, apply for a job with us or have been housed by us. We do not need your explicit consent to process your data in these circumstances.
Where you are a tenant of ours we will use your personal data to contact you about your rent, repairs or other housing management issues. The consequences of not providing accurate and up to date personal data in this example may mean that we could not properly and effectively manage your tenancy under the agreement we have with you.
We collect and hold personal information about:
- customers – This includes current, former and potential customers who live in our properties or access our support and other services and includes members of their family and people associated with them
- visitors – Visitors to our website and our offices
- anyone who makes a complaint or enquiry to any of the Jigsaw Homes Group companies
- partners, including employees and representatives of organisations with whom we do business including contractors, suppliers and other agencies.
We use your personal information to:
- enable us to provide you with accommodation and to communicate with you
- provide social and other types of housing
- assess your ability to afford our home ownership products by sharing your name, address and contact details with our appointed contractor. We will also notify any third parties involved in the sale of the property you are buying of the outcome of your application
- • undertake property and grounds maintenance, repairs and improvement/upgrade works
- manage your housing, tenancy/lease and accounts as your landlord or provider of another service to you
- ensure that we meet all our legal and statutory duties such as those which apply under the Equality Act, Fire safety etc and those owed to our funders and regulators
- promote equal opportunities and fair treatment for all our customers
- provide information (e.g. about products and services) you request from us
- help with crime prevention, prosecution of offenders and resolution of disputes. Where an allegation of a tenancy breach is made we will record the details on our case management system and will retain the details of such allegations for the duration of the tenancy of the (person or persons) against whom they are made, whether or not they are proven, as a means of establishing a pattern of anti-social behaviour that may assist us in taking enforcement action at a later date either against the alleged perpetrator(s) or the alleged victim(s);
- prevent and detect fraud and money laundering
- promote safety and the quiet enjoyment of our neighbourhoods and communities in our capacity as social housing providers
- engage with customers and make improvements to our products and services
- improve services by gathering your feedback in automated surveys
- protect individuals from harm as part of our safeguarding and other obligations
- provide you with welfare services including advice and appropriate support
- provide support for elderly and vulnerable customers
- keep in touch with our customers, understand your needs and preferences and invite you to events
- apply for grants to make improvements to your home; and
- carry out research and to provide anonymised information to help improve our services
- we may record public meetings for the purposes of holding accurate records.
Certain personal information is classified as ‘special categories data’ and means any personal data which tells us about your ethnic origin, political opinion, religious or philosophical beliefs, trade-union membership or anything revealing your genetic data, biometric data or anything which has the purpose of uniquely identifying you, anything concerning health or data relating to a person’s sex life or sexual orientation, allegations of criminal offences and criminal convictions and offences.
We minimise our holding and use of special categories data but, given the services we provide, there are times when we use it to understand our customers and their needs better, for example when providing accommodation for disabled persons or those with problems around substance abuse, when resolving neighbourhood disputes involving alleged criminal activity or anti-social behaviour or when helping someone to access care services. When we collect specific sensitive data we will notify you of how we will use it, including who it may be shared with, and seek your consent to this.
We also use sensitive personal data to ensure that we are complying with our obligations under the Equality Act.
We do not propose to use your personal data to make any automated decisions. Should our policy change, we will write to you and tell you this.
This privacy notice will be updated to reflect any changes either to the way in which we operate or changes to data protection legislation. We will bring any significant changes to your attention but to make sure that you keep up to date, we suggest that you revisit this notice from time to time.
We store personal data in line with our own document retention policy, a copy of which is available on request. Examples are:
- applications for accommodation, which are kept for 6 years after offer accepted
- tenancy files, which are kept for 6 years after the end of the tenancy
- application forms for shortlisted job applicants, which are kept for 1 year
- application forms for non-shortlisted job applicants, which are kept for 6 months.
If we store data other than in line with this guidance we will explain this.
The Group applies technical measures to store personal data securely on information systems, including controls over the organisation’s information network perimeter, such as firewall, anti-virus software and back-up/replication measures to prevent data loss. Access to personal data held on systems is controlled by password and can be monitored by audit records. Sharing of data with third parties is controlled by the use of secure transfer measures such as encrypted email and secure file transfer protocols.
The data held on mobile devices (smart phones, tablets and laptops) used by staff is encrypted. Staff are equipped with lockable bags for carrying personal data files outside of the office and we apply a clear desk policy in our offices.
The technical measures are supported by training and awareness raising exercises to ensure that staff understand the risks and their responsibilities for keeping personal data secure.
We have set out below some information on the rights you have under the General Data Protection Regulation. More information can be found by visiting the ICO website at www.ico.org.uk.
You have the right to:
- be informed about our collection and use of your personal data
- access the personal data we hold about you (see below)
- ask us to rectify any personal data we hold about you if it is inaccurate or incomplete
- ask us to delete any personal data we hold about you. We only hold your personal data for a limited time as explained above but if you would like us to delete it sooner please contact us. However we need to maintain certain records to enable us to comply with our contractual or statutory obligations even if you make such a request so certain information may still be retained by us even if you make such a request
- restrict (i.e. prevent) the processing of your personal data
- data portability (obtaining a copy of your personal data to re-use with another service or organisation)
- object to us using your personal data for particular purposes
- be informed about when we are using your personal data in automated decision making and profiling and object to this. We will inform you where such decisions and profiling occur; and
- withdraw consent you have given us to use your personal data. You may do this in writing to dpo@jigsawhomes.org.uk.
How do I complain about how you use my data?
If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 2 above and we will do our best to solve the problem for you. If we are unable to help you also have the right to lodge a complaint with the ICO; please go to www.ico.org.uk.
You have the right to access any personal information we hold about you, which we call a Subject Access Request (SAR). The purpose of these is to help you understand how and why we are using your data.
If you make a request to the Group or any member of it we will review the personal information held about you by all members of the Group when compiling our response.
It should be noted that the right of access is there to provide you with your personal data rather than giving the right to see copies of documents containing your personal data. We are not obliged to provided copies of original documents and some personal data may therefore be provided in the form of transcripts of relevant documents, sections of documents, or extracts of relevant information from our systems.
Where we process a large volume of data about you then we can ask that you specify the information or processing activities your request relates to, if it is not clear. The time limit for responding to your request (outlined below) will be paused until clarification is received.
How to make a SAR
You can make a request verbally (e.g. by speaking to a member of staff) or in writing (e.g. ; email to: dpo@jigsawhomes.org.uk or by letter to our registered office).
Can we ask for ID?
We need to be satisfied we know the identify of the person making a SAR (or the person the request is made on behalf of). To do this we may require proof of identity from you before releasing information. Depending on the circumstances this may include:
- Proof of signature/photo ID (e.g. driving license / passport)
- Proof of address.
- If you are a tenant we will accept verbal confirmation via Connect once their security checks have been completed.
Where a request is received from a third party claiming to represent you, we will also ask them for proof of this, which must include a signature that is verifiable against documentation we already hold. We also reserve the right to get in touch with you direct to confirm their appointment.
The timescale for responding to a SAR (outlined below) does not begin until we have received the requested information.
How long will a SAR take?
Ordinarily we are required to provide the information requested within one calendar month of receiving your request. This can be extended to three calendar months should a request be considered complex.
When can we refuse to comply with a request?
In certain circumstances we can refuse to fulfil a SAR. These are:
- Where the request meets the manifestly unfounded and/or manifestly excessive criteria laid out by the ICO
- Where an exemption applies.
Should we refuse your request we will clearly outline the reason(s) why and of your rights to make a complaint via the ICO / other supervisory body / the courts.
Can we charge a fee?
We will not normally charge for information requested via subject access request. However we can charge a ‘reasonable fee’ for the administrative cost of complying with a request if it is manifestly unfounded / excessive or if an individual requests further copies of their data.
