Privacy Policy About us Your personal information is collected by ‘Affordable Housing and Healthcare’ trading as ‘Platinum Skies’, and includes Affordable Housing Communities Ltd and Platinum Skies Management Ltd. Our Registered address is: 170 Charminster Road Bournemouth Dorset BH8 9RL We design, build, and manage delightful new homes for retirement living. This privacy policy explains how we use any personal information we collect about you when you conduct business with us. or use our website Affordable Housing and Healthcare Ltd is registered as a data controller with the Information Commissioner’s Office. The current data controller registration details are: Data Controller Name: Affordable Housing and Healthcare Group Limited Registration Number: ZA217941 Date Registered: 16th November 2016 Information we may collect This notice applies if you are a potential or existing customer, or use any of our services, visit our website, email, call, social media messages, write to us, or visit us in person. The type of information we collect depends on our needs. For example, if you contact or visit us, we may only need limited information about you to deal with your query. If you are one of our customers, we may need to collect a variety of information about you to ensure that we can provide you with the appropriate information or refer you to the appropriate services to assist you. We currently collect and process the following information: What information we hold (customers) When you begin the process to become a customer, we obtain certain information to determine your needs. You will provide us with information through your property purchase process which will generally include. Full name including proof of your identity / photo ID. Date of birth. National Insurance number. Contact details, including telephone, email or contact address. Details of anyone authorised to act on your behalf if applicable. Personal Details of all household residents. Banking or payment card details if you make payments to us. Council tax information. Proof of eligibility. Other personal information may be collected to help us resolve breaches of leases, alleged anti-social behaviour or suspected fraud. We may also need additional information from you concerning: Disabilities or vulnerabilities – We use this information to tailor our service to better meet your needs. We may also use this information for safeguarding of staff. Health information – to ensure that the property meets your needs. Financial information – It is important that to ensure that arrears payments are settled quickly, therefore we may collect information to help us to work out a plan with you. Identification – Photo ID, bank statements, payslips or income details may be used during the processing of a purchase. We will only use such data in very limited and strictly appropriate circumstances. We will record information whenever you contact us or use our services and we will note any action taken, for example logging repairs, and feedback from our contractors about appointments with you, so that we have a record of what happened and of our contact with you. How we will use the information about you Your personal data will be collected and used to help us deliver activities or services or to complete a task raised at your request. What we do with your information will depend on the nature of our relationship with you and how you interact with our various services and website. We use your personal information to allow us to: Enter into, or manage any contract we have with you, including: Processing applications and requests for Home ownership Managing leases including collecting rent and service charges Ensuring compliance with the conditions of any agreement between us Providing lifestyle services Providing repairs, maintenance, and adaptions at our properties Providing home ownership products Providing care and support for elderly and vulnerable customers Provide you with services and benefits in both our legitimate interests, including ensuring the proper management of your lease and giving you appropriate support: Assisting you in the management of account charges, payments, and arrears Providing support services Keeping in touch with customers to understand your needs and preferences and invite you to events Engaging with customers to make improvements to our products and services To collect feedback to improve our services and monitor customer experience To improve our services to input in to our marketing programme, to assist promotion of our services and adopting our products Comply with our legal and regulatory obligations, and acting in the public interest, such as: Preventing and detecting crime and resolve disputes Preventing and detecting fraud and money laundering Promoting safety and the quiet enjoyment of our neighbourhoods and communities Promoting equal opportunities and fair treatment for all our customers Meeting the obligations we owe to our funders and regulators Processing data which requires your Consent We may sometimes process your data for specific purposes which require your consent. If we do this, we will always ask for your written consent. Where we are processing your personal data based on your consent, you have the right to withdraw that consent at any time. This may affect the services that we can make available to you, but this will be explained in the consent form. Please contact us if this is the case. Sensitive or Special Category Personal Data Under the data protection legislation certain personal information is classified as “sensitive” or “special category” personal data. This includes information relating to racial or ethnic origin, physical or mental health, sex life or sexual orientation, religious or philosophical beliefs, political opinions, membership of a Trade Union, allegations of criminal offences and criminal convictions and offences, along with biometric data such as fingerprints. We minimise our holding and use of sensitive categories of personal information 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 when helping someone to access care services. We will usually be processing this information to allow us to comply with our legal obligations, act in the substantial public interest in relation to the services we provide, to provide you with social care, or to deal with any legal action. There may be times where we need to ask you for your consent to use this type of personal information, in which case we will always notify you and make this clear. Sharing your information Your personal information will be kept secure and confidential. Our staff have restricted access to personal information on a “need to know” basis. We may share information with third parties, including contractors we work with such as our repairs and maintenance contractors, lifestyle service providers, third party cloud hosting and IT infrastructure providers, agencies, and authorities we work with, such as Local Authorities, Social Services and Police. We will share certain information in appropriate circumstances with our regulators, funders, or purchasers or potential purchasers of our business. We will also share relevant information with others when we consider it is in your, or the public’s, interest to do so, such as to keep customers, staff, or visitors safe, or as required by law. In particular, please be aware: Current or forwarding addresses may be shared with utility companies and Council Tax offices to ensure billing details are correct. If you default on any lease conditions, information about you may be provided to authorised debt recovery agencies, to enable them to recover the debt. This may affect future applications for credit and insurance. We may pass your contact information to a third party to conduct surveys and research on our behalf which allow us to gather feedback and improve the services we offer you. The third party will be bound to strict terms and conditions outlined by us and will not share your data with other organisations. Should you choose not to participate in the surveys the third party will securely destroy your data. When we allow third parties acting on our behalf to access your information, we will always have complete control of what they see, how long they see it for and what they can do with it. We do not sell or share your personal information for other organisations to use. How we secure your data Information system and data security is imperative to us to ensure that we are keeping your data safe. We operate a robust and thorough process for assessing, managing, and protecting new and existing systems which ensures that they are up to date and secure against the ever-changing threat landscape. In addition to this, we follow a defence in-depth security model, which means that your data is protected by multiple layers of security. Personal information is stored and managed within a variety of IT software systems which are maintained to achieve a high level of security and confidentiality. We hold information in IT systems which may be copied for testing, backup, archiving and disaster recovery purposes. Our employees sign our privacy standard which sets out how we handle the Personal Data of our customers, suppliers, employees, workers and other third parties. The Privacy Standard applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject. Only those staff members and third parties who require access to your information will be able to access it. When you trust us with your data, we will always keep your information secure to maintain your confidentiality. By utilising strong encryption when your information is stored or in transit, we minimise the risk of unauthorised access or disclosure; when entering information on our website, you can check this is secure by right clicking on the padlock icon in the address bar. AHH and Platinum Skies are based in the UK and we store most of our data within the UK. How long do we keep your information? We will only use and store your information for as long as it is required for the purposes it was collected for. How long information will be stored for depends on what it is being used for. Sometimes we may also need to keep information for statutory or regulatory purposes or to deal with any legal claims. We will usually keep: any home purchase information for 6 years following completion of the purchase. service charge statements for 2 years. information on your property file for 6 years following the end of your lease with us. care plans and related documents permanently, or until transferred to a subsequent provider; and recordings of telephone calls for 30 days. Your data protection rights Under data protection law, you have rights including: The right to be informed about how your personal information is being used The right to access the personal information we hold about you The right to request the correction of inaccurate personal information we hold about you The right to request that we delete your data, or stop processing it or collecting it, in some circumstances The right to restrict direct marketing messages, and to withdraw consent for other consent-based processing at any time The right to request that we transfer or port elements of your data either to you or another service provider The right to complain to your data protection regulator — in the UK, the Information Commissioner’s Office If you want to exercise your rights, have a complaint, or just have questions, please contact us. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. If you wish to make a request, please contact us at: [email protected] or call 01202 531 635 or you can write to us at: Data Protection Officer Company Secretariat 170 Charminster Road Bournemouth BH8 9RL The Data Protection Act 2018 also gives you the right to lodge a complaint with the supervisory authority in the UK. This is the Information Commissioner who may be contacted at https://www.ico.org.uk/concerns or telephone: 0303 123 1113. The ICO’s address: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Website Specific Marketing We may also ask you to complete surveys and participate in market research projects that we use for research purposes, although you do not have to respond to them. We automatically collect web statistics about your visit to our site. This information is used to help us follow browsing preferences so that we can regularly improve our website. These statistics do not contain personal data and cannot be traced back to an individual. We do not use cookies to store personal data or link non-personal information stored in cookies with personal data about specific individuals. We will only disclose your information if it is lawful to do so in accordance with the Data Protection Act 2018 or the General Data Protection Regulations. We would like to send you information about products and services of ours and other companies in our group which may be of interest to you. If you have consented to receive marketing, you may opt-out at any time. You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, you may unsubscribe from any marketing email, or adjust your marketing preferences. You may also contact our marketing team on [email protected] Cookies We use cookies when you visit our site. There are four main types of cookies – here is how and why we use them: Site functionality cookies. These cookies allow you to navigate the site and use our features Site analytics cookies. These cookies allow us to measure and analyse how our customers use the site, to improve both its functionality and your user experience. We use Google Analytics to collect information about visitor behaviour on our website. Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. This Analytics data is collected via a JavaScript tag in the pages of our site and is not tied to personally identifiable information. We therefore do not collect or store your personal information (e.g., your name or address) so this information cannot be used to identify who you are. The Google Analytics tracking cookie also allows us to access aggregates demographic and audience data from online behavioural advertising services. This information is only available to us at a group level, with no personal or identifiable information contained within it. It is used only for us to evaluate the effectiveness of the website and see how different groups of users use and respond to the site, and in no way allow us to track people individually. You may opt out of this tracking by disabling cookies within your browser. Customer preference cookies. When you are browsing, these cookies will remember your preferences (like your language or location), so we can make your experience as seamless as possible, more personalised to you, and save you time specifying them again Targeting or advertising cookies. These cookies are used to deliver ads relevant to you. They also limit the number of times that you see an ad and help us measure the effectiveness of our marketing campaigns. By using our site, you agree to us placing these sorts of cookies on your device and accessing them when you visit the site in the future. If you want to delete any cookies that are already on your computer, the “help” section in your browser should provide instructions on how to locate the file or directory that stores cookies. Further information about cookies can be found at https://ico.org.uk/for-organisations/guide-to-pecr/cookies-and-similar-technologies. Please note that by deleting or disabling future cookies, your user experience may be affected, and you might not be able to take advantage of certain functions of our site. Your name, address, telephone number or email address may also be used to find you on Facebook [and Instagram], for the purposes of targeting you with advertising of our products and services on Facebook [and Instagram]. Changes to how we protect your Privacy We may change this notice from time to time, to reflect how we are processing your data. If we make significant changes, we will make that clear on our website, or by some other means of contact such as email, so that you are able to review the changes before you continue to use our services.