Clarion Futures Privacy notice
Clarion Futures, as part of Clarion Housing Group (Clarion), needs to process personal data in order to deliver our services to you as applicable:
- To develop and deliver services around community development to make our estates and neighbourhoods more attractive and vibrant places to live
- To deliver services around jobs and training
- To help people manage their money through budgeting advice, providing access to high quality debt advice and affordable loans and by helping people to manage their energy costs
- To support residents to get online and improve their digital skills
- To ensure young people have access to our youth programme
- To deliver on our ambition to ‘transform lives and communities’
We are committed to treating your information securely, with respect and in line with data protection legislation.
This privacy notice tells you what to expect when Clarion Futures processes your personal information. It applies to information about Clarion Futures applicants, residents and other service users.
This is a specific privacy notice for Clarion Futures. However, if you are also a Clarion Housing Group customer, you will also be subject to the Clarion Housing Group Privacy Notice which is available (with all others) on our website www.clarionhg.com under ‘Privacy Notice’.
It is important for you to read this Notice in full to understand what information we hold about you, how we may use it and your rights in relation to your data. However, we have also produced a summary version explaining why ‘Privacy Matters at Clarion Futures (PDF)’.
Clarion Housing Group includes a number of subsidiary organisations such as Clarion Housing and Clarion Futures.
We keep our privacy notice under regular review and we will place any updates on our website. If you would like to receive a hard copy of our current privacy notice, please let us know.
For further information you can contact the Data Protection Officer as follows:
The Data Protection Officer
Clarion Housing Group Ltd
Level 6, 6 More London Place
London SE1 2DA
For independent advice about data protection, privacy, e-privacy and data sharing issues, you can contact the Information Commissioner. (Lots of useful information is accessible on their website):
Wycliffe House, Water Lane,
Cheshire SK9 5AF
Phone: 0303 123 1113
What information do we collect about you and how is this used?
We will only collect personal information when we need (this). The type of information we need from you will vary depending on our relationship with you. When we ask you for information, we will make it clear why we need it. We will also make it clear when you do not have to provide us with information and any consequences of not providing this.
Most information we hold will be collected from you but we may also obtain this from third parties such as the local authority, your doctor (or other health professional), a previous landlord or other relevant community partner. This will generally be as a result of a discussion that we have with you. In addition, we may also obtain information from publicly accessible sources or engage the service of market research organisations to validate, or where appropriate, enhance the information that we hold.
We collect information from you (as applicable):
- To prioritise and assess applications for services and to check for eligibility:
- we will need your name, address and contact details (including telephone numbers, email addresses and details of anyone you may choose to represent you) for use by Clarion Futures and our partners.
- as required we will collect detailed personal information about you and other household members*, including age, sex, date of birth, ethnicity, income and expenditure, National Insurance number, income and benefits details, employment status, gender identity, relationship status, any disabilities, any communication and accessibility requirements, religion, sexuality, nationality, caring responsibilities, access to financial services such as banks and credit unions, bank details, benefits, council tax, medical information, details of any unspent criminal convictions.
* When you provide information about household members we assume that you do so with their full knowledge and consent.
Provision of information is voluntary (with the exception of Government mandated programmes such as ‘The Work Programme’ where the Government require participation and therefore the provision of relevant information), however without this information, we may not be able to provide this service. We will make it clear at the point of data collection whether the information is optional. For example, we cannot provide services to you if you do not give us your contact details. Please speak to us with any concerns.
Where enquiries relate to household members, it is in our legitimate interests to check that support offered to you is adequate for current and near future needs of the household and to check that household members’ needs are being met.
- To manage your service:
- we require up to date contact details (telephone number and email address) so we can reach you when we need to discuss issues pertaining to your service or tenancy, e.g. to offer you advice, request further information, tell you about other support options open to you directly linked to you needs, follow up on the progress of a service or if we need to arrange a home visit.
- we may require information relating to ongoing support requirements which could include your employment, health or finances for example.
- we will also use your contact information to tell you about changes to Clarion Futures and Clarion Housing Group, for example our organisational structure and governance arrangements, and to resolve or investigate complaints.
- we require details of any change in circumstances (e.g. if you move house and are in a location dependant service that means your service requirements need to be re-assessed).
- we will hold records of all our contact with you, your contact with us, and any contact from third parties representing you or about you. This may include call recordings.
- we may hold information about your history, for example regarding credit status or offences, if we need it to look after our staff, business or anyone else or if this is relevant to advice or services offered.
Provision of information requested by us is voluntary (with the exception of ‘The Work Programme’ where the Government require participation and therefore the provision of relevant information); however, without this information we may not be able to provide this service. We will make it clear at the point of data collection whether the information is optional. For example, we would be unable to support you with an application for charitable support if you do not provide details of the benefits you are in receipt of. Please speak to us with any concerns.
Where enquiries relate to household members, it is in our legitimate interests to check that support offered to you is adequate as explained above.
- To meet your needs in our service delivery
- to ensure our services are accessible, that we take account of any support needs in our dealings with you and to improve our communications with you. For example, if you are involved with a carer, social worker or other advocate, if there are considerations we need to apply when we visit you at home, if you need large print or translated text.
- when profiling you for services and to target our resources.
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.
- To prevent fraud and confirm eligibility for certain services
- we will ask for proof of ID and supporting information.
Processing for the purpose of fraud prevention is required in order to meet our legal obligations. Therefore if we are unable to verify your identity we may not be able to provide services to you.
- To assist with personal security and prevention and detection of crime
- we may capture your image on our CCTV systems if you visit an estate, office or community facility which is covered by this facility.
Processing of this information may be required to meet our legal obligations and our legitimate business interests around health and safety and crime prevention.
- To understand how we’re performing
- we may undertake call recordings for training and quality monitoring purposes.
- we may use your contact details to carry out market research and customer satisfaction surveys to help us to monitor our performance and to improve our services to our customers.
- to segment customers to help target our resources and prioritise services.
- in managing and analysing complaints.
- for statistical analysis.
It is in our legitimate interests to understand how we are performing so we can meet our mission statement and objectives.
There may also be a legal obligation for us to process the information or to demonstrate to our regulator that we are fulfilling our obligations, for example around anti-discrimination laws.
We also use your personal information in the following ways:
- Keeping in touch with you, understanding your needs, and inviting you to events.
It is in our legitimate interests to communicate with you and keep you up to date with news and events in order to meet our Group objectives around social inclusion and helping to build communities.
- Prevention and detection of crime, and quality management.
We do this to meet our legal obligations.
- Meeting our legal obligations including the requirements of our funders or regulators.
This is a legal obligation on Clarion.
Automated Decision Making and Profiling
We do not undertake automated decision making or profiling which has legal or similarly significant effect on you (where a computer system makes a decision about you without human intervention e.g. deciding if you are eligible for a loan). We do use software tools but any decisions about you are made by our staff rather than ‘automated’. Should this change in the future, we will inform you and explain your rights relating to this, for example that you have the right to challenge the validity of any decisions made in this way or object to automated decision making and ask us not to use this method of processing.
Special categories of personal data
As well as personal information (such as your name, address and data of birth) we may collect sensitive personal information (also known as special categories of data) of which may include:
- Racial or Ethnic origin
- Religious or Philosophical Beliefs
- Sexual Orientation
- Health information
We use this data to ensure services are delivered appropriately and to monitor Equality, Diversity and Inclusion.
We will apply additional security and confidentiality measures when processing special categories of data.
We will ask for your specific informed consent to process this data at the time of collection (unless we permitted or required to do so by law, for example under Health and Safety Legislation).
Where you provide consent for us to process sensitive personal information, you have the right to withdraw this consent at any time.
We may also process confidential data about you including bank and / or financial account information.
How will we protect information about you?
We will apply appropriate technical and organisational measures to ensure your personal information is secure. For example, we have systems in place to ensure that access to personal information is restricted to authorised individuals on a strictly need-to-know basis.
When we need to share personal data with our contractors and third party suppliers, our relationships are governed by our contracts with them which include strict data sharing and confidentiality protocols. Where we are working in partnership, we will ensure that Information Sharing Agreements govern the sharing of data.
To help us ensure confidentiality of your personal information we will ask you (and any of your representatives) security questions to confirm your identity when you call us and as may be necessary when we call you. We will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so, where we have received a clear verbal instruction from you (as a one-off circumstance) or where there is a legal order in place such as a Power of Attorney.
Who will we share your information with?
Sometimes we need to share personal information we hold about you with other organisations that we work with or who provide services on our behalf. When sharing information we will comply with all aspects of data protection legislation.
Where the information is of a sensitive nature, for example about your health, we will obtain consent from you prior to sharing this information, unless we are required or permitted to share this by law.
Where ‘sharing’ is in our ‘legitimate business interests’, we may share your information without seeking your consent first. This may be with:
- Other organisations in the Clarion Housing Group and contracted delivery partners
- Debt and money management advisors.
- Local authority teams such as social services, environmental health and benefit agencies.
- Utility companies (and their representatives) and Council Tax Departments to ensure billing details are correct.
- Third parties providing services on our behalf. For example a mailing company distributing our newsletter; a research company carrying out a customer satisfaction survey, or a debt collection agency pursuing former tenant arrears.
- Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative. More information can be found on the work undertaken by the Cabinet Office at: https://www.gov.uk/government/collections/national-fraud-initiative
- Police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime, the apprehension of offenders or the collection of tax or duty.
- Other statutory organisations e.g. social services and health authorities as necessary for exercising statutory functions.
We may also share information when required by law for example where ordered by the Court or to protect an individual from immediate harm.
There may be occasions where we need to process your information outside of the European Economic Area (EEA), for example where we use a third party computer system supported by employees in the USA. Where we do this we will take all necessary steps to ensure that your information remains secure. You can ask us for more information about how our International Processing arrangements affect you by using the contact details above.
Contact arrangements and promotion of our services
We will routinely use your contact details to send you relevant information and communicate with you about the Clarion Futures service as a whole. This is to ensure that you don’t miss out on any of the offerings which Clarion Futures provides because one area of support is often associated with another. For example, receiving digital support may lead to training opportunities. As a customer, we will also tell you about events in your area. During our work with you, we may establish other areas of support that one of our partners could deliver. We will talk to you about this and send you relevant communications about these as appropriate.
We would also like to keep you updated with information about other products and services (of ours and other reputable companies we work with) which do not form part of our core services but that we think may be of interest to you and where this will assist us in meeting our Group objectives to transform lives and communities. This could include information about events run by Clarion Housing Association. It’s a legitimate business interest for us to send you postal communications (from time to time) which may comprise information about all these areas of our work. You can object to receiving this type of content from us in the post. Before sending electronic communications of this nature, we will follow the law and guidance which requires us to seek your consent. You can change your mind at any time. Please just contact us or follow the ‘unsubscribe’ instructions that will be available on all of our promotional publications.
Neither Clarion Futures, nor Clarion Housing Group will ever sell your personal data to 3rd party organisations for marketing purposes.
How long will you keep my data?
Clarion Futures only holds records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us. This is currently set at 2 years, after which we will delete your personal information unless our contracts with funders require us to keep this longer. You can contact us to see if this applies.
Your rights in relation to your data
Clarion Futures is committed to upholding your rights in respect of your personal data.
The right to be informed
Through the provision of our suite of privacy notices, we will be open and transparent about how and why we use your personal information.
The right of access
You have a right to ask us what personal information we hold about you and to request a copy of your information. This is known as a ‘subject access request’ (SAR).
SARs need to be made in writing (we have a subject access form you can use for this purpose), and we ask that your written request is accompanied by proof of your address and identify.
If you are seeking to obtain specific information (e.g. about a particular matter or from a particular time period), it helps if you clarify the details of what you would like to receive in your written request.
If someone is requesting information on your behalf they will need written confirmation from you to evidence your consent for us to release this and proof of ID (both yours and theirs).
We have 1 calendar month within which to provide you with the information you’ve asked for (although we will try to provide this to you as promptly as possible). In response to SARs, we will provide you with a copy of the information we hold that relates to you.
The right to rectification
You can ask us to rectify your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by keeping us informed if your details change.
The right to erasure
The right to erasure is also known as ‘the right to be forgotten’. In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for its continued processing. This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data. Our response will also be guided by the provisions of our retention schedule.
The right to restrict processing
In some circumstances you can ask us to restrict processing, for example
- if you disagree with the accuracy of personal data
- if we’re processing your data on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate grounds override those of yours.
The right to data portability
If the situation arises where it would be helpful for you to move, copy or transfer personal data we hold about you, across different services, you may be able to ask us to do this. Please contact us to discuss.
The right to object
You can tell us if you object to our processing of your personal data:
- based on legitimate interests
- for the purpose of direct marketing (including profiling);
Rights in relation to automated decision making and profiling.
You can ask us to review any decisions that are determined by automated means. You can also object to our use of your personal data for profiling.
As explained earlier, we do not currently undertake this and will advise you if this position changes.
If you’d like to talk to us about your rights, you can contact us at email@example.com. Alternatively, if you want to raise a complaint about our processing of your data or would like to seek an independent view, you can contact the Information Commissioner using the contact details provided at the start of this notice.