• Organisation: Havenmore Housing Association CIC
• Address: 3rd Floor, 86–90 Paul Street, London, EC2A 4NE
• Email: housing@havenmorehousing.org.uk
• Phone: 0207 664 8955

• name, address, date of birth and contact details;
• tenancy, licence, room, property and move-in details;
• rent, service charge, payment, arrears and Housing Benefit information;
• appointee, attorney, deputy, advocate, family or representative details;
• local authority, social worker, commissioner, care provider and professional contact details;
• communication needs, accessibility needs and reasonable adjustments;
• repairs, maintenance, access and property condition records;
• complaints, feedback, incidents and safeguarding information;
• risk information relevant to tenancy sustainment, shared living, property safety or safeguarding;
• correspondence, call notes, emails, forms, documents and records of contact.

• you;
• family members, advocates or representatives;
• appointees, attorneys or deputies;
• local authorities, social workers, commissioners and Housing Benefit teams;
• care and support providers;
• NHS or mental health professionals where relevant;
• contractors, maintenance providers and compliance suppliers;
• police, safeguarding teams, emergency services or regulators where relevant;
• publicly available sources where needed for lawful purposes.

• assess referrals and housing suitability;
• manage tenancies, licences, rooms and properties;
• issue tenancy information, rent schedules and housing documents;
• manage rent, service charges, payments, arrears and Housing Benefit liaison;
• arrange repairs, maintenance, inspections and safety checks;
• manage access arrangements and reasonable adjustments;
• respond to complaints, feedback, incidents and service requests;
• respond to safeguarding concerns or emergencies;
• work with authorised representatives and professionals;
• meet legal, regulatory, financial, insurance and audit requirements;
• monitor service quality and improve how we work.

• Contract: where information is needed to enter into or manage a tenancy, licence or housing agreement.
• Legal obligation: where the law requires us to use or keep information, such as health and safety, safeguarding, company, tax, accounting or data protection duties.
• Legitimate interests: where we need to manage housing services, protect property, recover rent, manage risk, handle complaints, improve services or communicate with relevant parties, and this is not overridden by individual rights.
• Vital interests: where information is needed to protect someone’s life or immediate safety.
• Consent: where consent is appropriate, for example some representative communications or optional communications. Consent can usually be withdrawn.

• health information;
• disability or accessibility information;
• mental health or support-related information;
• safeguarding information;
• information about racial or ethnic origin, religion, sex life or sexual orientation where relevant and necessary;
• information linked to vulnerability, risk or care and support needs.

Where we use special category data, we must have both a lawful basis under Article 6 UK GDPR and a special category condition under Article 9 UK GDPR. We will only use this information where necessary and proportionate.

• explicit consent where appropriate;
• substantial public interest, such as safeguarding or protecting people at risk;
• vital interests where someone cannot give consent and there is serious risk;
• legal claims or legal obligations where relevant;
• health or social care purposes where appropriate and lawful.

• local authorities, Housing Benefit teams, social care teams and commissioners;
• DWP or other public bodies where relevant to housing costs or benefits;
• care and support providers where housing and support need coordination;
• appointees, attorneys, deputies, advocates or authorised representatives;
• contractors, maintenance providers and property compliance suppliers;
• emergency services, police and safeguarding teams;
• insurers, legal advisers, auditors, accountants and professional advisers;
• regulators, courts, tribunals or public authorities where required or lawful;
• IT, software, hosting and document management providers supporting our systems.

• We may share information without consent where this is necessary to protect someone from harm, prevent a crime, respond to an emergency, or meet a legal duty.
• We will seek consent where appropriate, but we may not do so where this would increase risk or delay protective action.
• Safeguarding records are handled carefully and shared only with those who need to know.

• name, address and contact details;
• access arrangements;
• communication or safety information needed for the visit;
• information about the repair or property issue;
• details of a representative or support contact where needed to arrange access.

• We may ask for consent or evidence of authority before sharing information or taking instructions from someone else.
• This may include appointeeship, Lasting Power of Attorney, deputyship, advocacy arrangement or written consent.
• Where mental capacity or safeguarding issues arise, we may need to involve relevant professionals or follow legal safeguards.

• whether you are an applicant, tenant, former tenant, representative or professional contact;
• the type of information;
• legal limitation periods;
• financial and accounting requirements;
• safeguarding, complaint, incident or legal risk;
• whether there is an ongoing dispute, claim or investigation.

• We restrict access to people who need the information for their role.
• We use secure systems and access controls.
• We train staff on confidentiality and data protection.
• We review and manage data risks where needed.
• We take action where there is a suspected data breach.

• ask for a copy of personal information we hold about you;
• ask us to correct inaccurate information;
• ask us to delete information in some circumstances;
• ask us to restrict how we use information in some circumstances;
• object to some uses of information;
• withdraw consent where we rely on consent;
• complain to the Information Commissioner’s Office.

• Email: housing@havenmorehousing.org.uk
• Phone: 0207 664 8955
• Address: Havenmore Housing Association CIC, 3rd Floor, 86–90 Paul Street, London, EC2A 4NE

If you are unhappy with how we handle your information, you can contact the Information Commissioner’s Office. The ICO is the UK regulator for data protection.

• ICO website: ico.org.uk
• ICO phone: 0303 123 1113