AAA Accessibility

Introduction

House Exchange is a partnership between Clarion Housing Group Ltd and 101Smart Ltd, both of which are Joint Data Controllers for the purpose of this service.

Clarion Housing Group are the lead contact for House Exchange and will be the point of liaison for customers and landlords.

Clarion Housing Group includes a number of subsidiary organisations such as Clarion Housing Association Limited and Clarion Futures. Please see our registered company information, including registration details and registered offices of all the entities associated with Clarion.

House Exchange needs to process personal data in order to provide the House Exchange service to you.

We receive personal data relating to you from you directly, but it may occasionally be provided to us by third parties with whom you have a separate relationship (such as a local authority).

We use your data to provide services relating to house exchange to you, correspond with you, meet our legal obligations and improve our website and our products and services.

The lawful basis for processing personal data about you falls into one of the following four categories:

  1. To meet our obligations under a contract – your tenancy agreement or lease - or because you have asked us to do something with a view to entering into a contract with you;
  2. In order to further House Exchange’s (or a third party’s) legitimate interests. Our legitimate interests include: ensuring that we monitor, analyse, deliver and improve our services to you and your household members; to properly manage our business; and to promote our services. We will look to balance your interests with our legitimate interests where we rely on this lawful basis.
  3. Where we have a legal obligation to do so; and/or
  4. To protect the vital interests of you, your family or others.

We are committed to treating your information securely, with respect and in line with data protection law.

This privacy notice applies to all users of the system and tells you what to expect when House Exchange processes your personal information.

It is important for you to read this policy in full to understand what information we hold about you, how we may use it and your rights in relation to your data.

We keep this privacy notice under regular review and we will place any updates on our website (houseexchange.org.uk). 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
House Exchange C/O Clarion Housing Group Ltd
Level 6
6 More London Place
Tooley Street
London SE1 2DA

dataprotection@clarionhg.com

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):

Information Commissioner,
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Phone: 0303 123 1113
Email: casework@ico.org.uk
Website: www.ico.org.uk


What information do we collect and how is it used?

We will only collect personal information when we need this. 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 or Housing Association where they are in partnership with House Exchange.

We collect information from you:

To process your application to join House Exchange and manage your service:

  • your name and contact information, including your email address;
  • your home address and other information about your current property including features, restrictions and adaptations;
  • basic details regarding the new property you are seeking e.g. location, property type, number of bedrooms;
  • your contact preferences for other users to approach you e.g. SMS, Phone, Email;
  • information required to take payment for this service via PayPal for social housing residents of non-partnered landlords. Please note, only a basic payment reference is stored from PayPal. We do not have access to your payment details.
  • each time you search for properties you will be able to add additional search criteria to your basic search, such as adaptations to the property.
  • your geographical location, Local Authority and / or and Landlord (if appropriate) may be used to send appropriate service updates or surveys to you or to display relevant messages on the site itself

Provision of some of the information requested by us is part of a ‘Contractual Requirement’. Without this information, we will be unable to accept an application for the House Exchange service as we would be unable to manage your service. Please speak to us with any concerns.

It is also in our legitimate interests to use your geographical location in order to tailor the service to your needs.

To understand how we’re performing:

  • 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.
  • 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 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 about the service, to understand your needs and to assist you in making the most of the service’s features.

It is in our legitimate interests to communicate with you and keep you up to date with service related news and changes to the system. We will let you know if you have the option to opt out of receiving communications.

  • Prevention and detection of crime, prevention of fraud and illegal sub-letting and quality management.

We do this to meet our legal obligations.


Special categories of personal data and Criminal Offence Data

House Exchange will not ask for any special category personal data about you or information relating to criminal offences. Special categories of personal data are: racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a person's sex life or sexual orientation.

On the rare occasions where this type of data is disclosed to us, House Exchange will process this:

  • With your consent
  • Where we need to protect the vital interests (i.e. the health and safety) of you or another person
  • Where you have already made your personal information public
  • Where we or another person needs to bring or defend legal claims and/or
  • Substantial public interest grounds

To process personal data about criminal convictions or offences, we must have both a lawful basis for the processing and either legal authority or official authority for the processing.

In the limited situations where we do process special category or criminal offence data, we would do this to ensure services are delivered appropriately. In the case of certain health information, this may be needed for health and safety purposes and / or social protection.

We will apply additional security and confidentiality measures when processing your special category data.

There may be times where we will not need your consent to process (including sharing) this type of data. This will apply where we are permitted or required to do so by law, for example under Health and Safety Legislation or where processing of this data is necessary in order for us to carry out our obligations under Social Protection Law.

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 partners, for example the local authority, our relationships are governed by our contracts with them which include strict data sharing and confidentiality protocols.

To help us ensure confidentiality of your personal information we may ask you (and any of your representatives) security questions to confirm your identity when you contact us and as may be necessary when we contact you. Unless the law permits or requires us to do so, we will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so or where we have received a clear verbal instruction from you (as a one-off circumstance).


Who will we share your information with?

In order for the House Exchange Service to work, certain information regarding you and your property needs to be made publicly available to other users of the site. We will make it very clear to you what information needs to be published in order for the system to work and what information you can choose to make public, for example the name you would like to appear on your account and the contact details you would like other users to use to get in touch. For guidance, we also use Google Maps to provide an approximate location of your property to other registered users of the site.

Sometimes we may need to share personal information we hold about you with other organisations that we work with such as your landlord or local authority. When sharing information we will comply with all aspects of data protection law.
If your landlord pays for the House Exchange Service, they (or an agent working on their behalf) will have access to your account in order to authorise the activation of your account. They will also be able to support you in your use of House Exchange.

Where ‘sharing’ is in our legitimate interests, we may share your information with:

  • Partner landlords or local authorities
  • Third parties providing services on our behalf. For example PayPal who take payments securely on our behalf

We are also legally permitted to share your information with organisations such as:

  • 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, health authorities, Homes England, the Greater London Authority (GLA), the National Housing Federation, 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.

House Exchange will not process your information outside of the EEA, however, as this is a website service, it is possible that you information would be available to a user who chooses to log onto this service outside of the EEA. We have taken 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 information and communicate with you about the House Exchange service. If you want to leave the House Exchange service at any time, you can let us know.

We will not use your data for unrelated marketing and House Exchange will never sell or share your personal data with 3rd party organisations for marketing purposes.


How long will you keep my data?

House Exchange 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.

At this current time, the set period of retention is 1 year after you close your account with House Exchange.


What are your rights in relation your data?

House Exchange is committed to upholding your rights in respect of your personal data.

The right to be informed

Through the provision of our privacy notice, 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).

The best way to do this is to put your request in writing or ask us for a copy of our template form. When a Subject Access Request is made, we will take reasonable steps to verify your identity before we can proceed so you may wish to submit a copy of your photo ID with your request to save time.

Where you are unable to put your request in writing, you can contact the Data Protection Team to arrange for your request to be documented on your behalf.

If you choose to make a verbal SAR request, please contact the House Exchange Team and request a call back from the Data Protection Team. We aim to contact you within 2 working days and will then send you a copy of the request to verify and attach ID before we start processing your request.

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 one 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

If you’d like to talk to us about your rights, you can contact us at dataprotection@clarionhg.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.


Website and Cookies

What cookies do we use?

Cookies are small text files that are sent by websites that you visit to recognise who you are when you return there. The files are stored on your computer’s hard drive, and are read by your web browser.

Cookies are used on this site to improve services for you through, for example:

  • enabling a service to recognise your device so you don't have to give the same information several times during one task
  • recognising that you may already have given a username and password so you don't need to do it for every web page requested
  • measuring how many people are using the site, so it can be made easier to use and there's enough capacity to ensure it is fast enough

We use Google Analytics to measure how many people use this site and how this is used. We do this to make sure the site is meeting users' needs and to understand how we could improve it.

The following cookies are used by Google Analytics:

  • _utma stores a randomly generated number for 2 years
  • _utmb stores a randomly generated number for 30 minutes
  • _utmc stores a randomly generated number until you close your browser
  • _utmz stores a randomly generated number and anonymous information on how the site was reached (e.g. direct or via a link or a search) for 6 months


The following cookie is used to provide other normal website functions:

  • asp.net_sessionid stores a randomly generated number until you close your browser

If you do not wish to accept any cookies on to your machine, you can disable them on your web browser or you are able to adjust the settings to allow only certain ‘trusted’ sites to store cookies on your computer. Please note that turning all cookies off may adversely affect the functionality of websites you visit.

For further information visit: www.allaboutcookies.org



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House Exchange is a joint initiative between Clarion Housing Group and 101Smart Ltd.

Clarion Housing Group Limited is a charitable registered society (Reg No 28038R). Registered with the Regulator for Social Housing (Reg No LH4087) VAT No (675 646 394). Registered office: Level 6, 6 More London Place, Tooley Street, London SE1 2DA.

101 Smart Ltd is a registered limited company in England (Reg No 5294196). Registered office: Unit 15 Beech Avenue, Taverham, Norfolk NR8 6HW.