1. Purpose of our privacy statement
1.1 Under the Data Protection Act 1998 and the General Data Protection Regulation, we are required to explain to you why we are asking for this information about you, how we intend to use the information you provide and whether we will share this with anyone else.
2. Who are we?
2.1 We are of Sanctuary Group (“Sanctuary”) one of the UK's leading providers of housing, care and commercial services. Our address is Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ.
3. Our data protection officer
3.1 Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
3.2 If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing firstname.lastname@example.org.
4. Why are we collecting your information?
4.1 The information that you provide to us or to one of our representatives completely voluntary. Our aim is that by further understanding your individual needs, we will be able to provide an improved customer service.
5. What information are we collecting?
5.1 The only information which we are collecting about you is the information which you provide to us during the course of your sales query.
5.2 It is possible that some of the information which we collect will be special categories of personal data (also called sensitive personal data), which could include information about your health.
6. What we are going to do with your information
6.1 The information you provide to us will be used for the following purposes:
6.1.1 It will be stored and used by us in accordance with this privacy statement and also in accordance with your rights under the Data Protection Act 1998 and the General Data Protection Regulation;
6.1.2 It will be collected and used by us fairly and openly for the purpose of providing marketing information about our products and services and informing you about how our services could meet your individual needs. It may also be used for market intelligence and customer research purposes;
6.1.3 It will allow us to provide information on products and services which are tailored to your needs;
6.1.4 It will allow us to make contact with you in the most appropriate way. For example, we can provide literature in large print if you have difficulty reading smaller print; or provide documents in an alternative language if English is not your first language.
6.2 An understanding of your personal situation and individual needs will allow us to provide a tailored service that meets any physical, cultural or financial needs that you may have.
6.3 Some of the information which we collect could relate to special categories of personal data (also called sensitive personal data), such as information about your ethnic background or any disability you may have. You need to be aware that we will use this information in order to ensure we deliver services in an appropriate manner. By providing us with this information, you consent to our use of this information for this purpose.
7. What is the legal basis for using your information?
7.1 In accordance with the data protection laws, we need a "legal basis" for collecting and using information about you. There are a variety of different legal basis for processing personal data which are set out in the data protection laws.
7.2 The lawful basis on which we rely in order to use the information which we collect about you for the purposes set out in this notice will be:
7.2.1 You have provided consent to our use of your information;
7.2.2 The lawful basis on which we rely in order to use your special categories of personal data which we collect about you will be that you have provided your explicit consent to our use of your information.
8. Sharing your information
Members of Sanctuary Group
8.1 Sanctuary is made up of a number of related companies. We will share your information with other members of Sanctuary where necessary in order to best provide the services to you in accordance with any subsequent contract between us.
8.2 Your information will only be accessed by other companies in Sanctuary where it is necessary to do so in order to provide services to you, in accordance with this privacy statement. The obligations which are set out in this notice shall apply to the other members of Sanctuary to the same extent that they apply to us.
8.3 For more information on which companies make up Sanctuary, please go to www.sanctuary-group.co.uk/about-us.
Contractors and sub-contractors
8.4 It may be necessary to share information about you with our contractors and sub-contractors, such as sales agents, in order to provide you with the services in accordance with the contract between us.We will only share information about you with the contractors and sub-contractors which is relevant and necessary to address your individual needs. The contractors and sub-contractors shall be contractually required to ensure that they adhere to the security requirements imposed by the Data Protection Act 1998 and / or the General Data Protection Regulation (as applicable).
8.5 Our contractors and sub-contractors will not share your information with any other parties and will only be able to use the information when completing work on behalf of us.
Regulators and other legal obligations
8.6 We may also be required to share your information with our regulators who are permitted access to this information by law and with other organisations where we have a legal obligation to share the information with them.
8.7 We may from time to time share your information with other organisations, such as:
8.7.1 the police for the purpose of detection and prevention of crime;
8.7.2 organisations with a function of auditing and / or administering public funds for the purpose of detection and prevention of fraud;
8.7.3 Homes England/Greater London Authority/Scottish Government as part of our auditing requirements and contractual obligations;
8.7.4 Agents who are managing sales processes on our behalf.
9. Transferring your information abroad
9.1 We intend to transfer the information which you provide to us to the United States of America. We are transferring that information to the USA because our e-marketing software provider is located in that country.
9.2 We are transferring your information to Campaign Monitor for the purpose of sending e-marketing and communication emails to you.
9.3 The European Commission has made an adequacy decision in relation to the USA. This means that the Commission has determined that the data protection laws of the USA adequately protect your personal information. As a result, we are not required to obtain specific authorisation to transfer your information to the USA. You can find details of the adequacy decision on the Commission's website: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
10. Security of your information
10.1 The information that you provide will be stored securely on our systems and any hard copies of the form that you complete will be stored securely before being shredded at the appropriate time. Our security measures and procedures reflect the seriousness with which we approach security and the value we attach to your information.
10.2 Only relevant members of staff will access the information you provide to us.
11. Can we use your information for any other purpose?
11.1 In limited circumstances we may use your information for a purpose other than those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.
12. Storing your information and deleting it
12.1 We will store the personal data which you provide to us for as long as we have products or services that match the site or location you have enquired about.Once we no longer have relevant products that match the interest you expressed, we will review the information which we hold concerning you and determine whether there are any reasons why we need to continue holding that information (for example, if a similar development is due to be marketed in the location in the near future). Once the identified purpose comes to an end, unless there is another identifiable purpose for which it is necessary to hold on to your information, we will delete your information.
13. Your rights
13.1 In relation to the information which we hold about you, you are entitled to:
13.1.1 Ask us for access to the information;
13.1.2 Ask us to rectify the information where it is inaccurate or is incomplete;
13.1.3 Ask us to erase the information and take steps to ask others who we have shared your information with to also erase it;
13.1.4 Ask us to limit what we do with your information;
13.1.5 Object to our use of your information and ask us to stop that use;
13.1.6 Instruct us to provide you with the information we hold about you in a structured and commonly used format or transmit that information directly to another organisation (for example, if you want the information to be sent to another housing provider).
13.2 Our obligations to comply with the above rights are subject to certain exemptions.
13.3 Where we are using your information because you have provided your consent to that use, you are entitled to withdraw your consent at any time. The lawfulness of our use of your information before consent was withdrawn is not affected.
13.4 To exercise any of the rights referred to above, you should contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing email@example.com.
13.5 You also have the right to complain to the Information Commissioner's Office (the "ICO") if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.