THORNER’S HOMES – PRIVACY NOTICE

INTRODUCTION

Thorner’s Homes (“we“, “our” and “us“) is committed to protecting and respecting your privacy. This notice sets out how we collect, process, store and share your personal information, as well as your rights under the law.

To make this notice easier to read and understand, we have separated out the information into sections. Sections 3A through 3E only apply to certain categories of people, based on their relationship to us. The remaining sections in this notice (section 4 onwards) apply to everybody whose personal information we collect and process.

We suggest reading this privacy notice in the following order:

  • read sections 1, 2 and the start of section 3 below;
  • read only those of sections 3A through 3E which apply to you (please note that you may come within more than one category); and
  • read the rest of this notice from section 4 onwards.

If you have any difficulty understanding this notice or you would like to receive a printed copy, please contact our Data Protection Officer Vicky Joynes. Her contact details are set out in section 2 below.

  • DEFINED TERMS USED IN THIS NOTICE

References in this notice to “data protection law” mean (as applicable) the Data Protection Act 1998, the General Data Protection Regulation (Regulation (EU) 2016/679) and all related data protection legislation having effect in the United Kingdom from time to time (including the Data Protection Act 2018).

  • Our details

The data controller with conduct of your personal information is Thorner’s Homes, a registered Almshouse Charity (charity number 220735) of 86 Thorner’s Court, Henstead Road, Southampton SO15 2GU.

Our data protection officer is Vicky Joynes of Thorner’s Homes, 86 Thorner’s Court, Henstead Road, Southampton SO15 2GU.

  • How we COLLECT, use, RETAIN AND SHARE your information

The following sections explain what information we hold about you, why we are processing that information, the legal basis for the processing, the duration for which we keep your information and (if applicable) who your information will be shared with and where those recipients are based.

This information is divided into five sections depending on our relationship to you. Please read all sections which apply to you then continue reading this notice at section 4.

The sections are:

  • Section 3A – Applicants. This section applies to people who are applying to become a resident with us.
  • Section 3B – Residents. This section applies to our current residents.
  • Section 3C – Visitors. This section applies to visitors to our website as well as visitors to our premises. If you are visiting to supply us with goods or services then please read section 3D as well.
  • Section 3D – Suppliers, contractors and their employees and representatives. This section applies to our suppliers and contractors, as well as their employees and representatives.
  • Section 3E – All other people. This section applies to all other people who we process personal information about, including residents’ next of kin, legal attorneys, executors and independent referees.

 

SECTION 3A – APPLICANTS

What information do we process and for what purpose?

We process the following information about you:

Information you provide to us – This is information you give to us by filling in our resident application form, by speaking to us in person or over the phone, or by sending us letters, emails or communications through our website.

The information you provide to us as part of a resident application will typically include: your name, address, telephone number, email address, date of birth and age, nationality, national insurance number and married status. We will also enquire about your current housing situation and your financial circumstances. If you are employed then we may ask about your weekly worked hours and any plans you might have to retire. If you own a car then we may ask for your car registration number.

The information you provide to us will also typically include sensitive personal data, such as details of any health conditions you have, information about your general health and details of any disability benefits you are in receipt of. We also ask for you to confirm whether you have any recent criminal convictions.

We also collect the details of your chosen emergency contact; your next of kin and/or the executor of your estate; should you have one, your legal attorney under a Power of Attorney; and two independent referees.

We process the information you provide to us to:

  • process and make a decision on your residency application, including in particular to establish whether you are eligible to receive accommodation from us;
  • contact your doctor to confirm the health information you have provided insofar as we need to do so in order to confirm your eligibility to receive accommodation from us;
  • add you to the waiting list and to contact you when accommodation becomes available;
  • maintain suitable records of applications received and their outcomes; and
  • if your application is accepted, to make the necessary arrangements for you to become a resident at one of our properties.

Information received from other parties – This is usually information we receive from your doctor or other medical professionals concerning your health and wellbeing.

We process information about you received from third parties to make a decision on your residency application and, where appropriate, to keep an internal record of your specific requirements.

What are the grounds for processing your information?

We process your data on the following legal grounds:

  • in the case of most non-sensitive personal information contained in your residency application, because the processing is necessary for us to carry out pre-contractual steps (i.e. assessing your eligibility for us providing you with accommodation) at your request;
  • in the case of the remaining non-sensitive personal information contained in your residency application, because we have a legitimate interest in processing such information in order to ensure that you are eligible and suited for becoming a resident. In accordance with data protection law, we have carefully weighed your interests and fundamental rights and freedoms against our own interests in processing your information and we are satisfied that we are legally justified in doing so. In particular, we keep all your information strictly confidential within the charity, unless you agree to us sharing it with a third party;
  • in relation to criminal conviction data, because we are authorised under UK law, specifically the Data Protection Act 2018, to do so on the basis of your consent; and
  • in the case of sensitive personal information relating to your health, because:
  1. you have explicitly consented to us carrying out that processing;
  2. in limited circumstances the processing is necessary to protect your vital interests should you become physically or legally incapable of giving consent; or
  3. on rare occasions, the processing is necessary for us to establish, exercise or defend a legal claim and doing so is in our legitimate interest of ensuring only eligible residents are provided accommodation by us. In accordance with data protection law we have carefully weighed your interests and fundamental rights and freedoms against our interest to process your information and are satisfied that we are justified in processing your information for this purposes.

How long do we keep your information?

We only keep your information for so long as it is reasonably necessary. When setting our data retention periods, we consider the amount, nature, and sensitivity of the information we hold, the potential risk of harm from unauthorised use or disclosure of the information and the purposes for which we process the information (including whether we can achieve those purposes by other means). We also take into account our other legal obligations to keep or securely dispose of personal information.

Generally speaking, we retain your information for the following periods of time:

  • once you submit your application, we keep it and any supporting information on file until we have reviewed it and made a decision. The decision making progress may require you to attend one or more interviews with us;
  • if, once we have decided on your application, you are unsuccessful in obtaining a place with us, we will usually keep a record of your application for three months from notifying you of that fact. We do this so that we can answer any questions you might have; and
  • if, once we have decided on your application, you are successful in obtaining a place with us, we will continue to process your information as set out in section 3B (Residents) below. If you are placed on our waiting list then we will keep a copy of your details on file until accommodation becomes available for you, or you otherwise withdraw your application or your application is withdrawn for you (e.g. because you cease being eligible for accommodation with us).

Criminal conviction information will usually be confidentially destroyed or anonymised shortly after we make a decision about your application. If you become a resident with us then you will have the option to consent to us holding your health information on an ongoing basis. Very occasionally we may continue to process your health data beyond the application stage if we suspect your application is materially inaccurate or has been submitted in bad faith.

If we otherwise need to keep your information for a longer period then we will notify you of the reason and grounds for doing so.

Who is your information shared with?

Your personal information is not shared with anyone except where we are required to do so to comply with the law, to protect our rights, to efficiently operate our charity or you have otherwise consented to the sharing. In order to achieve these purposes, we will share your data with the following people or groups of people:

  • our trustees, on a need-to-know basis. Our trustees are subject to strict contractual obligations to keep your personal information confidential and secure and to comply with data protection law;
  • government and regulatory bodies, where we have a legal obligation to do so;
  • where you have consented for us to do so, your doctor or other medical professionals, who will have a strict professional duty to keep your personal information confidential;
  • our outsourced IT providers may have access to your personal data on our IT systems if such access is required to enable them to resolve problems with our systems. Typically, your personal information will be encrypted before it is transferred to our hosts but in certain circumstances they may require access to unencrypted data. Our IT providers are subject to strict contractual obligations to treat your personal information with the utmost sensitivity, to keep it confidential and to comply with data protection law at all times;
  • the third party who referred you to us; and
  • our legal advisers or other professional advisers, if necessary to defend claims, protect our rights, or receive advice on compliance with the law. Such transfers will be protected by confidentiality obligations owed by our advisers.

To the best of our knowledge, understanding and belief, your information will not be transferred outside of the European Economic Area or to any country which is not approved by the European Commission. If this changes then we will let you know.

 

SECTION 3B – RESIDENTS

This section applies to our residents.

Which information do we process and for what purpose?

We process the following information from you:

Information you give us. This is information you provide us in writing by post or by email, by telephone or in person.

The information we hold about you will typically include: your name, address, telephone number, email address, date of birth and age, nationality, national insurance number and marital status. We will also hold information about your previous housing situation and your financial circumstances. If you are employed then we may hold details about your weekly worked hours and any plans you might have to retire. If you own a car then we may require your car registration number.

We operate CCTV cameras at our premises for the safety of residents and staff. You will invariably feature in the recorded footage.

The information you provide to us will also typically include sensitive personal data, such as details of any health conditions you wish for us to know about when deciding on your application, information about your general health and details of any disability benefits are in receipt of. Occasionally, we may also process criminal conviction information about you but this is rare.

Information we receive from third parties. In certain circumstances your doctor or other medical professionals will provide us with medical information about you.

We process your information for the following purposes:

  • to provide you with independent living accommodation at one of our properties. This includes arranging maintenance services for the common areas of the buildings and for your accommodation;
  • as required, to contact your doctor or social services to ensure you are receiving adequate medical support and to assess your ongoing eligibility for accommodation with us;
  • where applicable, to assist you in obtaining a valid television licence and CAREline support service by forwarding on your application forms;
  • for CCTV footage, to prevent crime, to safeguard our residents and staff, to ensure the safety of visitors in the event of an emergency, as well as to protect our position in the event of a dispute arising;
  • in relation to your car registration number, to monitor and manage usage of our car parks;
  • to comply with our legal and regulatory obligations; and
  • to administer any dispute which may arise between us or between our residents. This includes on the occasion where we need to process sensitive personal information as part of a legal claim, such as to regain possession of your accommodation should you cease to be eligible to stay with us.

What are the grounds for processing your information?

We process your personal information on the following grounds:

  • the processing is necessary for the performance of the contract between us and you for the provision of accommodation, including taking pre-contractual steps at your request prior to entering into that contract;
  • where applicable, because you have consented to us sharing your information with the Southampton City Council City Telecare team and/or the TV Licensing Authority;
  • where we retain a copy of your TV Licence application, because retaining a record of the same is necessary for the TV licensing arrangement, being a contractual agreement to which you are party;
  • in relation to your non-sensitive personal data, because we have a legitimate interest in:
  • (i) maintaining a CCTV system for the prevention of crime, to safeguard our residents and staff, to ensure the safety of visitors in the event of an emergency, as well as to protect our position in the event of a dispute arising;
  • (ii) maintaining appropriate records within the charity for administrative reasons; and
  • (iii) otherwise ensuring the safe and efficient operation of the charity and the provision of accommodation to our residents, including addressing any complaints received from you or from other residents which may concern you;

and in accordance with data protection law we have carefully weighed your interests and fundamental rights and freedoms against our interest to process your information and are satisfied that we are justified in processing your information for this purposes; and

  • in the case of sensitive personal information relating to your health, because:
  • (i) from time to time you have explicitly consented to the processing;
  • (ii) in limited circumstances the processing is necessary to protect your vital interests should you become physically or legally incapable of giving consent;
  • (iii) because the processing is necessary for reasons of substantial public interest on the basis of UK law; or
  • (iv) in limited circumstances, the processing is necessary for us to establish, exercise or defend a legal claim and doing so is in our legitimate interest of ensuring only eligible residents are provided accommodation by us. In accordance with data protection law we have carefully weighed your interests and fundamental rights and freedoms against our interest to process your information and are satisfied that we are justified in processing your information for this purposes; and
  • in relation to criminal conviction data, because we are authorised under UK law, specifically the Data Protection Act 2018, to do so on the basis of your consent.

How long do we keep your information?

We only keep your information for so long as it is reasonably necessary. When setting our data retention periods, we consider the amount, nature, and sensitivity of the information we hold, the potential risk of harm from unauthorised use or disclosure of the information and the purposes for which we process the information (including whether we can achieve those purposes by other means). We also take into account our other legal obligations to keep or securely dispose of personal information.

Generally speaking, we retain your information for 12 months after you cease being a resident of ours (for whatever reason).

Where you feature on our CCTV records, your information is kept for 6 months from the date of the recording, unless we need to keep the recording for longer, such as in the event of a dispute or other occurrence requiring us to preserve the footage.

If we need to keep your information for a longer period then we will notify you of the reason and grounds for doing so. This may be the case where there is a legal dispute between us.

Who is your information shared with?

Your personal information is not shared with anyone except where we are required to do so to comply with the law, to protect our rights, to efficiently operate our charity or you have otherwise consented to the sharing. In order to achieve these purposes, we will share your data with the following people or groups of people:

  • our trustees, on a need-to-know basis. Our trustees are subject to strict contractual obligations to keep your personal information confidential and secure and to comply with data protection law;
  • government and regulatory bodies, where we have a legal obligation to do so;
  • where relevant, your doctor/other medical professional, your care worker and/or social services;
  • where you have applied for a television licence through our accommodation for residential care (ARC) scheme, we share the information provided on your application form with the TV licensing authority so that it can process and approve the application;
  • where you have consented for us to do so, your doctor or other medical professionals for the purpose of confirming your medical information, who will have a strict professional duty to keep your personal information confidential;
  • where you have consented for us to do so as part of your CAREline scheme application, we will send your application form to the Southampton City Council City Telecare team on your behalf so that they can process your application and begin offering you the requested service;
  • should we need to carry out work on your accommodation, we may need to share a limited amount of personal information about you with the contractors we use to carry out that work. This is done to ensure that the work minimally impacts you;
  • our outsourced IT providers may have access to your personal data on our IT systems if such access is required to enable them to resolve problems with our systems. Typically, your personal information will be encrypted before it is transferred to our hosts but in certain circumstances they may require access to unencrypted data. Our IT providers are subject to strict contractual obligations to treat your personal information with the utmost sensitivity, to keep it confidential and to comply with data protection law at all times; and
  • our legal advisers or other professional advisers, to protect our rights, defend claims or to provide advice on compliance with the law. Such transfers will be protected by confidentiality obligations owed by our advisers.

To the best of our knowledge, understanding and belief, your information will not be transferred outside of the European Economic Area or to any country which is not approved by the European Commission. If this changes then we will let you know.

 

3C – VISITORS

This section applies to (as relevant) visitors to our website and people who visit our premises. This includes if you stay in the guest accommodation at one of our properties.

Which information do we process and for what purpose?

We process the following information from you:

Information you give us. For website visitors, this is information you provide us by using the contact page on our website. For visitors to our premises, this can include your name, contact details and car registration number.

Information we receive from third parties. This is typically where a resident informs us that you are staying with them or in our visitor accommodation. In such a case we typically receive your name, contact details and car registration number.

Information we collect about you. When you visit our website we collect non-personally identifying information of the sort that web browsers and servers typically make available. This includes technical information, such as your IP address and information about your visit, such as records of how you navigate the pages on our website and how you interact with the pages.

We operate CCTV on our premises so when you visit we will also process images and videos which feature you.

We process information your information for the following purposes:

  • when you use the contact form on our website, to make a record of and respond to your enquiry;
  • for non-personally identifying website usage information, to ensure that content from our website is presented in the most effective manner for you and for your device. For more information on how our website uses cookies, please refer to section 6 below;
  • for CCTV images and videos and records of visitors, to prevent crime, to safeguard our residents and staff, to ensure your safety in the event of an emergency, as well as to protect our position in the event of a dispute arising;
  • where you are a visitor making use of our guest accommodation, to allow us to provide that service to you; and
  • to otherwise facilitate and manage your visit.

What are the grounds for processing your information?

We process your personal information on the basis that we have a legitimate interest in:

  • processing your information in order for us to respond to your website enquiry;
  • maintaining CCTV coverage and visitor logs for the prevention of crime, to safeguard our residents and staff, to ensure your safety in the event of an emergency (such as a fire) and to protect our position in the event of a dispute arising;
  • being able to provide our guest accommodation for the benefit of our residents and our guests; and
  • maintaining the safe and effective operation of our charity,

and in accordance with data protection law we have carefully weighed your interests and fundamental rights and freedoms against our interest to process your information and are satisfied that we are justified in processing your information for this purposes.

How long do we keep your information?

We only keep your information for so long as it is reasonably necessary. When setting our data retention periods, we consider the amount, nature, and sensitivity of the information we hold, the potential risk of harm from unauthorised use or disclosure of the information and the purposes for which we process the information (including whether we can achieve those purposes by other means). We also take into account our other legal obligations to keep or securely dispose of personal information.

Generally speaking, we retain your information for the following periods of time:

  • if you make an enquiry through our website – 6 months from the resolution of that enquiry. If you proceeded to submit a residency application to us then a longer retention period would apply – please see Section 3A (Applicants) above for more information;
  • where you feature on our CCTV records – 6 months from the date of the recording, unless we need to keep the recording for longer, such as in the event of a dispute or other occurrence requiring us to preserve the footage;
  • where you complete our visitor’s log – 6 months from date of your visit; and
  • should you stay in our visitor’s accommodation – 3 months from the end of your stay (except for payment receipts which we keep for 7 years, in line with our accounting requirements).

If we need to keep your information for a longer period then we will notify you of the reason and grounds for doing so.

Who is your information shared with?

Your personal information is not shared with anyone except where we are required to do so to comply with the law, to protect our rights, or to efficiently operate our charity. In order to achieve these purposes, we will share your data with the following people or groups of people:

  • our trustees, on a need-to-know basis. Our trustees are subject to strict contractual obligations to keep your personal information confidential and secure and to comply with data protection law;
  • government and regulatory bodies, where we have a legal obligation to do so;
  • our outsourced IT providers may have access to your personal data on our IT systems if such access is required to enable them to resolve problems with our systems. Typically, your personal information will be encrypted before it is transferred to our hosts but in certain circumstances they may require access to unencrypted data. Our IT providers are subject to strict contractual obligations to treat your personal information with the utmost sensitivity, to keep it confidential and to comply with data protection law at all times; and
  • our legal advisers or other professional advisers, to protect our rights, defend claims or to provide advice on compliance with the law. Such transfers will be protected by confidentiality obligations owed by our advisers.

To the best of our knowledge, understanding and belief, your information will not be transferred outside of the European Economic Area or to any country which is not approved by the European Commission. If this changes then we will let you know.

 

3D – SUPPLIERS, CONTRACTORS AND THEIR EMPLOYEES AND REPRESENTATIVES

This section applies to suppliers, contractors and their employees and representatives. If you also visit our website or visit our premises then please also read Section 3C (Visitors), above.

Which information do we process and for what purpose?

We process the following information from you:

Information you give us. This is information you provide us by post, email, telephone or in person. It also includes information you send us through our website.

The information you give us may include your name, address, email address, phone number, job title and details of your employer. In certain circumstances, such as where you are a sole trader or partner in a legal partnership, you may be personally identifiable from the payment information you provide us.

Information we receive from third parties. This includes where you are an employee or representative of a supplier or contractor and we are passed your details by another person within your organisation. This may also be the case where you are a sole trader or partner in a legal partnership and we are passed your details by an employee of yours or from another partner in your business.

The types of information we would receive in this way are the same as if you provided them to us directly, as set out above.

We process information you give to us and which we receive from third parties for the following purposes:

  • to perform the contract entered into between you (or your organisation) and us, including taking pre-contractual steps;
  • to administer our account with you, including processing your requests for payment;
  • to administer any dispute which may arise between us; and
  • to keep proper administrative records.

What are the grounds for processing your information?

We process your data on the following legal grounds:

  • where you are a supplier or contractor of ours, the processing is necessary for the performance of the contract between you and us, including the taking of pre-contractual steps at your request;
  • if you are an employee or representative of a contractor or supplier of ours, because we have a legitimate business interest in processing your information in order to perform the contract between us and your organisation, including taking pre-contractual steps. In accordance with data protection law we have carefully weighed your interests and fundamental rights and freedoms against our interest to process your information in this way and are satisfied that we are justified in doing so;
  • in certain circumstances, because the processing is necessary for us to comply with our legal or regulatory obligations; and
  • depending on the circumstances, the processing is necessary for achieving our legitimate interests of:
  • (i) responding to an enquiry we may have received from you; or
  • (ii) in the event of a dispute arising between us or there being the potential for a dispute between us, administering that dispute,

and in accordance with data protection law we have carefully weighed your interests and fundamental rights and freedoms against our interest to process your information and are satisfied that we are justified in processing your information for this purposes.

How long do we keep your information?

We only keep your information for so long as it is reasonably necessary. When setting our data retention periods, we consider the amount, nature, and sensitivity of the information we hold, the potential risk of harm from unauthorised use or disclosure of the information and the purposes for which we process the information (including whether we can achieve those purposes by other means). We also take into account our other legal obligations to keep or securely dispose of personal information.

Generally speaking, we retain your information for the following periods of time:

  • supplier and contractor information (including contact details of employees and representatives) where we enter into a contract – seven years from the date of termination of our contract; and
  • supplier and contractor information (including contact details of employees and representatives) where a contract is not entered into between us – one year from the last communication between us concerning that matter.

If we need to keep your information for a longer period then we will notify you of the reason and grounds for doing so.

Who is your information shared with?

Your personal information is not shared with anyone except where we are required to do so to comply with the law, to protect our rights, or to efficiently operate our charity. In order to achieve these purposes, we will share your data with the following people or groups of people:

  • our trustees, on a need-to-know basis. Our trustees are subject to strict contractual obligations to keep your personal information confidential and secure and to comply with data protection law;
  • government and regulatory bodies, where we have a legal obligation to do so;
  • our outsourced IT providers may have access to your personal data on our IT systems if such access is required to enable them to resolve problems with our systems. Typically, your personal information will be encrypted before it is transferred to our hosts but in certain circumstances they may require access to unencrypted data. Our IT providers are subject to strict contractual obligations to treat your personal information with the utmost sensitivity, to keep it confidential and to comply with data protection law at all times; and
  • our legal advisers or other professional advisers, to protect our rights, defend claims or to provide advice on compliance with the law. Such transfers will be protected by confidentiality obligations owed by our advisers.

To the best of our knowledge, understanding and belief, your information will not be transferred outside of the European Economic Area or to any country which is not approved by the European Commission. If this changes then we will let you know.

 

3D – ALL OTHER PEOPLE

Which information do we process and for what purpose?

Our residents will sometimes provide us with details of:

  • their guests;
  • their chosen emergency contact;
  • their next of kin
  • the executor of their estate;
  • their legal attorney under a Power of Attorney; and/or
  • when making a residency application, independent referees.

If you fall within one of these categories then we will typically process your name, relationship to the resident (or applicant) and your contact details.

We may also on occasion process personal information relating to people who fall outside of the above categories. That information would typically comprise the person’s name, contact information and relationship to the resident.

We process this information in order to provide our services to residents and to provide assistance to our residents’ families and estates.

What are the grounds for processing your information?

Our processing is justified on the legal basis that we have a legitimate interest in processing the information in order to safeguard the wellbeing of our residents, ensure the efficient running of our charity and to provide assistance to the resident’s estate or legal attorney in the event of their death or incapacity. In accordance with data protection law we have carefully weighed your interests and fundamental rights and freedoms against our interest to process your information in this way and are satisfied that we are justified in doing so.

How long do we keep your information?

In most cases, your information will be kept until the earliest of:

  • the resident ceasing to receive accommodation with us;
  • the resident (or you) notifying us that you are no longer acting in the stated capacity; and
  • us assisting the family or estate of the resident following their death.

In the case of references for applicants (including housing and personal referees) we keep your information until references have been confirmed, asked any queries on the reference provided and a decision made.

In all other cases, we keep your information for so long as it is needed for the reason we originally collected it. After which point it will be securely destroyed.

Who is your information shared with?

Your personal information is not shared with anyone except where we are required to do so to comply with the law, to protect our rights, or to efficiently operate our charity. In order to achieve these purposes, we will share your data with the following people or groups of people:

  • our trustees, on a need-to-know basis. Our trustees are subject to strict contractual obligations to keep your personal information confidential and secure and to comply with data protection law;
  • government and regulatory bodies, where we have a legal obligation to do so;
  • our outsourced IT providers may have access to your personal data on our IT systems if such access is required to enable them to resolve problems with our systems. Typically, your personal information will be encrypted before it is transferred to our hosts but in certain circumstances they may require access to unencrypted data. Our IT providers are subject to strict contractual obligations to treat your personal information with the utmost sensitivity, to keep it confidential and to comply with data protection law at all times; and
  • our legal advisers or other professional advisers, to protect our rights, defend claims or to provide advice on compliance with the law. Such transfers will be protected by confidentiality obligations owed by our advisers.

To the best of our knowledge, understanding and belief, your information will not be transferred outside of the European Economic Area or to any country which is not approved by the European Commission. If this changes then we will let you know.

  • Automated decision making

We do not make automated decisions about you based on your information. Should this change in the future then we will let you know.

  • Your rights
    • Under data protection law you have the following rights:
      • if we are processing your data on the basis of your consent then you have the right to withdraw that consent at any time. Consent can be withdrawn by contacting us using the details set out in section 11 If you choose to withdraw your consent then please note that:
        • the lawfulness of our historic processing based on your consent will not be retrospectively affected by your withdrawal of consent; and
        • in certain circumstances, your consent to processing is necessary for us to provide accommodation to our residents. Accordingly, if you are an applicant and you withdraw consent to us processing your personal information then we will be unable to process your application. Similarly, if you are a resident then we may be unable to continue providing you with accommodation if you no longer consent to us processing certain personal information which is necessary for us to establish your ongoing eligibility to receive accommodation from us. If this is the case then we will let you know at the time you raise this with us;
      • the right to access a copy of your information which we hold. This is called a ‘subject access request’. Additional details on how to exercise this right are set out in section 7, below;
      • the right to prevent us processing your information for direct marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us using the details set out in section 11, below;
      • the right to object to decisions being made about you by automated means. We do not currently use automated decision making but we will let you know if this changes in the future;
      • the right to object to us processing your personal information in certain other situations;
      • the right, in certain circumstances, to have your information rectified, blocked, erased or destroyed if it is inaccurate;
      • the right, in certain circumstances, to claim compensation for damages caused by us breaching data protection law;
      • the right, in certain circumstances, to request that we erase, rectify, cease processing and/or delete your information; and
      • in certain circumstances, the right to request the information we hold on you in a machine readable format so that you can transfer it to other services. This right is called ‘data portability’. Additional details on how to exercise this right are set out in section 7, below.
    • You also have the general right to complain to us (in the first instance) and to the Information Commissioner’s Office (if you are not satisfied by our response) if you have any concerns about how we hold and process your information. Our contact details are set out in section 11, below. The Information Commissioner’s Office website is ico.org.uk.
    • For further information on your rights under data protection law and how to exercise them, you can contact Citizens Advice Bureau (citizensadvice.org.uk) or the Information Commissioner’s Office (www.ico.org.uk).
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    • Visitors to our site who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using our site. This will mean that some features of our site may not function properly without the aid of cookies.
  • ACCESS TO INFORMATION
    • Under data protection law you can exercise your right of access by making a written request to receive copies of some of the information we hold on you. You must send us proof of your identity, or proof of authority if making the request on behalf of someone else, before we can supply the information to you. Requests should be sent to us using the contact details in section 8 below.
    • You do not need to pay a fee to exercise this right unless you are requesting copies of documents you already possess, in which case we may charge our reasonable administrative costs. We are, however, allowed to charge you for our reasonable administrative costs in collating and providing you with details of the requested information which we hold about you if your request is clearly unfounded or excessive. In very limited circumstances, we are also entitled to refuse to comply with your request if it is particularly onerous.
    • In certain circumstances, you are entitled to receive the information in a structured, commonly used and machine readable form.
  • Third party websites

Our site may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these sites have their own privacy notices and that we do not accept any responsibility or liability for those notices. Please check their privacy notices before you submit any personal data to those websites.

  • Data security

We will always store your digital information on secure servers. Unfortunately, however, the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your information transmitted to our site or otherwise to our servers (such as by email). Any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

  • Changes to our privacy Notice

This notice was last updated on 25th May 2018. Any material changes we may make to our privacy notice in the future will be uploaded to our website and if the change is significant we will send you the updated notice by email. Please check back frequently to see any updates or changes to our privacy notice.

  • Contact

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to Vicky Joynes, Thorner’s Homes, 86 Thorner’s Court, Henstead Road, Southampton SO15 2GU or enquiries@thorners.org.uk.