‘Personal data’ is any information that relates to a living, identifiable person. This will usually include your name, address, contact details, and other information we collect as part of our relationship with you.
It can also include ‘special categories’ of data, which is the official term for information about a person’s race or ethnic origin, religious, political or other beliefs, physical or mental health, trade union membership, genetic or biometric data, sex life or sexual orientation.
The use of this type of data, and of information about criminal convictions and offences, is subject to strict legal controls.
We only process data if we need to for a specific purpose, as explained below. Most often, we collect your personal directly from you, through our contact with you.
Your personal data is held in both hard copy and electronic formats.
Electronic data, including emails, is stored on Community Impact Partnership's servers and on our software suppliers’ servers, which are located in the European Union.
Where we contract with a software supplier who stores data outside of the EU, only minimal data is processed, for example for carrying out feedback surveys, and we ensure appropriate safeguards are in place.
- To be informed about how your data is handled;
- To gain access to your personal data;
- To have errors or inaccuracies in your data changed;
- To have your personal data erased, in limited circumstances;
- To object to the processing of your personal data for marketing purposes or when the processing is based
- on the public interest or other legitimate interests;
- To restrict the processing of your personal data, in limited circumstances;
- To obtain a copy of some of your data in a commonly used electronic form, in limited circumstances;
- Rights around how you are affected by any profiling or automated decisions.
Legal basis for Processing
ApplicationsWhen you apply to live in, or buy, an Orbit home, we collect information directly from you and from relevant third parties, in order to assess your eligibility and suitability for the application you have made. For rented customers we receive your contact details and housing need information from the Local Authority if you have been nominated by them and we take up references from former landlords. Some decisions are made automatically about your eligibility, based on the answers you provide in your application, but you will always be given the opportunity to challenge the decision.
|This processing is necessary for entering into a contract with us, including a tenancy agreement or a purchase contract. We need to know that you are eligible, and that you can afford a property, and/or sustain your tenancy, and we may need to offer you additional support as part of your tenancy.|
CORE reportingSo that the Ministry of Housing, Communities and Local Government (MHCLG) can produce statistical information, we report information about our lettings and shared ownership sales via the CORE (Continuous Recording) system. The information provided does not include your name or full address, but it does contain special categories of data. Please see the CORE website for more details.
|The processing of this information by the MHCLG is necessary for the performance of a task in the public interest, and so far as the data includes special categories, the MHCLG states that the processing is necessary for reasons of substantial public interest.|
Orbit customersWhen you are an Orbit customer, we will collect information from our interactions with you, including any complaints or allegations that are made by you, or about you, and we process this information to allow us to manage our relationship with you, collect your rent, and provide you with tenancy or sales related services, and appropriate support services, and to manage any complaints or alleged ASB or similar issues. This will involve sharing information with, and receiving information from, third parties: Where crimes have been committed or alleged information is shared with the police and other agencies with investigative and prosecution powers; We will share rent information with local authorities for the purposes of administration of benefits; Where local authorities require information for council tax, we will confirm tenancy information to allow the correct tax to be paid. We will also share information with debt collection agencies so they can collect debts on Orbit’s behalf.
|Most of the information we collect and use as part of our ongoing interactions with you is necessary for the performance of your contract, and is linked to ensuring both you and Orbit are complying with the requirements of the contract. We have a legal obligation to keep business and financial transaction records as appropriate. We will offer you further support based on our legitimate interests to enable you to sustain your relationship (tenancy/shared ownership relationship) with us to the best of your ability. If we contact you by email or text to let you know about our offer, we will do so based on your consent to that use of your email or text contact details. If we refer you to an external agency for further support, we will do so only with your consent to pass your details onto them. When we share information for the reasons explained, we will do so on the basis of the fact it is necessary for a task in the public interest (crime, benefits and tax payment) or for our legitimate interests of debt collection.|
InsuranceIf you are an Orbit insurance customer, we will process your information so we can provide you with a policy, and to manage any claims you make, which may involve sharing information with third parties about the circumstances in order to assess the claims.
|This processing is necessary for the performance of your insurance contract. If it suspected that a claim is not legitimate, we will process information on the basis that it is necessary for us to protect our business from fraudulent claims, which is in our legitimate interests.|
Help to BuyOrbit manages the Help to Buy Midlands service, on behalf of Homes England, Please see the Help to Buy Midlands website for more details.
|Most of this processing is on the basis that it is necessary for a contract, or entering into a contract, for shared ownership or an equity loan.|
ContactsFor members of the public who are not customers but come into contact with Orbit in another way, such as to make an enquiry, complaint or allegation, we will collect information from our interactions with you, so that we can provide you with the information you have requested, or so we can investigate and handle any complaints or allegations.
|We process this information on the basis that it is necessary for our legitimate interests of responding to your enquiry, complaint or allegation, as appropriate.|
|Most of this processing is on the basis that it is necessary for an employment contract, or entering into an employment contract, with Orbit.|
EmployeesWe collect and process information about current and former employees as part of managing your relationship with Orbit.
|Most of this processing is on the basis that it is necessary for managing your employment contract with Orbit.|
CCTVOrbit uses CCTV in its offices and in some of our housing/schemes for the safety and security of premises, colleagues, customers and any third parties. CCTV footage can be disclosed to those organisations acting on official authority, including the police.
|We process data from CCTV for the purposes of our legitimate interest of protecting our premises and people.|
Telephone callsPhone calls to our main telephone number are recorded, so that we can monitor the quality and content of calls.
|This processing is on the basis of our legitimate interest of providing good customer service, as well as protecting our colleagues and other people from any problems arising from ambiguity in phone call conversations.|
ContractorsWe work with external contractors who provide our customers with housing related services, for example repairs or asset maintenance, and we will share your contact details with these contractors so they can contact you to arrange appointments to provide the services. Orbit’s suppliers of computer systems have access, which is controlled, to the data held on the systems, only as part of providing us with support.
|We share information in the ways explained based on our legitimate interests of outsourcing the provision of some services and of providing appropriate computer systems, to enable us to run the business efficiently.|
Work contactsPeople we work with – organisations and companies – your contact details are personal data and we will treat it accordingly, using it only as part of our relationship with your organisation, whether we work in partnership or have a customer/supplier relationship.
|This processing is based on our legitimate interests of managing business relationships appropriately.|
Surveys and feedbackIn order to understand our customers’ experiences and improve our services and products, we will contact you at various “touch-points” during our relationship with you, and ask you to complete a survey and give us feedback, over email or text or over the telephone. We contract with specialist companies to carry out surveys on behalf of Orbit, which involves sending them your contact details and they gather your responses for us. You can opt out of this sort of contact if you prefer.
|Orbit, and the specialist companies we work with, process data in order to ask for your feedback, based on our legitimate interests of improving our customer services and products.|
MarketingWe will send you information that we think will be useful or of interest to you, about the services we provide, whether they are paid for services or free of charge. We will make decisions about what information so send based on your profile, for example your age if we are letting people know about age-related services like our over 55s schemes.
|Orbit will send you hard copy marketing materials on the basis of our legitimate interests of increasing our customers’ knowledge of other relevant services and products. We will only send you emails or texts (electronic direct marketing) with this type of information if we have your consent to do so. For commercial services or products, this includes where you have bought, or entered into negotiations with us, for a similar service or product. Every time we send an email or text you will have the option to unsubscribe from similar marketing messages.|
|This information is processed for our legitimate interests of responding to any enquiries you make through the website, and of understanding the effectiveness of our website.|