Privacy Statement – Tenancy Agreements and Living with Us

PURPOSE OF OUR PRIVACY STATEMENT


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.


WHO ARE WE?


We are Homes for Students, one of the UK’s leading providers of student accommodation. Homes for Students is part of the ANUK national code, which demonstrates our commitment to providing good quality housing for students. Homes for Students is a registered business ‘Company Registration Number 9840367’ and its Head Office address is The Innovation Centre, Hornbeam Park, Hookstone Road, Harrogate, North Yorkshire, HG2 8QT. Prestige Student Living, EVO Student, Urban Student Life, Essential Student Living, Universal Student Living, NOW and Urba Life are brands of Homes for Students.


DATA PROTECTION OFFICER


Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance in line with the data protection regulations.


If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer in writing: The Data Protection Officer, Homes for Students, The Clock Tower Park, Longmoor Lane, Fazakerley, Liverpool L10 1LD or by emailing dataprotection@wearehomesforstudents.com.


WHY ARE WE COLLECTING YOUR INFORMATION?


The information that you provide to us during routine enquiry channels such as via our website, during a telephone call, during the registration or application process or in person is required by Homes for Students in order for us to provide you with the requested service and an offer of accommodation.


This information is specifically about you and without this information, we will not be able to provide you with a service or enter into a contract with you.


WHAT INFORMATION ARE WE COLLECTING?


The only information which we are collecting is the information which you provide to us via our booking system, online portal, on forms, in person or during any enquiry.


The information we collect may include, for example:



  • Name, Address, email address and further contact details

  • Date of Birth, Gender, Year of Study, University/College course details

  • Nationality, Next of Kin details, Guarantor details (if applicable)

  • ID documents

  • Financial Information, such as bank details to enable payment of rent

  • CCTV monitoring


Some of the information which we collect will be special categories of personal data (also called sensitive personal data), which includes information about your health, ethnicity and sexuality.


This information may be captured and used during your tenancy for statistical analysis purposes and for equal opportunities monitoring purposes.


WHAT IS THE LEGAL BASIS FOR USING YOUR INFORMATION?


Processing personal data which is in our own or a third-party’s Legitimate Interests. Where we use this as a basis for processing, we carry out a test to ensure that: 1) we have identified the Legitimate Interest; 2) the processing is necessary; and 3) our processing of such data does not adversely affect the rights and freedoms of individuals.


WHAT WE ARE GOING TO DO WITH YOUR INFORMATION


The information you provide to us will be used for the following purposes:



  • 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;

  • It will be collected and used by us fairly and openly for the purpose of providing our services to you and to tailor such services to your needs;

  • It will be used to improve the services you receive from us and will be used during you tenancy to contact you, if you have given your consent for us to do so.

  • We may conduct Sanctions, Politically Exposed Persons and other checks on all applicants, tenants, authorised residents, and guarantors


The information you have provided about yourself will enable us to ensure that we can provide you with the service requested and meet the terms of our contract.


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.


If you have given explicit consent during your enquiry, the registration or application process and have chosen to be included in communication regarding any future accommodation provision, we will use the data provided for this purpose.


Some of the information which we collect will be special categories of personal data (also called sensitive personal data), such as any disability you may have. You need to be aware that we will use this information in order to determine if we have suitable accommodation, and enable us to allocate the most appropriate accommodation depending on your specific needs.


By providing us with this information, you consent to our use of it for this purpose. Please note that not providing this information may result in unsuitable accommodation being allocated.


WHAT IS THE LEGAL BASIS FOR USING YOUR INFORMATION?


In accordance with the data protection law and regulation, 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.


The lawful basis on which we rely on in order to use the information which we collect about you, for the purposes set out in this notice will be:



  • Using your information in this way is necessary for us to provide you with information, ensure we can process your enquiry and application at your request and subsequently to enter into and perform a binding contract.

  • If you have given permission during the enquiry, registration or application process and have chosen to be included in communication regarding any future accommodation provision, we will use the data provided and we will do this under the legal basis of consent.

  • Using your information is necessary for us to comply with a legal obligation to which we are subject.

  • Processing personal data which is in our own or a third-party’s Legitimate Interests.  Where we use this as a basis for processing, we carry out a test to ensure that: 1) we have identified the Legitimate Interest; 2) the processing is necessary; and 3) our processing of such data does not adversely affect the rights and freedoms of individuals.


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 the information – see section above.


SHARING YOUR INFORMATION


OTHER HOMES FOR STUDENTS BRANDS


Homes for Students Ltd is made up of a number of related student accommodation brands. We will share your information within Homes for Students Ltd in order to best provide the services to you in accordance with your enquiry and any future contract between us.


Your information will only be accessed internally within Homes for Students Ltd where it is necessary to do so in order to provide services to you in accordance with your enquiry and any future contract. The obligations which are set out in this notice shall apply to all brands that make up Homes for Students Ltd to the same extent.


CONTRACTORS AND SUB-CONTRACTORS


It may be necessary to share information about you with our contractors and sub-contractors in order to provide you with the services in accordance with your enquiry and any 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).


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 our behalf.


REGULATORS AND OTHER LEGAL OBLIGATIONS


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.


OTHER ORGANISATIONS


We may from time to time share your information with other organisations, such as:



  • Partner organisations whom we have data sharing agreements with, for example, institutions of Study, Universities or Agencies acting on our behalf;

  • Our clients for statistical analysis, audit or debt collection purposes;

  • Utility companies so they can provide services to you and contact you in respect of utility charges (only if applicable);

  • The police for the purpose of detection and prevention of crime;

  • To assist the management of our contracts we may utilise debt recovery/deposit protection and credit reference agencies where applicable;

  • Mail or parcel delivery organisations who have incomplete delivery address details in order to facilitate delivery of parcels addressed to you.


TRANSFERRING YOUR INFORMATION ABROAD


We will not transfer the information you provide to us outside of the European Economic Area.


SECURITY OF YOUR INFORMATION


The information that you provide will be stored securely on our systems and any paper records you have completed will be shredded. Homes for Students has in place robust security measures and procedures which reflects the seriousness of how we approach the security of your information and the value we attached to this.


Only those members of staff who are deemed as relevant to requiring access to your information will have sight of the information you provide to us.


CAN WE USE YOUR INFORMATION FOR ANY OTHER PURPOSE?


Only in limited circumstances may we use your information for a purpose other than those set out in this document. However, if we intend to do so, we will provide you with information relating to that purpose before going ahead and doing so.


STORING AND DELETING YOUR INFORMATION


We will store the personal data which you provide to us for as long as you remain a service user.


Once you are no longer a service user of ours, we will review the information we hold concerning you and determine whether there are any reasons why we need to continue holding that information.


If a student is in arrears when they leave the property, it may be necessary to retain information about them in order to recover those arrears and the debt.


There also may be regulatory and/or business best practice requirements which dictate the length of time the data is held. Once the identified purpose comes to an end, unless there is another identifiable purpose for which it is necessary to hold your information, this shall be deleted.


YOUR RIGHTS


In relation to the information which we hold about you, you are entitled to:



  • Ask us for access to the information;

  • Ask us to rectify the information where it is inaccurate or is incomplete;

  • Ask us to erase the information and take steps to ask others who we have shared your information with to also erase it;

  • Ask us to limit what we do with your information;

  • Object to our use of your information and ask us to stop that use;

  • 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).


Our obligations to comply with the above rights are subject to certain exemptions.


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 is withdrawn will not be affected.


To exercise any of the rights referred to above, you should contact our Data Protection Officer by writing to The Data Protection Officer, Homes for Students, The Clock Tower Park, Longmoor Lane, Fazakerley, Liverpool L10 1LD or at dataprotection@wearehomesforstudents.com.


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.