Privacy notice - Digital survey

The Wheatley Group and its subsidiaries is committed to protecting the personal information that you provide, and recognise the importance of being clear about how we intend to use it.

All personal information provided by you through this digital survey will be under the control of Lowther Homes acting as Data Controller and in line with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Data Protection Act 2018.

Our Data Protection Officer is Ranald Brown who can be contacted on

This privacy notice explains how we may use any personal information we collect about you when you complete a digital survey.

You should check this page from time to time to ensure you are happy with any changes. This notice is effective from 1 November 2018.

What is personal information?

Personal information is information that alone or combined with other information may identify you. Under the GDPR personal data is defined as:

“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

We do not consider personal information to include information that has been anonymised so that it does not allow you to be identified.

What personal information we may collect

When you complete a digital survey we may ask you for personal information to allow us to contact you to deal with any follow-up request or enquiry.

The information we may collect from you includes the following personal information:

  • if you ask us to contact you - your full name, email address, telephone number and any personal data you may choose to include within the free text box
  • which website you were using when you chose to complete the digital survey
  • the part of the business that is providing your service.

How we intend to use your personal information

We process the information held about you for a number of reasons and upon different legal bases depending on the reason for which we have collected or obtained your personal information. The main reasons we process your information in relation to digital surveys are:


  • to provide a service: this is necessary for the performance of, or to take steps at your request prior to entering into, a contract with you. Our privacy notices for our customers and potential customers can be accessed at
  • if you are enquiring on behalf of someone else, we may need confirmation you are authorised to act on their behalf before we can discuss their personal details.

In our legitimate interest:

  • to keep our records up to date
  • to improve our understanding of our customers and their needs
  • to administer, support, improve and develop our services to ensure our service to you is as good as it can be
  • to support strategic development
  • to recover any monies owed
  • to prevent and detect fraud and other criminal activities
  • to safeguard and maintain our property
  • to send you further information about our services or survey your opinion: we may also retain your details to provide you with information about our own service we think you may find interesting, or send you a survey about your experience with us. We will do this using the contact details you have provided. This is necessary in order to fulfil our legitimate interest in providing you with this information.

The personal information you give to us via a digital survey may be transferred to our third party providers who undertake the following services on our behalf. These organisations include organisations who host the digital survey on our behalf, such as Formic Solutions, our current provider.

We may transfer information about you to other Wheatley Group companies for purposes connected to the management of the company’s business.

We may also share your information with other organisations in the following circumstances:

  • if we are required to do so by law
  • if Lowther Homes or substantially all of its assets, are acquired by a third party, in which case personal data held by us about our clients will be one of the transferred assets
  • if we transfer our rights and duties under this privacy notice.

Any third parties we share your data with are obliged to keep your details securely and to use them only to fulfil the service they provide to you on our behalf. When they no longer need your data to fulfil this service, they will dispose of it in line with our procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

All the above organisations will process your personal information inside the EEA.

How long will you keep my personal information?

Your personal information submitted in response to a digital survey will be retained by us, and those organisations that process your data on our behalf, for 13 calendar months. Any additional details you choose to provide will be retained for as long as is necessary for the required service to be provided to you.

We have a data retention policy that sets out the periods for retaining and reviewing all information that we hold. This sets out different retention periods for all information we hold about your tenancy.

You can request a copy by contacting us at

Where will my personal information be kept?

Your personal information will be under the control of Lowther Homes as detailed in this notice.

However, the security of your data transmitted to and from the website cannot be guaranteed and is entirely at your own risk, as the internet is never completely secure.

Changes to our privacy statement

We will regularly review our privacy statement to ensure it reflects the personal information we may request from you and how we may process it. The date of subsequent revisions of this privacy notice will be recorded at the beginning of this notice.

Your rights as a data subject

You can exercise any of the following rights by writing to us at

Your rights in relation to your personal information are:

  • you have a right to request access to the personal information we hold about you by making a Subject Access Request
  • if you believe that any of your personal information is inaccurate or incomplete, you have a right to request we correct or complete your personal information
  • you have a right to request we restrict the processing of your personal information for specific purposes
  • if you wish us to delete your personal information, you may request that we do so.

Any requests received by us will be considered under applicable UK Data Protection Legislation. If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner's Office.

The accuracy of our information is important to us - please help us keep our records updated by informing us of any changes to your personal information.


In the event you have any questions about our privacy notice or information we hold about you, or you wish to make a complaint about how your personal data is being processed by us or third parties as described above, please contact our Data Protection Officer by:

Please note that if you contact us by telephone, your call maybe recorded for training and quality purposes.

You also have the right to complain to the Information Commissioner’s Office (the ‘ICO’) about how we have processed your personal data. The ICO can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, by telephone on 0303 123 1113 or through the website

Changes to this privacy notice

Our privacy notice is regularly kept up to date and this version was updated on 23 October 2018. The latest full version is always available from our website at