Privacy notice - factored homeowners - collecting and retaining your personal information
Lowther Homes delivers excellent property management services, day-in, day-out, to customers across central Scotland. We are proud to be part of Wheatley Group - Scotland's leading housing, care and property-management group.
Lowther Homes is committed to maintaining the accuracy, confidentiality and security of your personal information. This privacy notice describes the personal information that Lowther Homes collects from or about you as a factoring customer, and how we use and to who we disclose that information.
Our Data Protection Officer is Ranald Brown who can be contacted on #firstname.lastname@example.org.
What we need
Lowther Homes is the data controller of all information held in respect of its factoring customers. We need to hold personal information about you, as a factoring customer, in order to fulfil our obligations as your factor.
We collect the following information through a variety of sources: (i) directly from you; or (ii) via one of Wheatley Group's Registered Social Landlords (RSLs); or (iii) via a third party including:
- your full name
- your date of birth
- your contact details (phone, email or correspondence address)
- other personal information that will vary on a case by case basis to assist us in fulfilling your factoring services
- your bank details - if you pay by direct debit
- correspondence with or about you, for example letters or emails from you
- details of anyone authorised to act on your behalf, if applicable
- your payment history, and
- historic complaint information.
The information we may collect from you includes:
- your date of birth to allow you to register for our web self-service and make a buildings insurance claim if required
- proof of identify, for example if a representation mandate is being set up.
We collect your personal information from you via a variety of sources, including when you complete one of our forms, when you call, write, email or meet with us or respond to a survey. We may collect information when you use our social media sites and or web self-service portal, ‘My Lowther- owner’.
Our landline phone calls to our Customer Service Centre and Group Debt Recovery Team are recorded for training and monitoring purposes and our recordings are usually held for a period of six months.
The Wheatley Group and its RSLs operate a CCTV system at its office premises and at various locations within the vicinity of their properties for the detection and prevention of crime, to fulfil their legal obligations to keep staff safe and in pursuit of their legitimate basis to keep their properties safe and secure. Their CCTV cameras operate continuously and recordings are held for one month.
From time to time the Wheatley Group and its RSLs may operate CCTV/sound recording and/or use photography to capture evidence of alleged anti-social behaviour or crime.
We may take photographs and video footage at events we organise or take part in, at our offices and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent.
We may transfer information about you to other Wheatley Group companies for purposes connected with the management of Lowther Homes’ business.
We may receive information about you from third parties including but not restricted to:
- solicitors dealing with the sale or purchase of a property factored by us
- councillors, MPs, MSPs or other representatives acting on your behalf/instruction
- police, welfare or support organisations dealing with you.
We do not usually process children’s information as part of your factoring services, as all factoring customers are adults.
We may receive children’s information if we are involved in the factoring aspects of a welfare case as part of a multi-agency working solution.
Why we need your personal information - Contractual purposes and legal obligation
We collect and use the above personal data in order to:
- set you up as a new customer on our systems including issuing you a Welcome Pack to welcome you as a customer
- carry out our factoring duties including reactive and planned repairs and investment in your property
- provide buildings insurance if required
- investigate and respond to complaints
- receive factoring charges payments
- pursue any debts owed to us
- process requests from third parties
- collect personal information for example telephone numbers, email address, date of birth, correspondence address if different from factored property, and
- to provide information requested by customers or their representatives as part of a property sale or purchase.
We are under a legal obligation to process certain personal information relating to our factoring customers for the purposes of complying with our legal obligations under:
- Property Factors (Scotland) Act 2011.
If you do not provide the information we need then we will not be able to provide factoring services to you.
Why we need your personal information – legitimate purposes
We also process your personal information in pursuit of our legitimate interests to:
- undertake research and statistical analysis to help improve our business processes and the services offered to our customers, as well as to evaluate our performance against other benchmarks. Where possible, statistical information is anonymised or pseudonymised
- carry out customer segmentation research to allow us to help us better understand our customers’ characteristics and prioritise, tailor and target services to you, and
- we may also conduct surveys regularly and periodically relating to our services in order to gauge satisfaction and make improvements based on feedback.
We request that you provide your date of birth to allow us to offer you access to our web self-service portal ‘My lowther-owner’, and also to make a buildings insurance claim. You may choose not to provide this information to us but this may impact on your ability to access these services.
Where we process your personal information in pursuit of our legitimate interests, you have the right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing, please contact us on InformationRequests@wheatley-group.com. If we agree and comply with your objection, this may affect our ability to undertake the tasks above for your benefit.
We offer a number of additional optional services to our factoring customers including boiler cover, internal repairs and contents insurance.
For these optional services, where your personal information is needed, we will issue an additional privacy notice.
Other uses of your personal information
We may ask you if we can process your personal information for additional purposes. For example, we may share your information with a language translation service if it is necessary to translate any information into or from a foreign language for you.
Where we do so, we will provide you with an additional privacy notice with information on how we will use your information for these additional purposes.
Who we share your personal information with
We share limited personal data with our contractors who are carrying out services on our behalf including:
- to carry out emergency, responsive or planned property repairs
- to support cyclical and investment works on your property as requested by you or other homeowners including the Group’s RSLs
- to provide a language translation service if it is necessary to translate any information into or from a foreign language for you
- with our professional and legal advisors for the purposes of taking advice
- with our building insurance provider if this service is required as part of our factoring duties
- with service providers of our optional services
- to carry out research, survey and segmentation on our behalf to help us to improve the services we offer to you, and
- with companies who provide our Direct Debit service.
Our contractors are required to comply with the law and our own Data Processing Agreement or Data Processing Clauses within our contracts to ensure data is managed appropriately and for specified purposes.
We may need to share personal information with local authorities, government departments and agencies, with our regulator and auditors, with utility companies or with other organisations and agencies where we are legally required to do so.
We will only share information on the basis of your consent or in accordance with another lawful basis under UK data protection legislation.
In the event that we do share personal information with external third parties, we will only share such personal information strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.
How we will communicate with you
As our factoring customer we need to communicate with you. This will usually be in writing or by telephone, but is more commonly becoming electronic and paperless. We are moving many of our services online as this is usually more convenient for you and more efficient for us. Our secure online factoring customer self-service is called ‘My lowther-owner’.
If you use the ‘Web self-service’ it is important that you keep your password secure and do not share your ‘My lowther-owner’ details with any other person. The privacy of your information, as with any online service, depends on you keeping your account username and password details to yourself, as well as setting a suitably complex password that cannot be guessed or calculated. In the case of a joint factoring account both parties can have their own ‘My lowther-owner’ account.
Our factoring customers receive our newsletters with information about what is going on within the organisation.
We will only discuss or communicate your factoring details with those named on the factoring account or those authorised (temporarily or permanently) by you.
How long we keep your personal information
We will only keep your personal information for as long as necessary to fulfil our factoring duties to you and to safeguard the Wheatley Group in the event of any claims, complaints, litigation, enquiries or investigations during or following the termination of that factoring relationship. Unless you ask us not to, we will review and possibly delete your personal information seven years from the date ownership of a factored property ceased or we have ceased to factor your property.
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 factoring account. You can request a copy by contacting us at InformationRequests@wheatley-group.com
We review our data retention periods regularly and will only hold your personal information for as long as is necessary for the relevant activity or as required by law (we may be legally required to hold some types of information).
You can exercise any of the following rights by emailing us at InformationRequests@wheatley-group.com
Your rights in relation to your personal information are:
- you have a right to request access to the personal information that 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 that we correct or complete your personal information
- you have a right to request that we restrict the processing of your personal information for specific purposes, and
- if you wish us to delete your personal information, you may request that we do so.
Any requests received by Lowther Homes 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 details.
Changes to our privacy notice
Our privacy notice is regularly kept up to date and this version was updated on 27 October 2020. The latest full version is always available from our website at www.lowtherhomes.com