My Account - Privacy Policy

Leeds Federation Housing Association Limited
‘My Account’ Tenant Portal and Associated Privacy Policy

This policy sets out:

information about the ‘My Account’ Tenant Portal and
how Leeds Federated Housing Association Ltd (“LFHA”) will process your personal and sensitive data in relation to the ‘My Account’ Tenant Portal.

What is ‘My Account’?

The LFHA ‘My Account’ is a way in which our tenants can access, view and engage with LFHA in regards to their tenancy. It enables our tenants to view documents and carry out a lot of day to day activities, including:

managing and keeping their information up to date
viewing, making, cancelling and changing repairs appointments
viewing information about previous repairs
viewing, downloading and printing rent statements
viewing and downloading property documents, for example gas and electrical safety certificates
reporting anti-social behaviour,
downloading our noise nuisance app
reporting a service complaint
contacting LHFA to ask for a call or support on monetary matters
viewing and updating your personal contact and profile information;
viewing and updating contact and profile information about your household occupants
requesting a tenancy termination.

The aim is to bring your tenancy details to your door.

How do I register for ‘My Account’?

To set up and have access to your LFHA ‘My Account’ you need to be the primary and/or be a joint tenant of a LFHA property. Only people named on the tenancy agreement will have a ‘My Account’. This means if there is a joint tenancy, each of the named tenants will have their own individual ‘My Account’, with separate user access and passwords.

To register your details to obtain access to your ‘My Account’, you will need to supply the following information:

First and Last Name
Address
Tenancy reference
Email address
Security question

Prior to registering for your ‘My Account’ please read our ‘My Account’ Privacy Policy which follows below, together with the Privacy Policy on LFHA’s website at www.lfha.co.uk/privacy. You should read these Policies carefully to understand how we will process your personal and sensitive data.

You can also view our Terms & Conditions on our website at www.lfha.co.uk/terms.

How do I change or reset my password on ‘My Account’?

You can reset your password by following these simple steps:

Click on the ‘Forgotten your password’ password reset link on the ‘My Account’ login page and enter either the email address or the mobile telephone number registered against your account.
Use the link to reset your password sent by email or SMS and enter your new password details.
On the ‘My Account’ login page you will now be able to access your account by entering your username (email address) and new password.

What does the ‘My Account’ do?

There are specific areas of the ‘My Account’ which help you contact us, report and manage your repairs, rent, payments and much more, for example:

Contact us

You can contact us through your ‘My Account’ to ask for a visit, phone call, make a complaint or to raise a monetary matter.

Change / request a repair date

Request or change forms may need to be completed in order for us to assess whether a repair is required or when the next available date for the repair can be carried out. The personal data entered will be used to contact you about the repair and to process the repair request. This data is added to the Housing Management System (“HMS”) to maintain a record of repairs carried out at the property.

Report Anti-Social Behaviour

The personal and sensitive data provided in regards to reporting Anti-Social Behaviour will be kept in line with our ASB policy to ensure confidentiality is adhered to. It may be necessary to share specific and relevant information where required to by law, with law enforcement and government agencies or public bodies where we are legally required to do so. We may hold this data on the HMS for the purpose of providing our services as a registered provider.

Paying rent

Making a rent payment is made through all-pay Limited, LFHA have supplied a secure gateway, we always recommend when visiting other website you ensure you read the privacy policy. However, we will ensure that the third party suppliers such as all-pay as our data processor have the appropriate safeguards to protect your personal information in line with the Data Protection Act 1998 and only processes this information on our instructions. The payment of rent will then be added to the HMS system.

Updating profiles of the individuals who live in the household

As part of your tenancy we obtain, use and retain personal and sensitive personal information about you as the tenant(s) and people that reside with you, (occupants). When updating your ‘My Account’ you need to ensure you have the informed consent of the occupants of your household if they are 18 years of age and above. When we collect this information from you we will require a written signature from any occupants that they have read and understood this Privacy Policy and have consented to their personal data being shared with us and processed for the purposes set out in this Privacy Policy. When changing, amending and/or removing occupant details from your ‘My Account’ you need to ensure you contact your local housing officer to ensure written consent is obtained. Any updates regarding the individual occupants of the household such as their profile information, will be also held on our HMS system and held in line with our information and records management retention policy.

‘My Account’ Privacy Policy

This Privacy Policy aims to give you information on how Leeds Federated Housing Association (“LFHA”) collects and processes your personal data through your use of ‘My Account’.

LFHA is defined as a data controller under the Data Protection Act 1998 and, from 25 May 2018, the General Data Protection Regulation ((EU) 2016/679) and any legislation which replaces the same (collectively the “Data Protection Legislation”) and is registered with the Information Commissioner’s Office (ICO) under Z666138X.

LFHA can be contacted by post at Arthington House, 30 Westfield Road, Leeds, LS3 1DE, or by telephone at 0113 386 1000 or by email at . Our Data Protection Officer is Megan Henderson and can be contacted by telephone on 0113 386 1000 or by writing to the address provided above.

We only collect or use personal information for those purposes indicated in our notification with the Information Commissioner’s Office. When processing your personal information we will comply with Data Protection Legislation and any national implementing laws, regulations and secondary legislation. The information we collect to deliver you a service through your tenancy is detailed in this document and our Privacy Policy found on our website: www.lfha.co.uk/privacy.

‘My Account’ may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

What personal data do we process and why?

When you register for your ‘My Account’ you are consenting for your data to be processed.

We process the following personal data pertaining to the primary, joint tenants and the occupants of the tenancy:

Why we process this personal data	Personal Data	Lawful Basis for processing
To identify you to enable us to provide a service to you	Full name (including title)	Performance of a contract with you.
To confirm your identity and right to rent in line with relevant immigration law	Identity documents, e.g. passports, residence permits	Necessary to comply with a legal obligation
To verify your identity and enable us to provide a service to you	Address	Performance of a contract with you.
To contact you in relation to your tenancy, e.g. any changes about which we that may need to notify you. To contact you in relation to repairs, including confirming appointments, sending reminders about appointments, responding to a request for a repair.	Telephone number(s)	Performance of a contract with you.
To verify your identity and enable us to provide a service to you. To contact you in relation to My Account.	Email address	Performance of a contract with you.
To enable us to tailor the service provided to you.	Preferred Communication	Performance of a contract with you.
To enable us to tailor the service provided to you.	Preferred Language	Performance of a contract with you.
To verify your identity and enable us to provide a service to you	Date of birth	Performance of a contract with you.
To verify your identity and for the routing of benefit payments in respect of rent and tenancy related costs.	National Insurance Number	Performance of a contract with you.
To identify your relationship with LFHA, for example if you are a tenant or a household member.	Relationship status	Performance of a contract with you.
To enable us to provide appropriate tenancy management services to you.	Economic status	Performance of a contract with you.
To enable us to provide appropriate services to you.	Correspondence with you, such as any information that you have provided	Performance of a contract with you.
To help us to tailor the service provided to you.	Information pertaining to your personal circumstances	Performance of a contract with you.
To help us to tailor the service provided to you.	Information regarding living individuals (e.g. customers / suppliers, staff)	Performance of a contract with you.
To allow us to receive payments from you and provide appropriate tenancy management services to you.	Financial details	Performance of a contract with you.
To assess patterns, gather broad demographic information for aggregate use, track visitors to the websites movements and to manage our website. LFHA does not link the IP addresses with any personal identifiable information.	IP addresses	Necessary for our legitimate interests to understand how people use our website and to improve the usability of the website.
To enable us to review the use of the LFHA website and ensure we continuously improve the service(s) we offer you. To act on your requests, changes and to respond to you. To help us develop closer relationships with you and helps us improve the services we provide.	Information that we gather when we monitor a tenant’s use of the ‘My Account’ system (e.g. how many times they have logged on and/or accessed part of the ‘My Account’.)	Necessary for our legitimate interests to understand how people use our website and to improve the usability of the website.

Where we process your sensitive data we will only do so with your explicit consent or where we have a legal right to do so.

Why we process these special categories of personal data	Special categories of personal data	Lawful Basis for processing
To monitor the allocation and management of LFHA properties. To demonstrate compliance with Equality legislation.	Ethnic origin	Necessary for our legitimate interests to help us better understand the diversity of our tenants and what steps we may need to take to improve this
	Religion
	Sexuality
	Gender Identity
To help us assess what adaptations we may be able to make to provide you with easier access to your property. To enable us to tailor the repairs service provided to you, prioritising some repairs to be undertaken more quickly where certain health conditions are present. To enable us to deliver specialist services to you such as Housing for Older Persons. To understand the needs of people living in our properties and identify areas where we need to develop plans to ensure services meet the needs of all customers.	Health, e.g. details of any mobility issues, physical or mental health conditions	Performance of a contract with you
To enable appropriate safeguarding for our customers. To inform the allocation of properties. To enable us to provide appropriate tenancy management services.	Offences committed or alleged to have been committed, commission of proceedings for any offence by the individual	Necessary to comply with a legal obligation. Necessary for our legitimate interests to determine suitability and identify if there are any pertinent risks to other tenants, the wider community or our employees.

How we use your personal data

The information obtained, processed and retained on the ‘My Account’ tenant portal will be processed in line with all applicable laws, in particular the Data Protection Legislation. LFHA is the sole data controller of the data collected and will not transfer, trade, sell or share the data without relying on a lawful purpose under the Data Protection Legislation.

All information entered on the ‘My Account’ will automatically be uploaded to our HMS. We will only use the personal information supplied for the purposes of delivering you a housing service as set out in this Privacy Policy, your tenancy agreement and tenancy handbook.

How we share your personal data

Our Privacy Policy details how we collect, use, share, retain and secure your personal information. We will not normally share your information without your consent unless we are required to by law or permitted to do so under other grounds under Data Protection Legislation – if this is the case we will inform you of what those grounds are.

We will share specific and relevant information where required to by law, with law enforcement and government agencies or public bodies where we are legally required to do so. Examples may include:

The prevention or detection of crime and fraud
The apprehension or prosecution of offenders
The assessment or collection of tax or duty owed to customs and excise
In connection with legal proceedings
In relation to the physical or mental health of an individual, where disclosure is required to protect them or others from serious harm and to protect their vital interests
Research and statistical purposes

There may be other times when we disclose your personal data to others, as follows:

our suppliers who enable us to provide our services to you, or who provide services on our behalf
housing contractors e.g. to undertake repairs or improvements to your home
IT providers who own or manage the computers, phones or systems we use
our contractors who handle your out of hours service calls for us
financial institutions e.g. to carry out payments through a secure system
companies that assist us in mailing out our leaflets/ newsletters
additional staff resources, such as consultants or agency staff
our professional advisors and providers of financial services
our partner organisations whose purposes dovetail with ours
training providers or learning institutions
other housing associations
external assistance where you have agreed to the referral, for example to do with financial problems or domestic abuse
local authorities and government departments who provide relevant services for you, including benefits
utility companies
debt collection agencies acting for others
for crime prevention or detection, risk assessment, resolution of complaints or other issues
local authorities, safeguarding boards, regulators, government departments and other public authorities, such as for preventing payment errors or fraud
the police, fire service, health authorities or medical practitioners

We may share your data with other registered providers or local authorities in connection with your application if you are registered on the Choice Base Letting scheme in Leeds and Wakefield.

There are some cases when we will share your information to support our legitimate business purposes and/or fulfill our other purposes as set out in the table above. We do this to ensure that we can meet your needs, and also to meet our health and safety obligations towards those delivering services on our behalf. This may include sharing information with our contractors and suppliers to enable them to carry out duties on our behalf or to meet contractual obligations we may have.

How we use your email and telephone number

When making an enquiry on ‘My Account’ you will be required to enter your contact number and email address. Contact via telephone, text messages and email provides a direct way to contact you regarding queries. We may share information with you about the services we can deliver to you, only with your consent.

We may use your telephone number and email address that you have provided us, to keep in contact with you. When we send SMS/text messages or emails, there may be someone in your household who may read the message before you are able to. You may like to inform the people who live with you that you may receive text messages from us time to time.

Electronic communications through emails will be monitored by us but only in so far as to be compliant with the law. This is to enable LFHA to fulfill its regulatory / legal obligations and its own internal policies.

How we keep your personal data secure

The ‘My Account’ will be accessible to all LFHA employees and our approved third party contractors, (data processors) who support you in your tenancy and/or supply us with technical support. We have taken reasonable steps to ensure your data is held securelyincluding implementing security policies, processes and technical security solutions to protect the personal information we hold from:

Unauthorised access
Improper use or disclosure
Unauthorised modification
Unlawful destruction or accidental loss.

All of our employees, contractors and third parties that we engage to process data on our or your behalf are obliged to treat the data confidentially. We hold and process personal data only within the European Economic Area (the “EEA”).

We cannot be held responsible for the security of the individual ‘My Account’ if you share you username and passwords:

You must not share your login details to your ‘My Account’.

How long do we keep your data for?

We follow the guidance laid down by the National Housing Federation in relation to the retention of personal data. We are happy to provide you with more information upon request.

Your rights in relation to your personal data

As a ‘data subject’, you have certain rights over the personal data we hold and process about you, specifically:

The right to be informed
The right of access
The right of rectification
The right to erasure (the ‘right to be forgotten’)
The right to restriction processing
The right to data portability
The right to object
Rights in relation to automated decision-making and profiling.

You can find out more about your rights from the ICO, which is the UK's independent body set up to uphold information rights.

The ICO’s website can be found at: at https://ico.org.uk/.

Contacting us about your personal information

We will be as open as possible with you about the personal information we hold about you, If you feel your information is wrong on your ‘My Account’, are dissatisfied on how your information is being processed or wish to exercise any of your data subject rights (as listed above) then please contact us. If something is wrong we want to work with you to put it right.

You have the right to have inaccurate/outdated information amended, deleted or destroyed. If any of your circumstances change please contact us. You have the right to object to direct marketing, know about automated decisions we make about your data, object to the use of data which causes you damage or distress. You can seek compensation via the courts if you feel a serious contravention of your rights has occurred.

Finding out about the personal data we hold about you

You can ask us whether we are keeping personal information about you by writing to our Data Protection Officer using the details provided above.

Requesting a copy of your personal data

As part of our service to you, we are happy to provide you with copies of personal information you are the focus of. We will provide this on receipt of a formal written request. This is called a ‘subject access request’. If you make a subject access request we will provide you with a readable copy of the personal information we hold about you. You will only receive the information Data Protection Legislation states is not exempt from disclosure. To make a subject access request you must:

Make your request in writing
Provide proof of your identity

Please send your request to CustomerService@lfha.co.uk or write to us at the address provided above.

If your request for your personal data is ‘excessive or manifestly unfounded’ (as defined under Data Protection Legislation), we have the right to refuse your request.

Withdrawal of your Consent

Where you have provided us with your consent to process your personal data in any particular way, you have the right to withdraw your consent at any time, however we may be unable to provide our services to you if we are unable to record and process certain information. If you would like to withdraw your consent to our processing of your personal data in any way then please contact us using the contact details provided above.

Questions and complaints

Please tell us if you have a concern about the personal data we hold about you, or how we use it. We will do our best to help.

If, after contacting us, you are still not satisfied you can complain to the ICO.

Contacting us

If you want to contact us specifically about your personal data, please contact our Data Protection Officer, Megan Henderson, using the contact details provided above.

Cookies

Our LFHA website and ‘My Account’ will use cookies to help customise your experience. Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.

Cookies do lots of different things, for example letting you navigate between pages, remembering your preferences, and generally improve your user experience. They can also help to ensure that information you see online is more relevant to you and your interests. The cookies used on ‘My Account’ have been categorised based on the ICC UK Cookie guide. A list of all the cookies used on this site by category is set out in our Cookies Policy. For further reading on cookies you can visit AboutCookies.org.

Keeping this policy updated

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We keep our Privacy Policy under regular review and this Privacy Policy does not form a contract between you and LFHA. This Privacy Policy was last updated on 25 May 2018.

Leeds Federation Housing Association Limited ‘My Account’ Tenant Portal and Associated Privacy Policy