Privacy Policy – Stonewall Housing

Privacy Policy

1 About this policy
Stonewall Housing helps thousands of people every year struggling with bad housing or homelessness, through our advice, support and legal services including our online services. We campaign to make sure that one day, no one will have to turn to us for help. In order to do this, we sometimes use anonymised data to highlight key issues.

When doing this, we process personal data about people who receive advice, guidance or housing support services from us – or provide us with support through campaigns, donations, booking on training courses, or volunteering. We are committed to protecting your privacy and take this responsibility very seriously. We therefore take care to safeguard it. This notice outlines what data we collect, how we may use it, how we protect your data and your rights, and how you can exercise those rights.

References to ‘we’ or ‘us’ are to Stonewall Housing (Stonewall Housing is a Charitable Housing Association registered under the Co-operative and Community Benefit Societies Act 2014 No. 24277R). Registered address: Stonewall Housing, 2A Leroy House, 436 Essex Road, N1 3QP.

We regularly check this notice to ensure we provide you with the most up-to-date information regarding our data processing activities. We strongly advise you to read this page from time to time to ensure you are happy with any changes that might be made.

This privacy policy was prepared to be as comprehensive as possible, but it does not include an exhaustive list of every aspect of our collection and use of personal information. However, we would be happy to provide any further information or explanation about our practices.

If you have any questions about this policy, please contact us using the details in the Contact us, section below.

This privacy policy was last updated in April 2018.

2 Why we collect your data
We collect personal data for many reasons, including to provide you with services, communicate with you and send you information you have requested, and administer campaigns and donations. Depending on how you interact with us, we may process data for the following reasons:

a. to provide you with advice, support or legal services that you have requested or been referred to
b. to record personal details shared during conversations with our Advice Line
c. to process personal details required for the administration of your booked training course
d. to record and contact you regarding payments you make to Stonewall Housing
e. to administer services Stonewall Housing is providing to you
f. to communicate with you regarding Stonewall Housing’s work, fundraising, and campaigning activities
g. to process donations and administer Gift Aid information for any donation you make to Stonewall Housing
h. for our own internal administrative purposes, and to keep a record of your relationship with us
i. to manage your communication preferences
j. to process job applications or volunteer placements
k. to conduct surveys, research and gather feedback
l. to obtain information to improve Stonewall Housing’s services and user experiences
m. to comply with applicable laws and regulations, and requests from statutory agencies.

3 Information we collect
We collect the following personal information:

a. your full name
b. contact details – including your postal address, telephone number(s), and email address
c. date of birth
d. details of your case when providing you with housing advice or services
e. your bank details
f. records of your correspondence and engagement with us
g. donation history and Gift Aid details
h. information you may enter on the Stonewall Housing’s website
i. photographs, video or audio recordings (with consent).
j. occupation
k. biographical information
l. other information you share with us

This information may be collected via:

a. any paper forms you complete
b. telephone conversations or face-to-face interactions
c. digital forms completed via our website, or online surveys
d. third-party companies and websites such as Just Giving
e. publicly available sources
f. communication via social media

We sometimes also collect sensitive, personal data about individuals. This includes information about health, religion, sexuality, ethnicity, political and philosophical beliefs, and criminal records. We will normally only record this data where we have your explicit consent, unless we are permitted to do so in other circumstances under data protection law. For example, we may make a record that a person is in a vulnerable circumstance to comply with requirements under charity law and the Code of Fundraising Practice, to ensure that we do not send fundraising communications to them.

4 Using your personal data
Stonewall Housing Services
If you are receiving advice, guidance or support from us, we will need to process your data because of your specific relationship with us.

We will keep all your case information – including notes, letters and information given to us about you – in a confidential record that is specific to you. We use a customer relationship management system (CRM) to support our advice, guidance and support. This means that we can keep the information you provide us, so we are able to see the history and relevant details of your case(s). This ensures that we provide appropriate and accurate advice or support. We take information security very seriously. No one is allowed access to our system or files unless they need this to provide the service to you, or one of the other purpose discussed in this notice.

When you call our Advice line for advice, your call may be recorded or listened into. This is used for training purposes, quality assurance, and to make further improvements to the service we provide to you. If the call is being recorded or listened into you will be informed of this before any data collection occurs.

To ensure that our services meet a high standard of quality, client files are sometimes checked by our quality assurance staff. This includes an external solicitor. Files may also be checked by external auditors such as the Advice Quality Standard. Your data may also be checked, if the work we do is funded by another organisation, such as a local authority. All auditors are bound by confidentiality policies.

We may use your data for statistical reports. These statistics will not include any information that could be used to identify any individual.

Fundraising/campaigning/direct marketing
We would love to keep you up to date with our fundraising, marketing and campaign activity.

We use a range of marketing activities and channels to contact our supporters – including our website, face-to-face fundraising, direct mail and email.

We will obtain your consent to contact you by email and text message for marketing purposes. We will also obtain consent from all new supporters (who sign up after 25 May 2018) to make marketing calls.

We will send you marketing by post, on the basis of it being within our legitimate interests to do so, unless you opt out. See section 10 (‘Our legal basis for processing data’) for more information about our use of legitimate interests.

We send the following marketing materials:

a. updates about Stonewall Housing’s work – including newsletters, magazines, and other publications informing you about our work.
b. campaigns – information about our campaigning activities, including how you can support such campaigns, (for example by signing a petition), and updates about the progress of our campaigns.
c. appeals and fundraising activities – including requests for donations, information about how you can leave us a gift in your will, how you can raise money on our behalf, attend or take part in a fundraising event, communications relating to our lottery and raffles, and updates on the impact that your fundraising activities have had on our work.
d. events – including details of our challenges, such as sponsored runs and activities, as well as other events such as drag events and comedy gigs in aid of Stonewall Housing. On occasion we will also send you a reminder about the same event in future years, in case you want to participate in it again.
e. volunteering – information about how you can help support Stonewall Housing by giving up your time or using your influence to progress our aims, along with updates on the impact of your work.
f. professional services – including details of the professional services that Stonewall Housing offers, such as training and publications.

We will never share or sell your personal data to a third-party organisation for its marketing, fundraising or campaigning purposes. You can withdraw your consent, unsubscribe from or update your marketing preferences at any point using the details in the ‘Contact us’ section below.

Any electronic communications, such as emails, will have a link to unsubscribe from future electronic communications, so you can manage your own communication preferences.

If you make any changes to your consent, we will update your record as soon as we possibly can. It may take up to 60 days for our systems to update and stop any postal communications from being sent to you. Email communications will, however, be stopped immediately. If you tell us you do not wish to receive marketing, fundraising or campaign communications, you may still receive transactional and service-based communications confirming and servicing other relationships you have with us (as described below).

Administrative communications to supporters
In addition to the fundraising and marketing communications that you receive from Stonewall Housing, we will also communicate with you by post, telephone, and email in relation to administrative and transactional matters. For example, we will call you after you have set up a Direct Debit to confirm your details, and upon cancellation. There may also be other occasions where we need to contact you about your donation – for example, if there is a problem with a payment or in relation to your gift aid declaration.

On occasion, we will also contact you about an event that you have signed up to participate in, to – for example – check that fundraising pages have been set up and to provide any other necessary information.

As mentioned above, we may still need to communicate with you for administrative purposes even where you have opted out of marketing communications from us.

5 Social media / digital
Depending on your settings or the privacy policies for social media messaging services like Facebook, Twitter, and Instagram, you may receive targeted advertisements through our use of social media audience tools. For example, Facebook’s ‘Custom’ and ‘Lookalike’ Audiences’ programmes enable us to display adverts to our existing supporters when they visit Facebook, or other people who have similar interests or characteristics to our supporters. We may provide your data (including your email address) to Facebook, so it can determine whether you are a registered account holder with them, or so that Facebook can create a ‘lookalike’ audience. Our adverts may then appear when you access Facebook. We only work with social media networks that provide a facility for secure and encrypted upload of data, and immediately delete any records not matching with their own user base. For more information, or to manage your social media ad preferences, please see Facebook’s ‘About Custom Audiences’ guide and its Data Policy.

Our website also uses web beacons or pixels through third-party service providers that allow us to track conversions and activity on our website, as well as generating advertisements that appear on Facebook and other search engines, like Google, for you and other potential users.

6 Applying for a Stonewall Housing job
When you apply for a job with us, your personal data will be collated to monitor the progression of your application, and the effectiveness of the recruitment process through the statistics collected. Where we need to share your data – such as for gathering references, obtaining a Disclosure and Barring Services (depends on the role), or a prison clearance (depends on the role) – you will be informed beforehand, unless the disclosure is required by law. These checks are only done after a position has been offered only to the successful candidate. Once you have been offered a role, we will automatically send out reference requests.

Personal data about unsuccessful applicants are held for 12 months after the recruitment exercise is complete for that vacancy. You, as an applicant, can ask us to remove your data before this time if you do not want us to hold it. If we feel there is another suitable vacancy available, we will contact you prior to sharing your application details with the relevant manager.

Once you have taken up employment with Stonewall Housing, we will compile a file relating to your employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to your employment. Once your employment with us has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it from our files.

7 Professional contacts
We may collect data about professional contacts and partners with whom we work, or to whom we provide professional services – such as training. Personal data collected in this way will be processed in accordance with data protection legislation and this policy.

We may send our professional partners information and updates about our work (primarily by email). Such contacts can opt out of receiving this information at any time.

We maintain a record of information related to MPs and other holders of public office, to enable us to undertake our campaigning activity in furtherance of our organisational aims. This will include keeping a record of contact details such as address, telephone number and email address as well as publicly available voting records and committee and group memberships.

8 Our legal basis for processing personal data
We need a lawful basis to collect and use your personal data under data protection law. The law allows for six ways to process personal data (and additional ways for sensitive personal data). Four of these are relevant to the types of processing that we carry out. This includes information that is processed on the basis of:

a. a person’s consent (for example, to send you direct marketing by email or SMS)
b. a contractual relationship (for example, to provide you with goods or services that you have purchased from us)
c. processing that is necessary for compliance with a legal obligation (for example to process a Gift Aid declaration, and carrying out due diligence on large donations)
d. Stonewall Housing legitimate interests (please see below for more information) Personal data may be legally collected and used if it is necessary for a legitimate interest of the organisation using the data, if its use is fair and does not adversely impact the rights of the individual concerned.

When we use your personal information, we will always consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair. Our legitimate interests include:

Charity Governance: whilst we are not currently a registered charity we are a charitable organisation and therefore operate as a charity. Therefore, in terms of charity governance we collect process data including delivery of our charitable purposes, statutory and financial reporting and other regulatory compliance purposes.
Administration and operational management: including responding to solicited enquires, providing information and Stonewall Housing’s services, research, events management, the administration of volunteers and employment, and recruitment requirements
Fundraising and Campaigning: including administering campaigns and donations, and sending direct marketing by post, sending thank you letters, analysis, targeting and segmentation to develop communication strategies, and maintaining communication suppressions
If you would like more information on our uses of legitimate interests, or to change our use of your personal data in this manner, please get in touch with us using the details in the ‘Contact us’ section below.

9 Disclosure of your personal data
We will not share any of your personal data to any third party – except where:

the transfer is to a secure data processor, which carries out data processing operations on our behalf (please see section 13 for more information)
we are required to do so by law, for example to law enforcement or regulatory bodies where this is required or allowed under the relevant legislation
it is necessary to protect the vital interests of an individual
we have obtained your consent
We will never share or sell your personal data to a third-party organisation for marketing, fundraising, or campaigning purposes.

10 Security of your personal data
We use appropriate technical and organisational measures and precautions to protect your personal data and to prevent the loss, misuse or alteration of your personal data.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

We encourage you to review the privacy statements of websites you choose to link to from the Stonewall Housing website, so that you can understand how those sites collect, use and share your information. We are not responsible for the privacy statements, security, or other content on sites outside of the website.

11 Transfers of data outside of the European Economic Area
We use Microsoft Office 365, which are multi-tenant cloud services, for our internal office use. This means that internal documents and information generated by us are stored in cloud services hosted within the European Economic Area (EEA).

However, in some limited cases, we may use data processors that process and/or store data outside of the EEA – for example, payment processors.

In these cases, we will take reasonable steps to ensure that the recipient implements appropriate measures to protect your information, for example, by entering into a contract that includes prescribed clauses about the use of data and if the company is based in the United States, checking that it is accredited under the EU-US Privacy Shield.

12 Retention of your data
Whatever your relationship with us, we will only store your information for a specified amount of time, as set out in our internal data retention policy.

The length of time that data will be kept may depend on the reasons for which we are processing the data and on the law or regulations that the information falls under, such as financial regulations, Limitations Act, Health and Safety regulation etc., or any contractual obligation we might have – such as with government contracts or if we have a business case, such as with research data. For business case data, we will anonymise the data so no individual is identifiable.

Subject to the above, we will typically store data relating to donors and people who have taken campaign actions for seven years after their last donation or interaction, and people to whom we provide services to for seven years after completion of those services. Personal data about unsuccessful applicants are held for 12 months after the recruitment exercise is complete for that vacancy.

Once the retention period has expired, the information will be confidentially disposed or permanently deleted.

13 Your rights
You have many rights under data protection legislation. These include:

Right of Access
You have the right to know what information we hold about you and to ask, in writing, to see your records. We will supply any information you ask for that we hold about you as soon as possible, but this may take up to 30 days. We will not charge you for this other than in exceptional circumstances. You will be asked for proof of identity as the person dealing with your request may not be the staff member you have met before. We need to be sure we are only releasing your personal data to you.

This is called a data subject access, and can be done by:

writing to the Data Protection Manager, c/o Stonewall Housing, 2A Leroy House, 436 Essex Road N1 3QP.
Right to be informed
You have the right to be informed how your personal data will be used. This policy, as well as any additional information or notice that is provided to you either at the time you provided your details, or otherwise, is intended to provide you with this information.

Right to withdraw consent
Where we process your data based on your consent (for example, to send you marketing texts or emails), you can withdraw that consent at any time. To do this, or to discuss this right further with us, please contact us using the details in the ‘Contact us’ section below.

Right to object
You also have a right to object to us processing data where we are relying on it being within our legitimate interests to do so (for example, to send you direct marketing by post). To do this, or to discuss this right further with us, please contact us using the details in the ‘Contact us’ section below.

Right to restrict processing
In certain situations, you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage.

Right of erasure
In some cases, you have the right to be forgotten (i.e. to have your personal data deleted from our database). Where you have requested that we do not send you marketing materials, we will need to keep some limited information to ensure that you are not contacted in the future.

Right of rectification
If you believe our records are inaccurate, you have the right to ask for those records concerning you to be updated. To update your records, please get in touch with us using the details in the ‘Contact us’ section below.

Right to data portability
Where we are processing your personal data because you have given us your consent to do so, you have the right to request that the data is transferred from one service provider to another.

14 Complaints
If you have any complaints about the way in which we have used your data, please get in touch with us using the details in the ‘Contact us’ section below. We would be happy to help and discuss your concerns.

In addition, you are also entitled to make a complaint to the Information Commissioner’s Office and the Fundraising Regulator.

15 Contact us
If you have any questions about this policy, would like more information, or want to exercise any of the rights set out above, you can get in touch with us in the following ways: Email: