Riverside

Equality and diversity

Our purpose(s) for processing and lawful basis

In addition to promoting human rights, we aim to eliminate discrimination and actively promote equal opportunities in all that we do, including the services we provide and the decisions we make.

In accordance with equality legislation, we may ask you and members of your household for your ‘protected characteristics’, namely, age, disability, gender reassignment, marriage & civil partnership, pregnancy & maternity, race, religion & belief, sex & sexual orientation.

We ask for this information so we can give everyone an equal opportunity to access our services, but also in order to understand you and your particular needs better. You do not have to provide this information, but it helps us if you choose to do so.

The legal bases which apply to the processing described above are:

• Where we have your consent
• Where we need to comply with legal obligations (such as the Disability or Equality Acts)
• Where the processing is necessary in the public interest, including the monitoring of diversity and equality where we work with local authorities and monitoring equality of opportunity or treatment (where the data isn’t used to make decisions on particular individuals)

How we use your information

You have the option to provide this information when you apply for a property. If you choose not to do so at this stage, you can choose to provide this information at any point once you are a customer of Riverside through ‘My Riverside’ or by contacting Customer Services. You may also update or delete this information at any time. Only Riverside staff with valid business reasons have access to this data.

We will use this data to:

• ensure your home meets your needs (including aids and adaptations)
• determine any assistance that you or other member of your household may require
• assist us in understanding any issues you may raise

We will also anonymise this data so that you cannot be identified and use this to:

• provide statistical data for monitoring and reporting purposes
• build a picture of the diversity of our customers at a local and national level
• inform our training, education, and awareness

Who we may share your information with

Where this personal data is required to ensure that your home meets your needs (including any assistance or modifications) identify support you or any household members may need or to help us comprehend any concerns you may have; we may share this data with those third parties listed in management of your tenancy.

We may also share anonymised data with government bodies, our regulators, our partners, or commissioners of our services to ensure that we share values and a genuine commitment to equality, diversity, and inclusion and to demonstrate our staff are representative to the customers and areas we provide homes in.

How long we will keep it

We keep information on our tenancy files for six years after the tenancy ends

You can contact us to delete this data at any time unless we have an obligation to retain it. Please see Your rights and right to erasure for more information.

Management of your tenancy (inc aids and adaptations)

Our purpose(s) for processing and lawful basis

During your tenancy we will collect and process information about you and members of your household to ensure that we can deliver our services to you.

The legal bases which apply to the processing described above are:

• Where we need to take measures to perform a contract we have entered into with you (provision of services set out in a tenancy or leasehold agreement);
• Where we need to comply with legal obligations (e.g. housing regulations, health and safety, safeguarding, tenancy fraud investigation);
• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. maintaining security of our property, customer satisfaction surveys and market research).

We may also use your sensitive personal data under the following legal bases:

• Where we have your consent (e.g. provision of additional benefits or services, information gathered through feedback or surveys).
• Where we need to protect your vital interests (or someone else’s vital interests).
• Where we need to comply with social protection responsibilities (safeguarding of individuals at risk or where we gather health data to make sure your home is appropriate for your needs)
• Where there is a public interest (to ensure there are no risks posed to our staff, customers, or contractors if you declare criminal convictions)

How we use your information

We will use your personal data to:

• Be able to contact you and respond to you directly.
• Manage your tenancy and property (including carrying out maintenance and repairs, notifying utility companies and local authorities);
• Monitor compliance with the terms of your tenancy or service agreement, investigate and report issues (e.g. tenancy fraud, anti-social behaviour)
• Share information with other agencies where we have your agreement, are required to do so, or were doing so gives effect to the tenancy/leasehold agreement.
• Investigate and resolve complaints and queries raised by residents and others.
• Comply with our safeguarding and health and safety duties.
• Deliver support for special needs to you or any member of your household.
• Provide information about additional services we offer, including opportunities to participate in meetings, training, employment services, youth services and events.
• Complete consultations, facilitate residents’ groups and community grant applications.
• Conduct transactional surveys in order to monitor and improve our service, for example, repairs and maintenance, complaints, lettings, anti-social behaviour issues and training.
• Monitor equality and diversity
• Provide information about our performance and services through newsletters and email campaigns.
• Verify your identity so that we can give you access to your MyRiverside account;
• Share information with our payment gateways to enable payments to be taken online

Who we may share your information with

Generally we collect personal data directly from you, but we may in some cases also receive personal data from government bodies and local authorities, third party suppliers, other individuals, or partner organisations (e.g. where work with other parties to provide services, for investigating a complaint etc.).

Normally, only Riverside staff will be able to see and process your personal information. However, there will be occasions when we will need to share personal information with third parties for the purposes as outlined or where we are legally required to do so.

We may communicate any information essential for the successful administration of the buildings, including any health and safety issues, with managing agents operating on our behalf. We may share the same information with other landlords (or managing agents acting on their behalf) who are involved in the joint management of properties.

We also share information:

• To allow us to tailor our services to you
• For detecting possible fraud (e.g. as part of the National Fraud Initiative)
• To deal with rent arrears (e.g. tracing and/or debt collection agencies)
• To deal with unpaid bills (e.g. utility or council tax bills) we may need to pass on your forwarding address
• To help us communicate with you (e.g. we sometimes use external printers, translators etc.)
• To assist the Police in solving crime and investigating anti-social behaviour.

As part of the government’s reform of welfare benefits, we can now share limited information about our residents and their properties with local authorities, for example, name, address, and National Insurance Number. This assists us in identifying and assisting those who may be impacted by welfare reform.

We will also disclose your personal details, if required to do so, by law or by any Government body.

Riverside contracts external organisations to manage certain areas of our business to fulfil our obligations as a social landlord. We share limited personal information of our residents with external contractors, such as name, address, and telephone number.

Examples include:

• Repairs and maintenance contractors (including Evolve)
• Out of hours call centre service
• Health and safety compliance checks (i.e. gas servicing, lifts, asbestos, legionella)

How long we will keep it

We keep information on our tenancy files for six years after the tenancy ends.

Experian rental exchange

Our purpose(s) for processing and lawful basis

We want to be able to assist you in improving your credit history. The Rental Exchange enables tenants with little or no credit history who pay their rent on time to build up a credit score.

Having additional information on your credit file can make it quicker and easier to:

• Open a new bank account
• Arrange a better utilities tariff, or qualify to pay for gas/electricity via a non-prepay tariff
• Apply for a mortgage

The legal bases which apply to the processing described above are:

• We rely on our, and your, legitimate interests to share your data for the Rental Exchange

How we use your information

Unless you choose to opt out/object, we will share selected information with the credit reference agency Experian to allow your rent payments to count toward your credit score.

We will not share any information before you are provided with specific notification and given time to object. We will respect your objection.

You can object to this processing by using this form.

Who we may share your information with

We will share the following information with Experian:

• Name, address, and date of birth
• Tenancy start (and end) dates
• Your required weekly or monthly rent payment
• Your actual weekly or monthly rent payment
• The total of any outstanding rent on your account
• If applicable, your Housing Benefit or Universal Credit payment amount

How long we will keep it

We keep information on our tenancy files for six years after the tenancy ends

You can read Experian’s Credit Reference Agency Information Notice here.

Regeneration

Our purpose(s) for processing and lawful basis

If you or your community may be impacted by planned regeneration work, we may collect information from you and other household members in order to better understand any needs you may have in regard to the regeneration. If you do not provide information, we may not be able to meet your housing needs and may not be able to provide an adequate level of service

The legal bases which apply to the processing described above are:

• Where we need to take measures to perform a contract we have entered into with you (provision of services set out in a tenancy or leasehold agreement);
• Where we need to comply with legal obligations (e.g. housing regulations, health and safety);

We may also use your sensitive personal data under the following legal bases:

• Where we have your consent (e.g. provision of additional benefits or services, information gathered through feedback or surveys).
• Where the processing is necessary in the public interest, including the monitoring of diversity and equality where we work with local authorities and monitoring equality of opportunity or treatment (where the data isn’t used to make decisions on particular individuals)
• Where we need to comply with social protection responsibilities (safeguarding of individuals at risk or where we gather health data to make sure your home is appropriate for your needs)

How we use your information

We will only use the information collected to:

• Ensure that we have accurate and up to date contact details for you, so that we are able to engage with you effectively
• Ensure that we are able to communicate in your preferred language or make any reasonable adjustments required to communicate with you
• Allow us to determine the relevant mix of housing required, based on the requirements collated through our engagement with you, and others
• Ascertain specific requirements such as aids or adaptations (based on physical health, or religious needs)
• Determine any demand for housing for specific populations, such as veterans and their families
• Inform the quality of the services and properties required, including financial viability of the regeneration
• Assist us in making decisions, developing policies, and designing and delivering services.
• Identify fraudulent activity

Who we may share your information with

We may share data with carefully selected third parties assisting us in the design and development of the regeneration project. If we do share data, we will only ever share the minimum amount required; and all third parties are contractually required to ensure that your data is secure and not used for any other purpose.

How long we will keep it

We keep information on our tenancy files for six years after the tenancy ends. You can also exercise your right to request that we erase all or part of your data (where it has been collected for the regeneration project and we do not have a legal obligation to retain it) at any time, though this may also impact the service we are able to provide.

Surveys

Our purpose(s) for processing and lawful basis

In order to provide our customers with the best service possible, Riverside may contact you for feedback.

In most instances the legal basis which will apply to the processing described above is

• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. maintaining security of our property, customer satisfaction surveys and market research).

Where our legal basis is legitimate interests, you are not obligated to complete surveys and can opt out of providing future feedback.

The Social Housing Regulator and Scottish Housing Regulator are legally obliged to monitor, assess, and report on how well Riverside and Riverside Scotland demonstrate compliance with regulatory standards., This means that we may occasionally also be required by law to conduct tenant perception surveys. In these instances our legal basis is:

• Where we need to comply with legal obligations (e.g. housing regulations)

You cannot opt out of surveys that we are required to conduct by law, though you are under no obligation to participate. It’s important to note that the responses to these surveys will ultimately be used to inform our approach to service delivery in the future, which is why it is important that you take the opportunity to have your say.

How we use your information

When making choices, developing policies, planning, and delivering services, we use survey data to monitor our commitment to listening to and working with our communities.

When you are asked to participate, you will be provided with more detail about the reason behind the survey in a separate privacy notice. Information collected in surveys will be anonymised and cannot be attributed back to you directly unless you:

• identify yourself to raise a comment or concern
• indicate you would like further support
• express an interest to participate in specific events or activities

Surveys may provide you the opportunity to provide feedback on:

• The quality and safety of your home
• Repairs and maintenance services
• Communal areas
• Our approach to keeping you informed
• Our approach to managing complaints
• If you feel you are being treated fairly and with respect
• If you feel Riverside is making a positive contribution to your neighbourhood and community

Who we may share your information with

We may share your contact data with carefully selected third parties to deliver electronic and paper surveys on our behalf. If we do share data, we will only ever share the minimum amount required; and all third parties are contractually required to ensure that your data is secure and not used for any other purpose.

Anonymised survey results will be shared with our regulators. They may also be shared with other organisations such as local authorities to inform research and analysis, develop and improve services and to help us (and other organisations) understand trends and requirements within the housing and Care and Support sectors.

How long we will keep it

We will keep anonymised data for as long as required to allow us to make informed decisions about survey results and to allow us to monitor and compare responses over a reasonable period of time.

If you have identified yourself to allow us to attribute feedback directly to you for the reasons listed above, we will keep any personal information you have provided on our tenancy files for six years after the tenancy ends.