Privacy policy

This notice:

• Applies to personal data held by the Peabody Group (including Peabody Group Maintenance, Tilfen Land, and Charlton Triangle Homes) (Rosebury Housing Association and Town and Country Housing have separate notices on their websites).
• Applies to housing applicants, residents, tenants, leaseholders, community programme participants, care and support residents and anyone else who engages with Peabody.
• Explains how we collect/use your personal data, who we share it with and the legal basis for processing.
• Explains the choices you have about the data we hold about you – your privacy rights.
• Is kept up to date. You can find the latest version on our website (peabody.org.uk). If you would like a hard copy, please see the Contact Us section of our website and ask us to send you one

It is important that you read this statement so that you know how and why we use information about you. It is also important that you inform us of any changes to your personal information so that the information which we hold is accurate and current. 

Peabody is the “data controller” whose head office is located at 45 Westminster Bridge Road, London SE1 7JB.

If you have concerns about how we are dealing with your data, in the first instance, you should raise these with the Customer Hub or your key contact within Peabody.  If you are not satisfied with their response you can contact the Group Data Protection Officer at DPO@peabody.org.uk

We need your information to:

• determine your application relating to a tenancy/lease, or equity loan;
• provide services to you under the agreement we have entered into, or are proposing to enter into (including equity loans);
• provide any other services you have requested, or that relate to your housing needs;
• provide care and support services;
• facilitate participation in one of our community programmes or as part of your visit to one of our community centres;
• comply with our legal and regulatory obligations.

Without this information we may not be able to enter into an agreement with you or provide the services you want.

We collect most of our information directly from you when you engage with us, or as part of delivering our services.

We collect information from third parties, but only where is it relevant to our relationship with you and the service we are providing, such as: 

• Organisations that we contract with to provide services on our behalf (our data processors), for example, maintenance and repairs, customer surveys etc. – for information relevant to that service.
• Local councils and central government departments such as the Department of Work and Pensions – for information about your benefits
• Local authorities, health/social care professionals, previous care providers – for information about your health, care and support needs, and those of your household (including your children)
• Previous landlords - for your rental history
• Credit reference agencies – for credit checks and information about your financial status/history when you apply for any Peabody property or equity loan, for debt recovery purposes, and fraud investigations/data matching checks. For commercial tenants, we may carry out ongoing risk assessments on commercial viability using credit reference data
• Home Office, local authorities – for information about your immigration status
• Police and other public authority fraud departments, local authorities – for information on criminal activity
• Other residents – if we receive information in relation to complaints about behaviour
• Heat meter providers – where your heat/energy bills are included in your rent/service charge, we receive information about your energy usage
• Managing agents, where they manage properties on our behalf – information about rent/service charges, complaints, anti-social behaviour and repairs/maintenance
• Other service providers if we are working in partnership with them - usually information about care and support needs; or for community programmes, information about the use of that service.

We may process information that you post on social media about Peabody if it relates to a situation that we need to be aware of and/or take action on.

In some instances, we rely on the “legitimate interests” condition as our lawful basis to process your data.  You can object to this processing if you think your legitimate interests outweigh ours. We must tell you what we think our legitimate interests are; they are:

• Our services/properties meet the needs of our customers;
• We can contact residents in the event of emergencies and to carry out essential repairs;
• We can communicate with residents to meet our business objectives, encourage social inclusion and help build communities;
• We keep our estates safe, and we work with authorities/police to support safer communities;
• Peabody remains commercially viable, and protects its commercial and social assets;
• We have effective procedures for preventing, and managing, outstanding debt, for example from unpaid rents, service charges etc;
• We make the most efficient use of our resources, and we understand how we are performing; and
• We understand our residents’ experiences and views so that we can provide value for money and effectively contribute to debates on future housing strategies.

You have several rights which allow you to choose and control how we use your data. These rights are explained below. If you would like to exercise these rights, please see the Contact Us section of our website for details of how to get in touch with the relevant contact centre.

Transparency: You have the right to be informed about how we are using your data. If you think we are doing something with your information that we have not told you about in this Privacy Notice, you can object to this.

Access: You have the right to ask us what personal information we hold about you, and to request a copy.

Objection: You can object to the processing of your personal data. You should note that this right does not apply in all circumstances, for example, where we are processing information because it is necessary in the performance of contract we will not be able to stop processing this information.

Withdrawal of consent: if we are processing your data based on your consent, you can withdraw this consent at any time. Where this is the case we may no longer be able to provide the relevant service to you.

Rectification: If you think that the personal data we hold about you is inaccurate or incomplete, you have a right to request that it be rectified.

Erasure: You can ask us to delete your personal data where it is no longer necessary for us to use it, where you have withdrawn consent (if we process based on consent), or where we have no lawful basis for keeping it.

Restriction: You can ask us to restrict the personal data we use about you where you have asked for it to be erased or where you have objected to our use of it.

Data portability: You can request the transfer of your personal information to another party under certain circumstances.

Appeal: If you are not satisfied with the way that we have dealt with your personal data, please let us know and we will try and resolve your concerns. If you are not satisfied with the outcome, you can make a formal complaint through our website.

If you are still not happy with our response, you have the right to appeal directly to the regulator – the Information Commissioners’ Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113.

We do not usually gather information directly from children as part of our core landlord service. We may process information relating to children in our households where it has been provided to us during our relationship with you.   

We process information relating to children for our community programmes where we have the consent of parents/guardians to do so.

We may record your telephone calls to our Customer Contact Centres and Collections Teams, for training and monitoring purposes and to make sure we’re delivering a good service.  We do not record all calls. We process data in this way because it is in our legitimate interests to do so.

Peabody operates CCTV across its estates, community centres and Care and Support schemes. These systems are in place to protect the security of residents, customers, and visitors. 

We process this information because it is in our “legitimate interests” to do so.  Where a disability, your race/ethnicity or religious beliefs are clear from your appearance in CCTV footage, we process this based on the “public information” condition).

If you visit our website, we collect your Internet Protocol address. Peabody logs this information for internal review purposes. For example, this log information helps us determine how well our services are working so Peabody can continually improve the quality of its web sites. The log information is also important for security, audit, and quality improvement.

You may only use our wi-fi guest access for lawful purposes. Wi-Fi access may be monitored from time to time and any unlawful behaviour may be referred to the relevant authorities. You will be asked to sign up to our terms and conditions of usage every time you access guest Wi-Fi; this includes more information about use and privacy.

Occasionally, we may need to transfer your personal data outside of the UK to other subcontractors or agents. For example, if we were to use an IT service whose servers are situated abroad. Where this is the case, we will take the appropriate steps to ensure that we only contract with organisations that have the appropriate security measures in place.  We are required to tell you about these instances and the safeguards we rely on.  The following third-party providers hold some of our data outside of the UK. 

We use some of your personal data to identify relevant Peabody services that might be of interest to you. For example, if information suggests that you might be having difficulties with managing your finances/paying your rent, or you might encounter difficulties in the future, we may offer the services of our Welfare Benefits and Money Advice Team. Alternatively, if our information suggests that you might be a vulnerable tenant because of age, or ill health, we may offer you an enhanced service.

We sometimes use profiling information to contact you about community programmes you might be interested in.

We generally rely on the “legitimate interests” condition to process information for these purposes.

Our customers have the right to opt-out of any electronic contact (texts, emails, telephone calls) that are not directly connected to the reason Peabody collected their information in the first place.  The main reasons that Peabody collects contact details are to:

• Carry out core landlord functions
• Enable us to provide care and support service

This type of contact is “necessary” and cannot be opted out of.  Examples include communicating about repairs/maintenance, rent/service charges (including arrears), ASB issues, complaints, health and safety issues, updates about estates which impact residents, consultations, anything relating to the service we are delivering.

Non-essential communication

Examples of areas that do not generally fall into “necessary” communications are:

• Customer surveys
• Research projects
• Marketing
• Promoting non-commercial initiatives (e.g. sustainability, energy efficiency, financial advice)

Your rights

When communication does not relate to our core landlord function or care and support services, we will:

1. Not contact anyone who has already opted out of this type of contact
2. Give residents the option to opt out of any further contact.

If you would like to exercise this opt-out, please do so by calling our contact centre.

How long we keep your personal data depends on the type of data it is. We keep:

• Tenancy/leasehold/community programme files for up to seven years after our relationship ends, or the end of programme. 
• Care and support service information for up to 8 years after the end of service, or the last time a customer was seen. 
• Equity loan information for 12 years after the last payment was made.
• CCTV images for up to 31 days
• Telephone recordings for up to six months

For more detailed information about your retention periods, please ask to see our full Retention Schedule.

Data protection law says we need a "lawful basis" for collecting and using any information about you. There are a variety of different lawful bases for using personal data which are set out in law.  Below is more detail about how we use your data and the corresponding “lawful basis”.

Data processors

We share some information with our data processors, which are organisations that carry out a service on our behalf. This includes IT providers, repairs and maintenance, managing agents, gas servicing, credit reference agencies, heat meter providers etc. We only share the information which is necessary for them to carry out the service they have been contracted to provide. All our contractors operate under the terms and conditions of a contract and cannot legally use your information for anything other than carrying out a service on behalf of Peabody.

We share this information based on our legitimate interests to carry out the relevant service.

Managing agents

Where managing agents are acting on our behalf we may share any information with them that is necessary for the effective management of the buildings, including any health and safety issues. Where other Landlords (or managing agents acting on their behalf) are involved in the joint management of properties, we may also share the same information.

We do this because it is necessary for the performance of a contract or in order to fulfill our legal obligations. Where this does not apply, we normally do this on the basis of our legitimate interests.

Ministry for Housing, Communities and Local Government (”MHCLG”)

We share information about social housing lettings data with the MHCLG. It is a regulatory requirement for all registered providers to supply this data as per the Regulator for Social Housing’s “Tenancy Standard”. The Tenancy Standard is a non-statutory Code of Guidance which we are obliged to follow.

The data sets we share include information on lettings, type of tenancy, rents and charges, demographic information about tenants (including special category data and criminal convictions) and financial information. The data set does not include names or addresses but does include the unique property reference and the full postcode.

This information is used for research and statistical purposes to allow the MHCLG to exercise their role in providing adequate social housing. The information cannot be used for any other purposes, such as making decisions in relation to specific individuals.

We share this information because it is necessary for the performance of a task carried out in the public interest and/or for reasons of substantial public interest. Individuals are not able to opt-out of this processing.

MHCLG have their own Privacy Notice.

Others

Other organisations we may share your information with include

• Local authorities and safeguarding authorities
• Regulators and other organisations where we have a lawful obligation to disclose information (such as HMRC, Social Housing Regulator, and local authorities in relation to council tax/benefits)
• Police and other law enforcement agencies for the prevention/detection of crime
• Utility companies so they can provide services to you and contact you in respect of utility charges
• MPs and Councillors acting on your behalf
• Legal and other professional advisers
• Courts and other parties in court proceedings
• Subsidiaries and other entities in the Peabody Group, as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance, support, and hosting of data;
• Third parties in the context of the possible sale or transfer of services in which you are involved.

Core landlord services

We use your contact details to get in touch about your property or the service(s) you are receiving.  You cannot opt out of this type of contact.

Service providers

We may pass on your details to contractors that provide services on our behalf, so that they can contact you to carry out essential services related to your property (and sometimes communal areas). We do this because it is necessary for the performance of a contract. You cannot opt out of this type of contact.

Customer surveys

We’re constantly working to improve our services. One of the ways we do this is by listening to our residents and asking for feedback via surveys. These surveys are carried out by contractors who are specialists in customer feedback. In such cases, we pass on your contact details to them so you that they can contact you and ask about our performance. It is in our legitimate interests to use your contact details this way, however, you may opt-out of further contact by letting the person requesting feedback know that you do not wish to take part in future. Or you can opt out by calling our contact centre.

Peabody events/services

We also use your contact details to keep you updated about Peabody events or other services which do not form part of our contractual landlord service, but which may be of interest to you. This includes our e-newsletter and letting you know about things such as accessing training opportunities, energy efficiency, digital support, housing options events and financial advice. It is in our legitimate interests to use your contact details this way, however, you may opt-out of further contact by simply selecting the opt-out button in the email or text.  Or you can opt out by calling our contact centre.

We share some of our resident’s personal data with Experian, a consumer credit reporting agency. This is to help us prevent and detect fraud and illegal subletting, and to manage our rental arrears. We also receive information about you from Experian for the same purposes. We process this information to fulfil our legal obligations and to prevent/detect unlawful acts.

As part of the Rental Exchange Programme, we share your rental payment history with Experian. This programme allows tenants with a history of little or no credit, who are paying their rent on a regular basis, to build up a credit score. You can opt-out of the Rental Exchange Programme at any time by contacting us. Please see the Contact Us section of our website for details of how to get in touch with the relevant contact centre and we’ll opt you out. We exchange information as part of the Rental Exchange Programme because it is in our legitimate interests to do so. (Please note the Rental Exchange Programmes is not relevant to ex-Catalyst tenants).

If you would like more information you can visit the Experian website or call them on 0115 941 0888 and ask for a copy of the Rental Exchange brochure.

Peabody collects very limited personal data about its commercial tenants, as most of the information we collect is about your business. However, some personal data is collected about individual sole traders and individual shareholders and/or Directors of companies.

We collect most of our information directly from you when you apply, either directly to us or through our managing agent, to rent/lease a property for commercial business. We may also collect information about you, your shareholders and/or Directors from public sources using credit reference agencies. Information collected from credit references may also be used to carry out ongoing risk assessments on the commercial viability of commercial premises.

We use the information we hold about you, your shareholders and/or Directors to manage your tenancy or leasehold. We collect this information because it is necessary in the performance of a contract. We also process some of your data because it is in our legitimate interests to do so. You can object to this processing if you think that your legitimate interests outweigh ours.

Data protection law says we need a "lawful basis" for collecting and using any information about you. There are a variety of different lawful bases for using personal data which are set out in law.  Below is more detail about how we use your data and the corresponding “lawful basis”. 

Data processors

We share some information with our data processors. Our data processors are organisations that carry out a service on our behalf, for example, our IT providers. We only share that information which is necessary for them to carry out the service that they have been contracted to provide. All our contractors operate under the terms and conditions of a contract and cannot legally use your information for anything other than carrying out this service on our behalf.

Partnership working

Where we are working in partnership with another organisation to deliver a community programme, we may share your information with them; sometimes we are required to do this where we receive external grants or income from them.  Where this is the case we will let you know what information we share when you sign up to the programme.

Employment and training providers

If you have engaged with our Employment and Training Service and they are working with other organisations to support you, we may share information with them where it is necessary for delivering the agreed programme. We will share information relevant to your job applications and other employment opportunities (for example your CV) with job agents and organisations who may be interested in employing you, or supporting you into work. If you come to us through one of our referral partners (e.g. DWP, local authority, another housing association) we may share information with that partner to evidence your engagement with our service.

Others

Other organisations we may share your information with include:

• Local authorities and safeguarding authorities
• Regulators and other organisations where we have a lawful obligation to disclose information.
• Police and other law enforcement agencies for the prevention detection of crime
• MPs and Councillors acting on your behalf
• Legal and other professional advisers
• Courts and other parties in court proceedings
• Subsidiaries and other entities in the Peabody Group, as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance, support, and hosting of data;

We use your contact details to get in touch about the services we are providing. We may also use your details to let you know about other similar services we think you might be interested in. We do this because it is in our legitimate interests to do so. You can opt out of this type of contact by calling our contact centre.

Data protection law says we need a "lawful basis" for collecting and using any information about you. There are a variety of different lawful bases for using personal data which are set out in law. Below is more detail about how we use your data and the corresponding “lawful basis”.

Joint working

If we are working with other organisations or services to support you, we may have to share information with them. We only do this if we have a good reason to and it is necessary for delivering the agreed support. You can object to us sharing your information but this might mean that you don’t get all the services you need.

Local authorities/NHS

Where we are providing care and support services as part of a local authority/NHS contract, we may share your information with the commissioning local authority or NHS health trust.

Safeguarding

Sometimes we might have to share information with authorities if we think that you or someone else is at serious risk of abuse or harm. We don’t need your consent to do this.

Data processors

We also share some information with our data processors, which are organisations that carry out a service on our behalf, for example IT providers. We only share information which is necessary for them to carry out the service they have been contracted to provide. All our contractors operate under the terms and conditions of a contract and cannot legally use your information for anything other than carrying out a service on our behalf.

Others

Other organisations we may share your information with include

• Local authorities and safeguarding authorities
• Regulators and other organisations where we have a lawful obligation to disclose information (such as Care Quality Commission)
• Police and other law enforcement agencies for the prevention detection of crime
• MPs and Councillors acting on your behalf
• Legal and other professional advisers
• Courts and other parties in court proceedings
• Subsidiaries and other entities in the Peabody Group, as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance, support, and hosting of data;
• Third parties in the context of the possible sale or transfer of services in which you are involved.
• Third parties in the context of the possible transfer of services in which you receiving.

National Data Opt Out

We do not share any data for planning or research purposes for which the national data opt-out would apply. We review this on an annual basis and for any new processing.

We use your contact details to get in touch about the service we provide you. We may occasionally contact you to ask for feedback about how well we delivered your service.

Data protection law says we need a "lawful basis" for collecting and using any information about you. There are a variety of different lawful bases for using personal data which are set out in law.  Below is more detail about how we use your data and the corresponding “lawful basis”.

Local authority

We will share your data with the relevant local authority who we operate the equity loan scheme in conjunction with.

Data processors

We share some information with our data processors. Our data processors are organisations that carry out a service on our behalf, for example, our IT providers. We only share that information which is necessary for them to carry out the service that they have been contracted to provide. All our contractors operate under the terms and conditions of a legally enforceable contract and will not use your information for anything other than carrying out a service on our behalf.

Others

Other organisations we may share your information with include

• Regulators and other organisations where we have a lawful obligation to disclose information
• Police and other law enforcement agencies for the prevention detection of crime
• MPs and Councillors acting on your behalf
• Legal and other professional advisers
• Courts and other parties in court proceedings
• Subsidiaries and other entities in the Peabody Group, as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance, support, and hosting of data;
• Third parties in the context of the possible sale or transfer of services in which you are involved.

We use your contact details to get in touch about the equity loan.

This section applies to any member of the public who comes into contact with us in our day to day operations. It does not apply to residents, commercial customers, community programme participants or visitors to our community centres. Generally this contact is either through a routine enquiry or through a relationship with one of our residents/employees.

Data protection law says we need a "lawful basis" for collecting and using any information about you. There are a variety of different lawful bases for using personal data which are set out in law. Below is more detail about how we use your data and the corresponding “lawful basis”.

Data processors

We share some information with our data processors. Our data processors are organisations that carry out a service on our behalf, for example, our IT providers. We only share that information which is necessary for them to carry out the service that they have been contracted to provide. All our contractors operate under the terms and conditions of a legally enforceable contract and will not use your information for anything other than carrying out a service on our behalf.

Others

Other organisations we may share your information with include

• Local authorities and safeguarding authorities
• Regulators and other organisations where we have a lawful obligation to disclose information (such as Care Quality Commission, Social Housing Regulator)
• Police and other law enforcement agencies for the prevention detection of crime
• MPs and Councillors acting on your behalf
• Legal and other professional advisers
• Courts and other parties in court proceedings
• Subsidiaries and other entities in the Peabody Group, as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance, support, and hosting of data;

We use your contact details to get in touch about the enquiry you have raised.