Sharing Owner and Access Owner Privacy Notice

To allow us to provide the service you would expect from us, we may process the following information about you:

• Name
• Address
• Previous address
• Telephone number
• Date of Birth
• E-mail address
• National insurance number
• Next of kin
• Physical and mental health
• Financial information including bank details
• Personal data relating to those living in your household
• Nationality
• Ethnic group

The reason we collect your information is:

• to undertake and perform our obligations and duties to you in accordance with the terms of our contract with you
• to enable us to supply you with the services and information which you have requested or expect from us
• to enable us to respond to your request for service or complaint made about our service
• to analyse the information we collect so that we can administer, support and improve our business and the services we offer
• to contact you in order to send you details of any changes to our services which may affect you
• for all other purposes consistent with the proper performance of our operations and business
• to contact you for your views on our services.

Your personal data will be securely stored electronically on computers, laptops and other devices which are password protected and encrypted.  Paper files will be stored in locked cabinets.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

Personal data

• We have a contractural obligation as outlined in your occupancy agreement
• We have a legal obligation to meet conveyancing requirements
• We have a legitimate interest as a sharing owner

Special category date

Explicit consent — you can withdraw this at any time by contacting us at business@horizonhousing.org

We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.

To view how long we keep your personal data, please visit our retention schedule here.

The information you provide to us will be treated by us as confidential.

We may disclose your information to third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:

• If we enter into a joint venture or merge with another business entity, your information may be disclosed to our new business partners or owners;
• If we instruct repair or maintenance works, your information may be disclosed to any contractor;
• If we are investigating a complaint, information may be disclosed to Police Scotland, Local Authority departments, Scottish Fire & Rescue Service and others involved in any complaint, whether investigating the complaint or otherwise;
• If we are updating ownership details, your information may be disclosed to third parties (such as utility companies and Local Authority);
• If we are investigating payments made or otherwise, your information may be disclosed to payment processors, Local Authority and the Department of Work & Pensions;
• If you are in breach of your occupancy agreement, we may share information with solicitors, sheriff officers or debt recovery services;
• While purchasing a property or a share in a property, your information will be shared with our solicitor;
• If we are conducting a survey of our products and/or service, your information may be disclosed to third parties assisting in the compilation and analysis of the survey results

We may receive the following information from third parties:

• Benefits information, including awards of Housing Benefit/Universal Credit
• Payments made by you to us;
• Complaints or other communications regarding behaviour or other alleged breaches of the terms of your contract with us, including information obtained from Police Scotland;
• Reports as to the conduct or condition of your tenancy, including references from previous tenancies, and complaints of anti-social behaviour;
• Information from third parties about support and assistance provided to sustain your occupancy and/or independent living

If your details change, please contact 0330 303 0089 or e-mail@horizonhousing.org to inform us to ensure that all of the information we hold about you is up to date.

You have the right to ask us for copies of your personal information. 

You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 

You have the right to ask us to erase your personal information in certain circumstances. 

You have the right to ask us to restrict the processing of your personal information in certain circumstances. 

You have the  the right to object to the processing of your personal information in certain circumstances . However, if Horizon can demonstrate that there is a compelling reason to process such personal data then we may refuse to stop processing your personal data

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.  

Please contact us at  business@horizonhousing.org  if you wish to make a request.  

How to complain 

If you have any concerns about our use of your personal information, you can make a complaint to us at Leving House, Fairbairn Place, Livingston, West Lothian EH54 6TN or by email at business@horizonhousing.org

You can also complain to the ICO if you are unhappy with how we have used your data.  

The ICO’s address:              

Information Commissioner’s Office  

Wycliffe House  

Water Lane  

Wilmslow  

Cheshire  

SK9 5AF  

Helpline number: 0303 123 1113  

ICO website: https://www.ico.org.uk