Privacy Statement

In this notice, whenever you see the words ‘we’, ‘us’, ‘our’, or ‘Sovereign’, it refers to Sovereign Network Group (formerly Sovereign Housing Association Ltd) and our subsidiary Sovereign Network Homes (formerly Network Homes Ltd). Our ICO registration numbers are ZA221241 for Sovereign Network Group and ZA191631 for Sovereign Network Homes.

We are a Registered Social Landlord (RSL) regulated by the Regulator of Social Housing.

As a Social Housing provider, our normal activities can be summarised as:

1. Providing social and other types of housing.
2. Property and grounds maintenance and repair.
3. Managing your housing, tenancy/lease and account as your landlord.

We also provide additional optional services including:

1. Organising and assisting community events.
2. Offering opportunities to be involved (co-regulation).
3. Providing welfare, benefits and debt advice (WBDA).
4. Adaptations made to the properties we manage.
5. Selling properties.
6. Homelessness prevention programmes.

If you have any questions in relation to this document or how we use your personal data they should be sent to: data.protection@sovereign.org.uk for Sovereign Network Group or dpo@networkhomes.org.uk for Sovereign Network Homes.

You can also contact us by post by writing to the Data Protection Officer at:
Sovereign Network Group
Sovereign House
Basing View
Basingstoke
RG21 4FA

Or

Sovereign Network Homes
The Hive
22 Wembley Park Boulevard
Wembley
HA9 0HP

We collect and hold personal information about:

Customers - This includes current, former and potential customers who live in our properties or access our support and other services and includes members of their family and people associated with them.

Visitors - Visitors to our website and our offices, those who email, call, message us via a social media application or write to us, including anyone who makes a complaint or enquiry to Sovereign.

We collect information in a variety of ways.

You can give us personal data by filling in forms provided by us, for example at tenancy sign-up, by registering to use our customer portal, by subscribing to take part in research on our website or other social media functions on our website, promotion or survey or by corresponding with us (by phone, email, chatbots, virtual agents, video triage, live chat agents or by joining as a customer).

We also collect information through our ongoing contact and correspondence with you, and with other support agencies which relate to you, and from people associated with you such as family, friends and neighbours.

Calls to our offices might be recorded.

We also record incoming and outgoing calls in our Contact Centre, this includes calls transferred to an internal line*.

At some schemes and offices we also have Closed Circuit Television (CCTV) surveillance cameras to record events in public areas.

If you provide us with personal information relating to members of your family or your associates we will assume that you do so with their knowledge and consent.

It is important that you notify us of any changes to your personal information as soon as possible so that we can contact you easily.

*We may monitor, record, store and use any telephone calls, CCTV recordings, email or other communication you provide, such as on our customer portal for example. This is to enable us to check any instructions given to us, for training purposes, and to improve the quality of our customer service. We only keep these in line with our Data Retention Schedule.

When you apply to become a Sovereign customer, we obtain information to determine your housing needs.

You will provide us with information through your application form. We will also use information from third parties such as other housing providers/private landlords, your mortgage lender (if you own/have owned your own home), the Police, the Probation Service, support workers, social workers, mental health workers and credit reference agencies where appropriate to help us to assess your application.

We will generally require the following information from tenants and leaseholders:

• Full name including proof of your identity / photo ID
• Date of birth
• National Insurance number
• Contact details, including telephone, email or contact address
• Details of anyone authorised to act on your behalf if applicable
• Personal Details of all household residents
• Banking or payment card details if you make payments to us
• Benefit and Council tax information
• Proof of housing eligibility.

Other personal information may be collected in order to help us resolve breaches of tenancy, alleged anti-social behaviour or suspected fraud.
We may also need additional information from you concerning:

• Disabilities or vulnerabilities – We use this information to tailor our service to better meet your needs. We may also use this information for safeguarding of staff.
• Health information – when we require this to support funding for adaptations made to the property you are living in. More specific details are provided if you use this service.
• Financial information –In order to ensure that arrears payments are settled quickly, we may collect additional information to help us to work out a payment plan with you. In addition, to provide welfare, benefits and debt advice as a free service to help you budget, pay your bills, or to apply for funding on your behalf.
• Identification – Photo ID, bank statements, payslips or income details may be used during the processing of a house sale or purchase.

We will record information whenever you contact us or use our services and we will note any action taken, for example logging repairs, and feedback from our contractors about appointments with you, so that we have a record of what happened and of our contact with you.

We will keep a record of your contact with us, whether by phone, email, chatbot, virtual agent, live agent chat, in writing or in person. This may include CCTV images, recording of calls to our Contact Centre, any requests or conversations that take place through our chatbot, virtual agent and live agent chat functionality and noting any action taken as a result of your contact with us. This could for example include the collection of a unique boiler ID to raise and carry out emergency repairs.

For visitors to the website, in order for our website to work correctly, we automatically collect the following information:

• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, make and model, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and if you access our website via your mobile device we will collect your unique phone identifier.
• Information about your visit, including, but not limited to the full Uniform Resource Locators (URL) and query string, clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as but not limited to scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number and the terms that you use to search our website.

Please note that certain services on our website won’t be available to you until you’ve registered to use our website, this includes our customer portals.

For further information please also see our website terms and conditions on our SNG website and Sovereign Network Group Cookie Policy on our SNG website and Sovereign Network Homes Cookie Policy on this website.

Some of our locations and offices have CCTV and you may be recorded when you visit them. CCTV is used to provide security and to protect both our visitors and communities. CCTV will only be viewed when necessary (e.g. to detect or prevent crime) and footage is stored for a set period of time after which it is recorded over. Sovereign Network Group complies with the ICO’s CCTV Code of Practice and we put up notices so you know when CCTV is used.

We may take photographs at our events, at our properties and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for those purposes with your consent, which is held within our Communications Team.

Your personal data will be collected and used to help us deliver activities or services or to complete a task raised at your request.

What we do with your information will depend on the nature of our relationship with you and how you interact with our various services, website and customer portals.

We use your personal information to allow us to:

Enter into, or manage any contract we have with you, including:

• Processing applications and requests for: Rental accommodation (including private market rent), Home ownership, Garage rental, Careline service, Keyworker accommodation.
• Managing tenancies including collecting rent and service charges.
• Ensuring compliance with the conditions of any agreement between us.
• Providing repairs, maintenance and adaptions at our properties.
• Providing home ownership products.
• Provide care and support for elderly and vulnerable customers.

Provide you with services and benefits in both our legitimate interests, including ensuring the proper management of your tenancy and giving you appropriate support:

• Offering help with debts and benefits advice.
• Assisting you in the management of account charges, payments and arrears, including through our online portal.
• Providing support services to help customers achieve their goals.
• Keeping in touch with customers to understand your needs and preferences and invite you to events.
• Providing information about Home Contents Insurance Schemes.
• Engaging with customers to make improvements to our products and services.
• Through desired channel of choice where support services are available via chatbot & live agent offering.
• Working with our partners including charities and local organisations to provide independent advice and advocacy services to support you.
• We have a legitimate interest in processing your data in connection with any mergers, acquisitions or reorganisation of our business. Consequently, we may share some of your data with a prospective target organisation but only so far as is strictly necessary.

Comply with our legal and regulatory obligations, and acting in the public interest, such as:

• Preventing and detect crime and resolve disputes.
• Preventing and detect fraud and money laundering.
• Promoting safety and the quiet enjoyment of our neighbourhoods and communities.
• Promoting equal opportunities and fair treatment for all our customers.
• Meeting the obligations we owe to our funders and regulators.

Under the data protection legislation certain personal information is classified as “sensitive” or "special category" personal data. This includes information relating to racial or ethnic origin, physical or mental health, sex life or sexual orientation, religious or philosophical beliefs, political opinions, membership of a Trade Union, allegations of criminal offences and criminal convictions and offences, along with biometric data such as fingerprints.

We minimise our holding and use of sensitive categories of personal information but, given the services we provide, there are times when we use it to understand our customers and their needs better, for example when providing accommodation for disabled persons or those with problems around substance abuse, when resolving neighbourhood disputes involving alleged criminal activity or when helping someone to access care services. We will usually be processing this information to allow us to comply with our legal obligations, act in the substantial public interest in relation to the services we provide, to provide you with social care, or to deal with any legal action. There may be times where we need to ask you for your consent to use this type of personal information, in which case we will always notify you and make this clear.

We do not usually process data on children aged under 18 that live in our properties, as all of our tenants are adults. However, we record children’s basic information if they are resident in one of our properties, including their name and date of birth. This is required for checking the property is not overcrowded and to assess other tenancy management issues where all householders and ages are required to be known.

We may also receive children’s information if we are involved in the housing and tenancy aspects of a welfare case as part of a multi-agency working solution.

Your personal information will be kept secure and confidential. Our staff and volunteers have restricted access to personal information on a “need to know” basis.

We may share information with third parties, including contractors we work with such as our repairs and maintenance contractors, third party cloud hosting and IT infrastructure providers, agencies and authorities we work with, such as Local Authorities, Social Services, Police, and other social landlords.

We will share certain information in appropriate circumstances with our regulators, funders, or purchasers or potential purchasers of our business. We will also share relevant information with others when Sovereign believes it is in your, or the public’s, interest to do so, such as to keep customers, staff or visitors safe, or as required by law.

In particular, please be aware:

• Current or forwarding addresses may be shared with utility companies and Council Tax offices to ensure billing details are correct.
• If you default on any tenancy/licence conditions, information about you may be provided to authorised debt recovery agencies, to enable them to recover the debt. This may affect future applications for tenancies, credit and insurance.
• We may discuss your financial situation, rent payments (including any arrears) and any claims made for welfare benefits with an external debt advice agency, welfare rights advisor, the housing benefit department or the local authorities’ housing advice and homeless prevention team to make sure that benefits are paid correctly.
• We may pass data about your rent payment record to credit reference agencies. This will enable them to assist other organisations to assess your financial standing if you apply for products and services.
• We may pass your contact information to a third party to conduct surveys and research on our behalf which allow us to gather feedback and improve the services we offer you. The third party will be bound to strict terms and conditions outlined by us and will not share your data with other organisations. Should you choose not to participate in the surveys the third party will securely destroy your data.
• We may share your National Insurance number to verify your Universal Credit application and manage these payments and to prevent and investigate tenancy fraud and right to buy applications fraud.
• We may share your data with our web services provider when using our chatbot, virtual agent and live agent functionality for the purpose of the transfer and storage of an interaction.

When we allow third parties acting on behalf of Sovereign to access to your information, we will always have complete control of what they see, how long they see it for and what they are allowed to do with it. We do not sell or share your personal information for other organisations to use.

CORE stands for Continuous Recording of Social Housing in Lettings and Sales (England). As a social housing provider, we are required by the Department for Levelling Up, Housing and Communities (DLUHC) to submit data on social lettings as part of the national monitoring requirements for allocation of social housing. It is a national information source that records information on the characteristics of both private registered providers and local authority new social housing tenants and the homes they rent.

This data is only provided to central government in a highly pseudonymised form which means that it is not instantly directly identifiable. The data is submitted through a website and only accessible by individual logins and passwords. The CORE dataset includes information on the letting or sale, type of tenancy or sale, rents and charges and demographic information about the tenant. The dataset in CORE does not contain direct personal identifiers but when taken as a whole the data allows social tenants to be identified. This is because the dataset may contain unique property reference numbers or even full postcode data. The dataset also contains information which is very sensitive and may be related to such information as whether the social housing tenant has been in prison or probation or referred by a mental health institution.

The data is protected by standards aligned with Government Security Standards. The legal basis for sharing this data is for carrying out a task in the public interest for research and analytical purposes. For more information or if you have any queries on CORE please contact dataprotection@communities.gsi.gov.uk or see their website and Privacy Notice.

We occasionally participate in the National Fraud Initiative (NFI) data matching exercise carried out by the Cabinet Office. Our participation in NFI assists in the prevention and detection of fraud against Sovereign and organisations within the public sector. We participate on a voluntary basis and provide the Minister for the Cabinet Office with particular sets of data for matching as detailed on the Government's National Fraud Initiative webpage.

We are also part of the National Anti-Fraud Network (NAFN) and therefore may share information with them as required.

The use of data by the Cabinet Office in a data matching exercise is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned. Data matching by the Cabinet Office is subject to a Code of Practice.

Further information on the NFI is detailed in the Cabinet Office’s fair processing notice.

Information system and data security is imperative to us to ensure that we are keeping your data safe.

We operate a robust and thorough process for assessing, managing and protecting new and existing systems which ensures that they are up to date and secure against the ever changing threat landscape. In addition to this, we follow a defence in-depth security model, which means that your data is protected by multiple layers of security.

Personal information is stored and managed within a variety of IT software systems which are maintained to achieve a high level of security and confidentiality. We hold information in IT systems which may be copied for testing, backup, archiving and disaster recovery purposes.

Our employees complete mandatory information security and data protection training at the start of their employment, and annually thereafter to reinforce responsibilities and requirements set out in our information security policies. Only those staff members and third parties who require access to your information will be able to access it.

When you trust us with your data we will always keep your information secure to maintain your confidentiality. By utilising strong encryption when your information is stored or in transit, we minimise the risk of unauthorised access or disclosure; when entering information on our website, you can check this is secure by right clicking on the padlock icon in the address bar.
Sovereign is based in the UK and we store most of our data within the European Union (EU). Some organisations which provide services to us may transfer data outside the European Economic Area but we’ll only allow this if your data is adequately protected.

We will only use and store your information for as long as it is required for the purposes it was collected for. How long information will be stored for depends on what it is being used for. Sometimes we may also need to keep information for statutory or regulatory purposes or to deal with any legal claims.

We will usually keep:

• any application for accommodation for 6 years following acceptance of the offer of accommodation
• housing benefit notifications and rent statements for 2 years
• information on your tenancy file for 6 years following the end of your tenancy with us
• care plans and related documents permanently, or until transferred to a subsequent provider
• chatbot and virtual agent interactions for 2 years
• live agent interactions will be placed on your tenancy file for 6 years following the end of your tenancy with us
• recordings of telephone calls for 6 months.

You have various rights in your personal data including the right in certain circumstances:

• to ask us for access to information about you that we hold
• to have your personal data rectified, if it is inaccurate or incomplete
• to request the deletion or removal of personal data unless there is a compelling reason for its continued processing, for example if we are required to retain it for statutory purposes, or to protect our legal interests
• to restrict our use of your personal data (i.e. permitting its storage but nothing further), although in some cases we will not be able to restrict our uses of your information, for example if we are required to process it for statutory purposes or to protect our interests
• to object to certain ways we use your information
• not to be subject to decisions made automatically through the use of technology and with no human consideration where it produces a legal or similarly significant effect on you
• to request that we transfer your information directly to a new landlord or other third party.

Further information about your data protection rights appears on the Information Commissioner’s website.

If you would like further information or to exercise any of these rights, please contact us.

We may sometimes process your data for specific purposes which require your consent. If we do this we will always ask for your written consent. Where we are processing your personal data based on your consent, you have the right to withdraw that consent at any time. This may affect the services that we can make available to you but this will be explained in the consent form. Please contact us if this is the case.

If you are unhappy with our use of your personal data, or anything in this notice, please talk to us directly so we can help to resolve any problem or query.

You also have the right to raise any concerns with the Information Commissioner’s Office (ICO). They can be contacted by post:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

By calling 0303 123 1113 or by email casework@ico.org.uk

Their website is www.ico.org.uk

This privacy notice was updated in September 2023 and subsequently will be updated to reflect changes either to the way in which we operate or changes to data protection legislation. We will bring any significant changes to your attention but to make sure that you keep up to date, we suggest that you revisit this notice from time to time.