This is the Privacy Notice of Northern Ireland Co-Ownership Housing Association Limited (Co-Ownership). It tells you about the information we collect from you, what we ask others to tell us about you and what we do with your information and who we share it with.
At Co-Ownership we treat your Data with the highest standards of security and confidentiality, in accordance with Data Protection Law.
When we collect Personal Data, about you and other people this Information will remain strictly confidential.
1. Why do we collect your Personal Data?
As you complete an application to Co-Ownership , we will ask you (and anyone applying with you) to supply personal information, including identity details, details of your income and outgoings, your financial history, your employment status, a landlord reference and any dependents you might have. If you are employed we may ask you to give us information from your employer. If you are self-employed we may ask you to give us information from your accountant or any person who deals with your accounts.
We use the information you provide (and the information provided by any other applicants) along with information provided by a credit reference agency to assess whether the Co-Ownership scheme is suitable for you. If we think it is, we will also use the information to work out what level of rent and mortgage payments we think you can afford.
We may also use the information you supply for research and management information purposes, to help us improve
- our services to you and other customers
- the effectiveness and efficiency of our business
- how our managers make decisions, and
- how we look after public funds.
If you are successful in your application we will use the information you give us as well as the information on the mortgage product you have selected to administer the equity sharing lease between you and us and also in connection with the purchase of further shares in the property.
2. Consequences of failure to provide Information
If we cannot collect necessary Information from you, it may make it impossible for us to process your application and enter into a contract with us.
3. The Lawful Grounds for Processing your Information
We process your information for lawful reasons. These are:-
- Contract – the processing is needed because you have applied to us and if successful you will have a contract with us.
- Legal obligation – this is so that we can comply with certain laws.
- Consent – When you have consented to us processing your information.
- Legitimate interests – this means that the processing is in our Legitimate Interests. We will not prejudice your rights when processing your information for our legitimate interests, and you have the right to opt out of our processing on this basis at any time.
- Criminal Law Enforcement
4. The Purpose of Processing your Information and the associated Lawful Bases
Here we set out way we process your information and also the grounds we rely on to do this.
|Why we process your information||The grounds we rely on to do this|
|We give you information on your application||Legal obligation|
|We process and administer your application and verify your identity||Contract, Legal obligation and Criminal Law Enforcement|
|Assess potential customers to determine whether we can proceed with your application and on what terms||Contract, Legal obligation and Criminal Law Enforcement|
|To comply with legal and regulatory requirements||Legal obligation, Consent, Legitimate interests and Criminal Law Enforcement|
|To share member’s rental payments with the Experian Rental Exchange||Contract and legitimate interests|
|Disclose data to any of the persons or organisations as set out in (7) below||Contract, Legal obligation and Criminal Law Enforcement|
|Identify and prevent fraud and enhance the security of our network and systems|
Comply with legal requirements relating to Anti-Money Laundering compliance
|Legal obligation and Criminal Law Enforcement|
|Understand how people interact with our websites|
Carry out and determine the effectiveness of advertising, and of marketing campaigns
Run promotional campaigns
Carry out analysis of customers to assess risk, model, and plan strategy & growth
5. Criminal Convictions and Offences:
Co-Ownership may hold, use, disclose and process Data relating to criminal conviction and offences where it is necessary for the assessment of risk or prevention of fraud.
6. Who Co-Ownership share your Information with:
In order to provide our services and comply with legal obligations imposed on us we may share your Information with:
- Legal, financial, valuation & other professional advisors;
- Outsourced processing companies for example merchant payment supplier, payment services providers and valuation software;
- IT Maintenance personnel;
- the lender you have a mortgage with and its agents
- debt tracing agencies
- our funders – the Department for Communities and our own lender
- our auditors
We will also share information you supply on your application with Experian, a credit reference agency, to verify your identity, and to assess whether the Co-Ownership scheme is suitable for you.
If your application is successful, Co-Ownership will report your rental payment information to with Experian’s Rental Exchange. This will allow you to establish or build credit history and will help you to access financial products and services and prove your identity. In the event that you do not pay your rent on time, your credit report may be negatively impacted.
Your track record with Co-Ownership will enable Experian to will use the information supplied to them in the future to assist other landlords and organisations to:
- assess and manage any new tenancy agreements you may enter into;
- assess your financial standing to provide you with suitable products and services;
- manage any accounts that you may already hold, for example reviewing suitable products or adjusting your product in light of your current circumstances;
- contact you in relation to any accounts you may have and recovering debts that you may owe;
- verifying your identity, age and address, to help other organisations make decisions about the services they offer;
- help to prevent crime, fraud and money laundering;
- screen marketing offers to make sure they are appropriate to your circumstances;
- for Experian to undertake statistical analysis, analytics and profiling, and
- for Experian to conduct system and product testing and database processing activities, such as data loading, data matching and data linkage.
We will continue to exchange information about you with Experian while you have a relationship with us. We will also inform Experian when that relationship has ended and if you have outstanding rental arrears Experian will record this outstanding debt. This information may be supplied to other organisations by Experian.
7. Transfer of Information
We will not transfer your personal data outside of the EU.
8. How long do Co-Ownership Housingkeep your Information?
When you apply to Co-Ownership, it may be necessary to retain your information for an extended period of time. We keep your information for as long as required for the purpose that you gave it to us for. For legal and best practice reasons we keep your information for 6 years after the date on which your contract with us ended. For more information please contact our Data Protection Officer
9. Your Rights
Accessing your Information:
You have the right to obtain a copy of your Personal Data. If you would like a copy of your information, please write to our Data Protection Officer. Your request will be dealt with as quickly as possible and in any event you will not have to wait for more than a month for us to respond. If at that stage we are unable to provide the data you require (due to the complexity or number of requests) we can extend the period to provide the data by a further two months but shall explain the reason why.
Correcting your Information:
You have the right to have your information corrected free of charge by contacting our our Data Protection Officer.
10. Automated Decision Making
An Automated Decision is a significant decision affecting you that is made using your Personal Data solely by automatic means, where no humans are involved in the decision-making process. We do not and will not make automated decisions affecting you based on profiling. An indicative conclusion may be reached on the basis of Personal Data you have provided, but a member of our team will always review this.
11. Who controls your Personal Data and how can you contact them?
Co-Ownership controls your Personal Data. Any questions or concerns you have can be addressed to our Data Protection Officer, Murray House, Murray St, Belfast, BT1 6DN. Tel. 028 903 7276 (In the interest of customer service and to ensure the accuracy of our records, calls may be recorded and monitored).
12. Your Right to Make a Complaint
If you are unhappy about the way we handle your Personal Data please contact our Data Protection Officer and we will do our best to address your concerns swiftly and resolve any issues you have.
If you have a concern about an Organisation’s information rights practices, you can report it to the Information Commissioners Office; 0303 123 11.
14. Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated in July 2018.