Over 55s Privacy Notice

This is the Co-Own for Over 55s 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 from the time you apply to us until your relationship with us has ended.

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 (including potential income) and outgoings, details of your savings, your financial history, your employment status, a landlord reference (if applicable) and any dependants 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. If you have an existing (current) property we will ask you details about this property and the mortgage on it (if applicable).

We use the information you provide (and the information provided by any other applicants) along with information provided by a credit reference agency and other information about you that is in the public domain (in any format and on any platform) to assess whether Co-Ownership is suitable for you. If we think it is, we will also use the information to work out what level of rent 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 to administer the equity sharing lease between you & 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:

  1. Contract – The processing is needed because you have applied to us and if successful you will have a contract with us.
  2. Legal obligation – This is so that we can comply with certain laws.
  3. Consent – When you have consented to us processing your information.
  4. 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.
  5. Criminal Law Enforcement

4. The Purpose of Processing your Information and the associated Lawful Bases

Here we set out the way we process your information and also the grounds we rely on to do this.

Why we process your informationThe grounds we rely on to do this
We give you information on your applicationLegal obligation
We process and administer your application and verify your identity

Disclose data to any of the persons or organisations as set out in (6) below

Contract, Legal obligation and Criminal Law Enforcement
Assess potential customers to determine whether we can proceed with your application and on what terms and to determine whether you are suitable for our productContract, Legal obligation and Criminal Law Enforcement
To comply with legal and regulatory requirements to enable us to comply with and enforce any legal arrangements we have with you.

To enable our regulator and any other persons or bodies to whom we report to check how we provide our services and establish how we are performing.

Legal obligation, Consent, Legitimate interests and Criminal Law Enforcement
To share member’s rental payments with the Experian Rental ExchangeContract and legitimate interests
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 and surveys of customers to assess risk, model, and plan strategy & growth

Legitimate interests
To share information with local councils/Department for Infrastructure/Department for Communities/Northern Ireland Housing Executive in relation to reporting on affordable housing requirements or on climate change requirementsLegal obligation contract, legitimate interests

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:

  1. Legal, financial, estate agency, valuation and other professional advisers;
  2. Someone appointed by you to act on your behalf or someone who has statutory authority to act for you;
  3. Outsourced processing companies for example merchant payment supplier, payment services providers, external mailing company, archiving company, confidential waste disposal company, management companies, managing agents and valuation software;
  4. IT Maintenance personnel;
  5. The lender you currently have a mortgage with and its agents (if applicable);
  6. Debt tracing agencies;
  7. Our funders – the Department for Communities and our own lender;
  8. Our auditor
  9. Local councils, Department for Infrastructure, Department for Communities and Northern Ireland Housing Executive
  10.  External research agencies

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 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 use the information supplied to them in the future to assist other landlords and organisations to:

  1. Assess and manage any new tenancy agreements you may enter into;
  2. Assess your financial standing to provide you with suitable products and services;
  3. Manage any accounts that you may already hold, for example reviewing suitable products or adjusting your product in light of your current circumstances;
  4. Contact you in relation to any accounts you may have and recovering debts that you may owe;
  5. Verifying your identity, age and address, to help other organisations make decisions about the services they offer;
  6. Help to prevent crime, fraud and money laundering;
  7. Screen marketing offers to make sure they are appropriate to your circumstances;
  8. For Experian to undertake statistical analysis, analytics and profiling, and
  9. 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 may transfer the personal information we collect about you outside the UK to the countries in the European Union. If we do transfer your personal information, then we rely on the adequacy regulations that are in place in respect of those countries. This means that the countries to which we transfer your data are deemed to provide an adequate level of protection for your personal information.

8. How long does Co-Ownership keep 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

In certain circumstances you have the following rights in relation to your personal information:

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 Data Protection Officer.

Erasing your information:
You have the right to request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Object to processing:
You have the right to object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

Restrict processing of your information:
You have the right to request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your information:
You have the right to Request the transfer of your personal information to another party.

Right to withdraw consent:
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, request that we transfer a copy of your personal information to another party, or wish to withdraw your consent to our processing please contact the Data Protection Officer in writing. Please note that we may not always be able to comply with your request to exercise your rights under this section 9, for example, there may be a specific legal reason why we cannot comply. If we are unable to comply with your request then we will notify you of the specific reasons for this at the time of your request.

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, Moneda House, 25-27 Wellington Place, Belfast, BT1 6GD. Tel. 028 9032 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 Commissioner’s Office;

Information Commissioner’s Office,
Wycliffe House,
Water Lane,
SK9 5AF,
Helpline number: 0303 123 1113,
ICO website: https://www.ico.org.uk

13. Cookies

You can read more about how we use cookies on our Cookies page at https://www.co-ownership.org/the-small-print/cookies/

14. Changes to this privacy notice

We keep our privacy notice under regular review. This Privacy Notice was last updated in December 2023.