1. WHO WE ARE
2. INFORMATION WE COLLECT ABOUT YOU
3. HOW WE COLLECT YOUR INFORMATION
4. HOW WE USE YOUR PERSONAL INFORMATION
5. WHO WE SHARE YOUR INFORMATION WITH
6. INTERNATIONAL TRANSFERS
7. HOW WE PROTECT YOUR INFORMATION
8. DATA RETENTION
9. YOUR RIGHTS
10. HOW TO CONTACT US OR MAKE A COMPLAINT
11. GLOSSARY
Your personal information is collected by Ocasa Management Limited (hereafter: Ocasa Homes), registered in England under company number 12075849. We respect your privacy and are committed to protecting your personal information.
We are providing this privacy notice to explain how we collect, use, share and protect your personal data when you visit our website, engage with us as a tenant, prospective tenant, visitor, contractor, supplier, or otherwise interact with us.
Ocasa Homes is the data controller for the processing that we undertake that is outlined in this privacy notice.
As the data controller, we are responsible for deciding how we hold and use the personal information we collect.
Throughout this document we refer to Data Protection Legislation which means the Data Protection Act 2018 (DPA2018), United Kingdom General Data Protection Regulation (UK GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any replacement or amending legislation in force from time to time.
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. Historic versions can be obtained by contacting us at privacy@ocasahomes.co.uk.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your information changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Children
While our website is designed for a general audience, we will not knowingly collect any data from children under the age of 13 or sell products to children. If you are under the age of 18, you are not permitted to use or submit your data to the website.
If we discover that we have collected any personal information from a child under the age of 18 we will suspend the associated account and remove that information from our database as soon as possible.
If you believe we might have any personal information from or about a person under the age of 18, please email us at privacy@ocasahomes.co.uk
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy notice.
If you fail to provide personal information
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Special categories of personal information
Some personal information is treated as falling into a special category. This includes information about health, disability, race, ethnicity, political opinions, biometrics or religion.
We will use your health data only where:
For example, we may process your health data to provide you with a home or residence that meets your particular needs.
We use different methods to collect data from and about you including through:
Please click the Cookie button in the bottom left corner of this page for further details.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
To find out more about the types of lawful basis that we will rely on to process your personal data refer to the Glossary
Purposes for which we will use your personal data
We have set out below a description of the personal data we collect, how and why it is collected and which of the legal bases we rely on to do so (including a description of the legitimate interest pursued). We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data, where more than one ground has been set out in the table below.
| Purpose/ Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer: (a) Create an account for you (b) Provide our products and services (c) Manage our systems (d) Prevent fraud (e) Send you marketing communications (f) Share this information with third parties if you have provided your consent to this | (a) Identity (b) Contact | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (d) Consent |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting of data, and anti-money laundering checks). | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content | (a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about products and services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
| Information that we collect incidentally from other sources or public sources, including information presented on our social media or wider social media platforms including Facebook, Twitter and Instagram, as well as websites where our properties are advertised, such as Rightmove or Zoopla. We use this information, including to: (a) Maintain market awareness (b) Build and maintain social media branding | (a) Technical (b) Usage (c) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business) |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Third-party marketing – we will not share your information with any third parties for the purposes of direct marketing.
Opting out – you can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Cookies – you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Please click the Cookie button in the bottom left corner of this page for further details.
Change of purpose – we will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
There are certain circumstances where we transfer your personal information to other parties. For example we will:
We share your information with certain contractors or service providers. They may process your personal data for us, for example, if we use a marketing agency. Other service providers include telephony providers (Aircall), advertising agencies, IT suppliers, database providers, backup and disaster recovery specialists, and email providers.
Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function. They will not be permitted to use your information for any purposes other than those outlined in this privacy notice.
We also share your information with certain third parties. We will do this either when we receive your consent or because we need them to see your information so we can provide products or services to you. These include:
If we are not able to share your information with these third parties, you will not be able to buy the products on our website.
Your personal information may be transferred to other third-party organisations in certain scenarios:
Your personal data may also be shared with third parties if it is made anonymous and aggregated. In such circumstances the information will cease to be personal data.
We share your personal data with our suppliers and service providers. This may involve transferring your data outside the UK. For instance, our telephony provider, Aircall, may host or allow access to call data in the European Union for the purposes of providing its cloud-based telephony and call recording services.
Whenever we transfer your information out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK.
For further information please refer to the ICO’s guidance on international transfers.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
WHow long will you use my personal information for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We have a Retention Schedule in place that outlines how long We will retain different categories of Personal Data. Ocasa Homes considers the retention period to begin from the point at which We last contacted you or otherwise reviewed your record to determine whether it was still active, unless otherwise required by law.
By law, we are required to retain certain basic information about our customers (including Contact, Identity, Financial and Transaction Data) for the current financial year plus 6 further years after they cease being customers, for tax and accounting purposes.
In addition to the general criteria above, we apply the following standard retention periods to certain categories of personal data:
Where personal data is retained for longer than the standard period due to an ongoing matter, access will be restricted to authorised personnel only and the data will be reviewed regularly to ensure that continued retention remains necessary and proportionate.
In some circumstances you can ask us to delete your data.
Sometimes we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out above, please contact us using privacy@ocasahomes.co.uk.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have any questions or complaint about this privacy notice or our privacy practices, please contact us at privacy@ocasahomes.co.uk.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Lawful Basis
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of a contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Consent means processing your data where you have freely given, specific, informed and unambiguous indication of your wishes.
Your Rights in Detail
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
We are committed to providing the information you request as part of your Data Subject Access Request and have procedures in place to ensure this occurs in a timely fashion.
We do not have agreements in place with any third-party platforms that offer “Data Subject Access Requests as a Service”. As a responsible data controller of your personal information this represents significant risks when sharing data. The right of access afforded to you, does not obligate us to share data with third-parties. It is our policy to provide the information directly to data subjects ensuring the safety and security of the information throughout the process.
We will monitor future guidance from the Information Commissioner’s Office but will follow our reasonable measures to verify the identity of data subjects. We would like to assure you that the protection of your data is our main concern and we are committed to providing information as part of any valid request.
This policy will also apply to the rights set out below.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.