Privacy policy

The Joseph Rowntree Housing Trust (JRHT) is:

• a charitable housing association registered under the Co-operative and Community Benefit Societies Act 2014
• a housing association and registered social landlord with the Regulator of Social Housing (registered number 5079) of The Homestead, Water End, Clifton, York, YO30 6WP
• a care provider regulated by the Care Quality Commission
• a controller of personal data.

We may ask you to provide some information so that we can confirm your identity. If other people (for example, family members, support workers, solicitors) act on your behalf, we will take steps to ensure that you have agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent and/or authority to act on your behalf. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.

We use your information to provide our services to you (or you to us) or to contact you and respond to your queries.

We use your information to keep in touch with you, let you know about changes, and to make sure the services we are offering are fit for purpose.

We will only use your personal information for the purposes for which we collect it. In limited circumstances we may use your information for a purpose other than those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it.

We may use your personal information for a new purpose if either this is compatible with the original purpose, we get your consent, or we have a clear obligation or function set out in law.

If you do not provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as making payments without your bank information).

We use your information in line with the UK General Data Protection Regulation (GDPR) and the Data Protection Act 2018. We refer to these as “the Data Protection Laws”. The Data Protection Laws require us to have a lawful basis for using your information.

The Data Protection Laws give you rights which you can use to manage your information to:

• request access to the personal information we hold about you
• request correction of your information if you believe it is incomplete or inaccurate
• request erasure of your information where there is no good reason for us continuing to process it
• object to processing your information where we are relying on a legitimate interest (or those of a third-party) and you want to object to processing on this ground
• request the restriction of your information if you want us to check its accuracy
• request the transfer of your personal information to another party in a useful format
• withdraw consent if we are processing your personal data based on your consent at any time.

Some of these rights only apply in specific circumstances or to a limited extent. If you would like to exercise any of your rights or talk to us about how your data is processed, please contact our Data Protection Officer. If you are not happy with the way we have handled your information you can complain to the Information Commissioner’s Office (ICO).

We do not currently and do not anticipate using any automated decision making (computer only decisions with no human interaction) on your personal information. We will update this notice if this changes.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered, disclosed, used or accessed in an unauthorised way. We limit access to your personal information to those employees, agents, contractors and other third parties who have a need to know. Third-party processors will only process your personal information on our instructions and where they have agreed to treat the information securely and confidentially.

We retain your personal information for the duration of your relationship with us and then for a period defined by legal, accounting, or reporting requirements. Copies of our retention scheme are available on request. Please contact our Data Protection Officer.

In some circumstances, we anonymise your personal information so that it can no longer be associated with you. In such cases, we may use anonymised information without further notice to you.

We update our privacy notices from time to time and these will be reflected on the website.

Please contact us to update us about any changes to your information and preferences.

• In this notice “you” refers to the tenant or prospective tenant and also anyone that lives with you.
• If you have children we will process personal data about their ages, gender and any disabilities or additional needs they may have that might require adaptations to the housing.
• We use your personal information to enable us to deliver services and manage your relationship with us as your landlord.
• In performing our role as your landlord, JRHT may use personal and sensitive information about your health, racial and ethnic origin, sexual orientation and religion to ensure our services are accessible.
• We may share your data with third parties, including third-party service providers, for legal reasons or to enable them to deliver services on our behalf.
• We respect the security of your data and treat it in accordance with the law.
• We will not collect information about you that we do not need.

This statement does not form part of any tenancy agreement or contract to provide services. However, some of the information you give us is required for us to provide our services in accordance with your tenancy agreement or lease. Without this information we may not be able to deliver the services that we are contractually obliged to provide, or to improve our services to meet current, prospective or former residents’ needs.

We collect information about you which is relevant to your contract or application with JRHT, either for housing or for use of our services.

This includes:

• your name and date of birth
• contact details such as your address, telephone number and email
• confirmation of your identity such as your National Insurance number
• information about your family and others, such as dependants, next of kin and emergency contact numbers
• information about your income and other financial circumstances, including rent payments and debts
• employment status
• your views on our services and/or why you need to access a service
• photographs, CCTV footage and noise recordings.

We also collect special categories of personal data. Special categories of personal data require a higher level of protection.

We occasionally collect:

• information about your race, ethnicity or religious beliefs as part of our regulatory obligations in respect of statistics and contractual obligations relating to land bequeathed to us (where certain religious groups are offered priority for certain housing to reflect the wishes of the land’s donors)
• information about your health, including any medical condition, health and sickness records, access requirements or assistance you may need
• information about criminal convictions and offences or concerns about behaviours which may present a risk to you and others.

We gather this information from:

• you
• third parties including previous landlords and employers
• GPs and other healthcare providers
• the Department for Work and Pensions
• providers of other financial information in relation to your personal circumstances
• statutory bodies such as the police, social services, or local authorities
• voluntary and other organisations who may be involved with your household in some way, such as providing support or advice
• mediation services
• information obtained about you in the course of your occupancy and through the provision of the services we provide including from neighbours and people in the community
• our employees and advisers including recordings of calls made to or from our customer contact centre.

We use your information for:

• making a decision about an offer of a property, affordability of a property, eligibility for benefits, eligibility for services, or identifying support needs
• providing you with services, managing your relationship with us as your landlord, determining any specific service requirements (for example aids and adaptations to your home, preferred contact arrangements, religious preferences) and determining eligibility for those services
• identifying any support you may need, for example, for residents in our sheltered housing
• dealing with complaints, such as gathering evidence in relation to any complaints made by or about you
• dealing with legal disputes involving you
• supporting you to maintain your home and manage your tenancy or part ownership in line with your tenancy agreement with us
• supporting you in making arrangements for the termination of your tenancy agreement
• resolving issues and disputes which may involve you, for example, use of CCTV footage
• keeping you up to date about services we provide including money and benefit advice, or signposting you to other specialist services
• informing you about activities or events that are directly relevant to you such as resident involvement opportunities, annual meetings and events in your community
• taking feedback to review and improve the services we provide to all our customers.

We may use this information on occasion in an anonymous form, to report on general information about JRHT services and residents, for example, the number of residents who need adjustments to services. The data will be anonymised and it will not be possible to identify individual residents from these reports.

We will use information about your physical or mental health, or disability status, to help support you in your home and to help determine your service and accommodation needs, for example, for residents of sheltered housing or adapting a property to make it more accessible.

We will use information about your religious, philosophical or moral beliefs and any of the protected characteristics or other sensitive information about you to adapt our services to meet your service requirements and/or to determine service eligibility. For example, some of our housing is on land bequeathed to us and certain religious groups are offered priority for certain housing, to reflect the wishes of the land’s donors.

We will use information about your ethnicity, religion, disability, and sexual orientation for statistical purposes, to help us understand who is living in our housing. We use this data internally to ensure meaningful analysis of the services we are providing and also to meet the regulatory obligations to which we are subject.

We will only collect information about criminal convictions if it is appropriate, given the nature of your application for rehousing or current occupancy, and where we are legally permitted to do so. We may also be notified of such information directly by you in the course of your occupancy. We use information about criminal convictions and offences to determine eligibility for our services and our accommodation.

We may make notes on your file called ‘markers’ in relation to your vulnerability, service requirements, or behaviour to enable us to deliver services to you that meet your needs, and to identify any measures we may need to put in place to protect you, other residents and our staff. We will inform you if this is the case and we will regularly review all such markers.

In accordance with the Data Protection Laws, we need a lawful basis for collecting and using information about you.

There are 6 different lawful bases and for the purpose of housing we use the following:

• using your information in this way is necessary for us to perform the contract, such as tenancy agreement or lease
• using your information is necessary for us to comply with legal and regulatory obligations to which we are subject, such as contacting you to perform checks on equipment
• using your information in accordance with our legitimate interests, or those of a third-party, and your interests and fundamental rights do not override those interests, such as keeping our sites and staff safe by using CCTV
• you have given us your consent to use your information for a particular purpose, such as contacting you about updates to our service by email
• we need to use your personal information to protect your interests (or someone else’s interests) in a life or death situation
• we need to use your personal information in the public interest, such as to prevent or detect unlawful acts.

Special categories of personal data (those which are particularly sensitive) require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data.

The lawful basis on which we rely in order to use your special categories of personal data which we collect about you are:

• it is necessary in order for us to comply with our legal obligations in our role as your landlord, such as the Equality Act 2010
• you have provided your explicit consent to our use of your information
• using your information is necessary in relation to the provision of health and social care
• we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our legal or regulatory obligations.

We may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We share your personal information with third parties where required by law, for example to HMRC, the police, and other regulators such as the Charity Commission in the following circumstances:

• the prevention or detection of crime and fraud
• the apprehension or prosecution of offenders
• the assessment or collection of tax or duty owed to customs and excise
• sharing in connection with legal proceedings
• sharing in relation to the physical or mental health of an individual where disclosure is required to protect them or others from serious harm
• to the Ministry of Housing, Communities and Local Government (MHCLG) for research and statistical purposes.

We also share your personal information with third parties in the following circumstances:

• to third-party services providers (including contractors and designated agents) such as maintenance contractors to make appointments with you to carry out repairs or deliver services
• organisations who provide response services in addition to that provided by JRHT, for example, Tunstall and Be Independent
• other housing providers to which you may apply for re-housing
• welfare benefit providers and organisations who provide financial support
• solicitors and specialist advice organisations processing applications, requests, enquiries on our behalf or at the request of a resident
• Housing Ombudsman and other regulatory bodies either acting on behalf of a resident or JRHT
• emergency services and the local authority in the event of an emergency
• members of parliament or councillors acting on your behalf.

The information you provide will not be sold, leased or rented to parties outside of JRHT. All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies.

JRHT uses photographs in internal communications to staff and in communications with residents to illustrate what we do on our website or on social media.

When we take photographs that are specifically of you, we will always ask you to sign a consent form before we use them. This is so that residents are clear about how we will use the photographs now and in the future. We will not use these photographs on our websites, in social media or in our externally facing publications, unless residents have specifically agreed for us to do so.

We also need to store a signed consent form, so that we know for which purposes residents have consented to us using the photographs. Photographs and consent forms will be stored securely on our IT systems and will only be available to staff who need access to them to do their job. Photographs and consent forms will usually be deleted after 2 years. We may keep a small number of photographs for our office archive to use for anniversaries or other milestones.

Photographs which are used in publications will be visible in those for the lifetime of the publication.

If a resident wishes to withdraw consent for us to use these photographs, they can contact the Data Protection Officer.

We do not gather information directly from children but we process information relating to children in your household when you provide it to us. For example, when you apply for housing you will be asked for your children’s ages, gender and whether they have any disabilities. This is so that we can assess the most appropriate housing for you and your family and whether we need to make adaptations to our housing to support your children. We do this for the same purposes and under the same lawful bases as set out above.

• As part of the services we offer, we are required to process personal data about our residents and, in some instances, the friends or relatives of our service users.
• We respect the security of your data and treat it in accordance with the law.
• We take particular care of special category data such as health information.

Residents

If you are a resident, we collect the following types of data about you:

• your basic details and contact information including your name, address, date of birth and next of kin
• your financial details including details of how you pay us for your care or your funding arrangements
• your preferences, likes and dislikes, information about your life such as whether you have a spouse or relatives, what job you used to do, and any hobbies you enjoy
• your image on CCTV around our premises.

We also collect the following data which is classified as special category personal data:

• health and social care data about you, which might include both your physical and mental health data. Your GP Record but only with your consent.
• dietary requirements (which may indicate religious beliefs).
• data about your race, ethnic origin, sexual orientation or religion.

Friends and relatives

We collect and use your basic details including your name, contact information and address.

We gather sources of personal information from:

• you
• your health and social care providers including doctors, community nursing, and existing care providers
• NHS England via a secure service called GP Connect
• your family and friends.

We use your information for:

• providing high-quality care and support
• liaising with your health care providers such as local hospitals or social services
• collecting your medication from the pharmacy or arranging vaccinations
• keeping your relatives and friends up-to-date
• keeping our residents and sites safe
• liaising with the local authority regarding funding
• managing our trust staffing levels, responding to queries, and complaints
• providing information to regulators such as the Care Quality Commission and Charity Commission
• providing information to emergency services such as the police and ambulances in the event of an emergency.

In accordance with the Data Protection Laws, we need a lawful basis for collecting and using information about you.

There are 6 different lawful bases and for residents’ personal information we use the following:

• we are required to do so in order to fulfil a contract that we have with you
• we have a legal obligation to do so under the Health and Social Care Act 2012 or Mental Capacity Act 2005
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Special categories of personal data (sensitive information about you) require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data.

The lawful basis on which we rely in order to use your special categories of personal data which we collect about you are:

• it is necessary due to social security and social protection law, for example in safeguarding instances
• it is necessary for us to provide and manage social care services
• we are required to provide data to our regulator, the Care Quality Commission as part of our public interest obligations, or (where appropriate) with your consent.

If we need to ask for your permission to provide data to our regulator, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent. We do this so that we can give everyone an equal opportunity to access our services and also so we can understand you and your particular needs better. For example, we will ask if you have religious beliefs that affects your dietary preferences or wishes to celebrate (or avoid) certain festivals.

At this time, we do not share any data for planning or research purposes for which the national data opt-out would apply. You can read more about the national data opt-out.

Friends and relatives

We process your data because we have a legitimate interest in holding next of kin and lasting power of attorney information about the individuals who use our service, so that we can contact you about your relative or friend’s care, or in the case of an emergency.

We also have a legitimate interest to share your contact details with third-party organisations for the purpose of inviting you to take part in surveys designed to give relatives and friends an opportunity to express their views about the services JRHT provides for our care residents. The survey results will be used to improve the quality of the services we provide.

We may also process your data with your consent. If we need to ask for your permission, we will offer you a clear choice and ask that you confirm to us that you consent. We will also explain clearly to you what we need the data for and how you can withdraw your consent.

We share your personal information with third parties in the following circumstances:

• where required by law, for example, to the Care Quality Commission, Charity Commission, or the police
• to health care providers such as local hospitals, social services, or pharmacies
• keeping your relatives and friends up to date with the local authority regarding funding
• with emergency services such as the police or ambulances in the event of an emergency
• to third-party service providers (including contractors) such as IT service providers, auditors, legal advisers, banks or other financial institutions.

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies.

• We use third-party service providers and some of your information will be shared with them.
• We respect the security of your data and treat it in accordance with the law.
• We may transfer your personal information outside the EU and, if we do, you can expect a similar degree of protection in respect of your personal information.
• This statement does not form part of any license agreement or other contract to provide services.
• We may update this statement at any time.

We collect the following types of data about you:

• your name and business contact details
• where necessary, your car registration number
• where appropriate, confirmation of your identity such as a copy of your driving licence
• if you are self-employed, information about your tax status such as HMRC records of self-assessment and bank details
• any feedback about your service including complaints or claims information
• security information such as CCTV footage, swipe card information, or number plate recognition.

We gather sources of personal information from:

• you
• credit reference agencies
• trade references
• your colleagues.

We use your information for:

• making a decision about procuring goods or services
• determining payment terms and making payments
• dealing with complaints or claims involving you or your business
• to keep our sites safe, prevent fraud, and manage parking and deliveries
• managing any proposed restructuring, transfer or merging of any or all parts of our Trusts, including to respond to queries from the prospective merging organisation.

In accordance with the Data Protection Laws, we need a lawful basis for collecting and using information about you.

There are 6 different lawful bases and for supplier personal information we use the following:

• it is necessary for us to perform or enter into the contract between us
• it is necessary for us to comply with legal and regulatory obligations to which we are subject
• it is necessary to our legitimate interest of keeping our sites and colleagues safe and running our charity effectively.

We may use your information for a purpose other than those set out in this policy but only where that complies with the Data Protection Laws.

We share your personal information with third parties in the following circumstances:

• where required by law, for example, to HMRC, the police, or regulators such as the Charity Commission
• to third-party service providers (including contractors and designated agents) such as IT service providers, auditors, legal advisers, banks or other financial institutions to facilitate payments and contractors or prospective merging organisations who work on our systems.

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies.

• We process a significant amount of information about employees including special categories such as health and criminal records information.
• We respect the security of your data and treat it in accordance with the law.
• We take particular care of special category data such as health information.
• We collect and process different information as you progress through recruitment with us.

Recruitment

We process the following types of data about you:

• your name and contact details
• identity information such as your date of birth and gender
• your previous experience and education
• information about you on publicly available sources such as LinkedIn
• your referees
• answers to questions relevant to the role you have applied for
• notes from interviews.

Conditional offers

If we make a conditional offer of employment, we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the UK and seek assurance as to their trustworthiness, integrity and reliability.

You will therefore be required to provide:

• proof of your identity
• proof of qualifications.

You will be asked to attend our office with original documents and we will take photocopies. We will contact your referees, using the details you provide in your application, to obtain references and information on your trustworthiness, integrity and reliability. Your referees may be asked follow up questions on these areas if anything is unclear or uncertain.

Confirmed, unconditional offers of employment

We will process the following:

• comments, queries or concerns you have in relation to the offer being made and our response(s) to such correspondence
• bank details to process salary payments
• HMRC starter checklist to ensure you are placed on the right tax code and where applicable, capture any student loan data
• emergency contact details so we know who to contact in case you have an emergency at work.

Unsuccessful candidates

If you are unsuccessful following either shortlisting or interview/assessment for the position you have applied for, we will only keep the personal data you provided for the application process for a period not longer than 12 calendar months from when we last processed your application.

We may on occasion ask if you would like your details to be retained in our talent pool for the purposes of contacting you in the future, should other suitable vacancies arise. This would be for an initial period of 12 months after which we would contact you again to ask the same question. Should we receive no response to this request then your details will be removed.

As your employer, we will need to keep and process additional information about you for employment purposes, including:

• your contract of employment and any amendments to it
• correspondence with or about you, for example letters to you about a pay rise or, at your request, a letter to your mortgage company confirming your salary
• information needed for payroll, benefits (which may include pensions) and expenses purposes
• your contact and emergency contact details
• records of holiday, sickness and other absences (including the reason(s) for such leave)
• records relating to your career history, such as training records, appraisals, other performance measures and, where appropriate, disciplinary and grievance records
• user IDs and passwords
• information captured or recorded by CCTV, electronic card access, IT access logs, vehicle tracking, and dashcam footage
• your image for staff intranet and ID purposes
• comments, queries or concerns you have in relation to your employment and our response(s) to such matters
• your image for promotional work or bids.

We gather this information from:

• you (including your use of JRHT systems)
• recruitment agents
• publicly available sources such as LinkedIn or social media
• your referees and previous employer
• the Disclosure and Barring Service (DBS)
• Occupational Health and other necessary sources.

You will be asked to provide equal opportunities information. This is not mandatory information. If you do not provide it, it will not affect your application or employment. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide will be used only to produce and monitor diversity statistics.

Dependent upon the role, we may contact you to complete a DBS application. You will be sent an electronic link to facilitate this in addition to providing original forms of ID (further ID information is provided at the time of offer). Your DBS ID will be retained on your staff file, and if you do not consent to your ID being retained you must notify us in writing.

We will ask you to complete a questionnaire about your health. This is to establish your fitness to work. The Occupational Health form may be shared with Occupational Health providers who may ask for access to your GP records. Where necessary, we may process information relating to your health, which could include reasons for absence and GP reports and notes. We will use this for internal monitoring of sickness absence.

Dependent upon the role, we may ask you to provide evidence of your Covid-19 vaccination or exemption status.

You will be asked to complete a criminal records declaration to declare any unspent convictions.

In accordance with the Data Protection Laws, we need a lawful basis for collecting and using information about you.

There are 6 different lawful bases and for the purposes of employment we use the following:

• using your information in this way is necessary for us to perform (or enter into) the employment contract between us
• using your information is necessary for us to comply with legal and regulatory obligations to which we are subject (such as DBS checks and meeting statutory requirements to make reasonable adjustments)
• using your information in accordance to our legitimate interests, or those of a third-party, and your interests and fundamental rights do not override those interests (such as keeping our sites and staff safe by using CCTV)
• you have given us your consent to use your information for a particular purpose (such as using your photograph for publicity).

Special categories of personal data (personal information that is sensitive in nature) require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information.

The additional lawful basis on which we rely in order to use your special categories of personal data which we collect about you are:

• it is necessary for your/our obligations and rights in the field of employment and social security and social protection law, such as to comply with our health and safety and occupational health obligations
• you have provided your explicit consent to our use of your information, such as your background checks, or use of your photograph
• it is necessary for reasons of substantial public interest
• it is necessary for preventive or occupational medicine, for the assessment of the working capacity of the employee, for example, to administer and manage statutory and company sick pay.

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

We share your personal information with third parties where required by law, for example, to HMRC, the police, and other regulators such as the Charity Commission in the following circumstances:

• the prevention or detection of crime and fraud
• sharing in connection with legal proceedings
• the assessment or collection of tax or duty owed to customs and excise.

We may also share your personal information with:

• third-party service providers such as Occupational Health, the Disclosure and Barring Service, IT support, and CCTV processing
• advisors such as accountants, solicitors, and insurers
• organisations processing applications, requests, and enquiries on our behalf or at the request of a resident.

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies.

We share the personal information of JRHT Directors and of the 5 highest paid non-executive employees with the US Tax authorities for the purpose of maintaining our status as an exempt foreign private foundation, which minimises the tax withheld on income arising from our US investments.

We may also share data when managing any proposed restructuring, transfer or merging of any or all parts of our Trusts, including to respond to queries from the prospective merging organisation.

Should you leave our employment, we are required to keep any data that relates to PAYE (pay as you earn) for a period of 7 years after the end of the tax year from the date of leaving. A full list of retention dates of documents that may have been held on your staff file is available on request.

• We respect the security of your data and treat it in accordance with the law.
• We take particular care of special category data such as health information.
• Depending on the nature of your query we may need to share the data with another party such as our insurers or advisers.

We record the following information about you:

• your basic details and contact information, for example, your name, address, telephone number and email
• the nature of your query or complaint
• the details of others involved.

We gather sources of personal information directly from you.

We use your personal information for the purpose of considering and investigating your complaint. We create a case file so we can track and report back to you on our actions.

We need to know the details of your complaint so we can fully investigate it and put things right if we’ve got something wrong.

We will use your personal information to investigate your complaint and check on our level of service. We compile statistics to show information like the number of complaints we receive, but not in a form that identifies anyone. We may also use your contact details to ask you to complete an anonymous follow up survey.

If you are acting on behalf of someone making a complaint, we will ask for information about you to prove your identity, and, if relevant, ask for information to show you have authority to act on someone else’s behalf.

In accordance with the Data Protection Laws, we need a lawful basis for collecting and using information about you. There are 6 different lawful bases, and for complaints we are required to collect your personal information in order to fulfil a contract that we have with you, for example, a tenancy agreement.

If the information you provide us in relation to your complaint contains special category personal data, such as health, religious, race or ethnicity information, the legal basis we rely on to process will be:

• it is necessary in order for us to comply with our legal obligations in our role as your landlord
• you have provided your explicit consent to our use of your information
• using your information is necessary in relation to the provision of health and social care.

We share complaints personal information with third parties in the following circumstances:

• where required by law, for example, the police, or regulators such as the Care Quality Commission or Charity Commission
• to seek a resolution to your complaint to external parties such as the Housing Ombudsman
• to third-party service providers such as auditors, legal advisers, insurers and IT service providers.

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies.

• We use cookies on our websites and these collect personal data.
• If you sign up to marketing from us we will ask for your consent and you can change this at any time.
• Information is shared with third parties providing services to us.

We process the following types of data when you browse the website:

• your cookie preferences, IP address and location of your device
• how you found our website and how long you stay
• your name and contact details
• how you use our website and interact with any communications from us (including whether you open emails from us)
• queries or comments you send to us including survey or questionnaire feedback.

We gather this information from you or from cookies placed on your browser.

• respond to your queries, send you newsletters and other information you may request
• monitor and produce statistical information regarding the use of our website and its contents, to analyse and improve functionality
• manage any proposed restructuring, transfer or merging of any or all part(s) of our Trusts, including to respond to queries from the prospective merging organisation.

In accordance with the Data Protection Laws, we need a lawful basis for collecting and using information about you.

There are 6 different lawful bases and for website browser personal information we use the following:

• it is necessary for us to perform or enter into a contract between us
• it is necessary for us to comply with legal and regulatory obligations to which we are subject
• we have a legitimate interest to keep our website running effectively, responding to queries or comments, or letting people know about the important work of the Trust
• in limited circumstances and with your consent, for direct email marketing and the placement of non-essential cookies on your browser.

In limited circumstances we may use your information for a purpose other than those set out in this policy, but only where that complies with the Data Protection Laws.

We do not collect special category data when you browse the website.

We share your personal information with third parties where required by law, for example, to HMRC and other regulators such as the Charity Commission or the police in the following circumstances:

• the prevention or detection of crime and fraud
• sharing in connection with legal proceedings
• the assessment or collection of tax or duties owed.

We also share your personal information with third-party service providers (including contractors and designated agents) such as IT service providers, auditors, legal advisers, banks or other financial institutions or prospective merging organisations to facilitate payments and contractors who work on our systems. All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies.