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whg SALES CUSTOMERS’ PRIVACY NOTICE

whg needs to hold and process information about you and your circumstances.  Some of this information is personal data; this means it can be used to identify you.  The law gives you rights around what happens to this personal information.

This Privacy Notice is for prospective purchasers of homes for shared ownership.  It tells you who we are, what information we will collect, how we will use it, how we will keep it and who we will share it with.

About whg

whg is a Data Controller registered with the Information Commissioner’s Office, registration reference Z667510X.  

“whg” means Walsall Housing Group Limited, a registered provider of social housing.  Our registered company address is 100 Hatherton Street, Walsall WS1 1AB. 

More information about the organisation can be found on our website at www.whg.uk.com or please ask a colleague from the Sales team.

The Data Protection Officer for whg is Helen Lane.  She can be contacted on 01922 426917 or This email address is being protected from spambots. You need JavaScript enabled to view it.

What information we process about you and why

This is the information we will collect/process and how we will use it:

DATA WE PROCESS

PURPOSE

Your name and contact details (address, phone numbers, email address)

To register your interest in buying a property

For marketing purposes – to send you details of properties you may be interested in.  We may do this by post/email/text.

To arrange any necessary repairs in the 12 months defects period

Current housing situation (renting / own home etc.)

To establish your eligibility for Help to Buy or to buy a shared ownership property

Working status/salary/dates of employment

Proof of savings and credit report

To establish your eligibility for Help to Buy or to buy a shared ownership property 

Passport or other proof of identity

Legal requirement for anti-money laundering purposes

Details of your mortgage and mortgage lender.

Details of your solicitor.

To process the sale.

Ethnicity*

To monitor equality of opportunity

Nationality

To monitor equality of opportunity.

A legal requirement for anti-money laundering purposes.

* Some of the above information that we need to collect is sensitive in nature and is considered to be in a ‘special category’ i.e. ethnicity.

Keeping your information

We will usually keep this information for:

  • 12 years after completion for leases
  • For as long as you own an interest in the property plus one year – for contact details and information about the original purchase

whg uses our industry standard Document Retention Schedule to determine retention periods.

We will store your information securely in computer systems or in certain circumstances in manual files.  We will dispose securely of all information when we no longer have a contractual relationship with you.

Who we will share your information with

We will share some or all of the information we hold about you with:

  • Other companies that deliver services on behalf of whg, for example:
    • Expert Agent – to process your application
    • Metro Finance – to carry out an affordability assessment
    • Solicitors
    • Developers – to carry out repairs in the defects period
  • Utility providers – to set up your services
  • Your local Council – for payment of Council Tax
  • Land Registry

If asked to do so, we may share your information with the police for the prevention and detection of crime, including fraud and benefit fraud.

We only share the minimum amount of personal data necessary to enable us to fulfil our legal obligations.

We will not sell your personal data.

Lawful basis for collecting and processing your information

The law says that we have to meet a legal condition under the Data Protection Act 2018 before we can process (which includes sharing) your personal data.  The conditions which apply for the personal data that we process for prospective purchasers are:

  • To enter into a contract: to purchase one of our homes
  • Necessary for compliance with a legal obligation: for example, in relation to anti money laundering regulations.
  • Our legitimate interests: this allows us to collect your non-sensitive information (name, contact details) and where necessary share it with our partners for our own administrative purposes, to ensure compliance with whg policies and to set up your utility services etc. 

The conditions that apply for processing special categories of personal data are as follows:

  • The processing is necessary to monitor equality of opportunity or treatment: ethnic origin/nationality.

Statutory or contractual requirements

Most of the personal data that we hold about you is processed in order to fulfil a contractual obligation (between whg as the vendor of the property and you as our customer) or a legal obligation (providing your details to the Land Registry).

Failing to provide your personal data would mean that we would be unable to sell you a property. 

Your rights

You have the following rights set out in law concerning your personal information – the right to:

  • be informed about how we process your personal data (which is why we have developed this Privacy Notice);
  • have access to a copy of the personal information we collect and keep (known as a Subject Access Request);
  • have inaccurate or incomplete personal data rectified;
  • restrict processing of your personal data in certain circumstances, for example when you are contesting the accuracy or you object to the processing;
  • object to processing for direct marketing or for the company’s legitimate interests or performance of a task in the public interest, or for purposes of scientific/historical research and statistics
  • have your personal data erased in certain circumstances where there is no compelling reason to continue processing it;
  • data portability, to enable you to receive a copy of your personal data in a machine readable format, allowing you to move, copy or transfer personal data easily to another company;
  • object to automated decision making that would affect you significantly, in certain circumstances;  
  • claim compensation for damages caused by a breach of the Data Protection Act (this can only be done via the Courts); and
  • withdraw your consent for whg to use or share your personal information where you have previously given us your consent for this.

Questions and concerns

If you have any questions about the way in which we collect, process and store your information please speak to a colleague or the Data Protection Officer.

Right to lodge a complaint

If you have concerns about the way in which whg has handled your information you can speak to the Independent Information Commissioner's Office.  Go to https://ico.org.uk/concerns/ for more details or phone 0303 123 1113. 

Helen Lane, Data Protection Officer 1/3/18

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A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser, and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies can be used by web servers to identity and track users as they navigate different pages on a website and to identify users returning to a website.

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