Notting Hill Genesis (NHG) Sales are committed to safeguarding the rights of individuals to confidentiality. Personal data is protected by the Data Protection Act 2018.
Notting Hill Genesis (Sales) is a housing provider and registered charitable organisation. Notting Hill Genesis Sales is a controller of personal information for the purposes of the Data Protection Act 2018.
If you have any questions or wish to make complaint about how we handle your personal information, please contact our Data Protection Team on the details below:
Data Protection Team
Notting Hill Genesis , 1-3 Sussex Place, Hammersmith, London, W6 9EA
This privacy notice explains how NHG Sales collect and use your personal information and who we share it with in relation to new build properties and sales - those who are considering purchasing a property with us (prospective purchasers and those at our application stage) or are already buying with us and have bought with us (residents, leaseholders and other customers).
It also explains the choices you have about the data we hold about you, the legal basis under which we process it and how to raise any concerns should you wish to. Any reference to "we", "our" or "us" in this policy is a reference to NHG Sales.
- How we collect & use your information (and the legal basis for processing) and whom it may be shared with
- Keeping your personal information (data retention)
- Your privacy rights
1. How we collect & use your information and the legal basis for processing
NHG collects your information through online platforms (such as our website via our enquiry forms and any requests for bookings or call backs and any property portals where your data submitted through our portal listings will be accessible by relevant parties within NHG in order to be able to respond to your enquiry appropriately), social media channels (Instagram, Twitter, Facebook), events, telephone conversations, interactions with our sales agents and any partnerships that allow us to deal with your enquiry (including but not limited to solicitors, mortgage brokers and financial advisors or parties who will work on your behalf).
Where a scheme is managed by an estate agent who is working in partnership with us, we my pass your information to them in order for them to be able to handle your enquiry and discuss your requirements further for the scheme you have shown interest in.
Collecting your information also allows us to keep you informed about properties we believe meet the criteria you have defined for a potential home should you choose to express an interest in home ownership with Notting Hill Genesis and in doing so, if choosing to purchase your first home with us, we may contact you in regards to collecting some further information for case studies as part of our legitimate interest in promoting the benefits of home ownership and the type of individuals who live in our homes for others who are also considering expressing their interest with us too.
The type of data we hold on you will primarily enclose your name, address, contact details, date of birth, income and savings data as well as your previous household tenancy type, number of occupants in your current household and requirements for your next home (including number of bedrooms and if you require an accessible home). This allows us to provide you with a service that is relevant and unique to you and your requirements and we endeavour to keep your information accurate and up to date, without holding this for longer than necessary.
We may from time to time record our phone calls for training and monitoring purposes. Should this be the case, a message will be played before your call connects to one of our advisors and will ask for your consent to be given (via a keypad) for the call to be recorded.
Your data will be used to help us improve our services (in which case will be anonymised), or for us to reach out and to finalise any case studies which you have provided consent for us to do. Where we do have your consent, we may also use your information under the basis of legitimate interest to:
- Send you communication which you have requested and that may be of interest based on your home ownership requirements. This may include marketing information on other properties which suit your criteria, upcoming launch events and incentives or promotions
- Notify you of changes to our service offerings (such as changes to appointment bookings, changes in the way which we are conducting our viewings and so forth)
- Seek your views or comments on the services we provide through surveys and other forms of engagement
- Advise you of business-related opportunities or information if you have expressed an interest in finding out more about this with NHG
Legal basis for processing:
Under GDPR, we process your data for the following reasons: legitimate interests, contract (contractual purposes of entering into a contract with you), consent and for legal obligations.
Contract: In order to assess your eligibility for the property purchase you have applied for or purchasing and then to enter into an agreement with you for the property purchase. Any reasonable adjustments that are required to be made to the property (such as disability adjustments) and overall communication of each stage of the property enquiry, booking, viewing and purchase also fall under the need to process data for contractual reasons.
Legal Obligations: Assessing eligibility and any reasonable adjustments (such as disability adjustments) are legal obligations for us to process your data as well as requirements for detection and investigation of fraud prevention.
Consent: Where you may be considering a number of properties in your initial search across London, we require your consent to send you information about other developments which suit your requirements (such as 2 bedroom apartments in East London) and where this is provided, your data will be processed to fulfil this.
Legitimate Interest: It is necessary in our legitimate commercial interests to process your data in regards to sending you information on other developments that may be of interest to you in your property search, as well as to monitor and improve business standards and service offerings where we may also process your data for training and monitoring purposes.
Who we may share your information with:
We will not sell or rent your information to third parties or pass any personal data on to third parties, other than to those who either process information on our behalf, or because of a legal requirement in relation to housing applications and property purchases.
We will only undertake this, where applicable, after we have ensured that sufficient steps have been taken to protect the personal data by the third party. All of our contractors operate under terms and conditions of a legally enforceable contract which includes particulars around using your information only for the service it has been provided. We do this because it is necessary for the performance of a contract. It is also in our legitimate interest in maintaining the property.
We may collect information from other third parties where and when this information is relevant to our relationship with you, and in these instances those third parties can include but are not limited to:
- Organisations that we contract with to provide services on our behalf, eg: security and maintenance
- Local authorities and central government departments, eg: Department of Works and Pensions for information about benefits received in support of a housing application as well as the Help to Buy agents where facilitating a Help to Buy scheme sale.
- Health and social care professionals and/or previous care providers for information about health care and support needs of either yourself or those in your household when applying for housing that stipulates a demand for care and support being deemed necessary
- Previous landlords for rental history where applicable
- Credit reference agencies for credit checks and information regarding your current and previous financial status and history when applying to buy a NHG property for debt recovery and fraud investigation/data matching checks
- Utility providers for debt recovery purposes if required
- Mortgage advisors (approved panel) for financial assessments and as part of the application process unless you choose to find your own
- Managing agents (including estate agents) where they manage NHG Sales properties on our behalf
- If required by law, we may under legal obligation have to share your information with the police and other law enforcement agencies for the purpose of detection and prevention of crime
Occasionally, we may have a need to transfer your personal data outside of the UK to other contractors. Where this is the case, we will endeavour to take appropriate steps to ensure that we only contract with organisations that have the appropriate security measures in place.
If at any point you wish to stop hearing from us due to a change or circumstances or buying elsewhere and this hasn't been reflected on your records with us, please feel free to contact us at email@example.com and we will remove you from our databases immediately.
2. Keeping your personal information (data retention)
How long we keep your personal information will depend on the type and level of information we hold on you. We endeavour to only retain your personal information for as long as necessary to fulfil the purposes in which we collected it for.
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 requirements.
If you are purchasing or have purchased a property through NHG Sales, we will retain your personal data in line with our data retention schedule which you can request from our Data Protection Officer to receive a copy of the schedule.
If your application for a property purchase was unsuccessful and you choose to no longer proceed with NHG, or if you choose not to pursue any property purchase with NHG, your data will be retained for a period of 2 years, after which we will remove your personal data from our systems.
3. What rights do I have when it comes to my data?
Your duty is to inform us of changes. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you.
- Request transparency of your personal information and be informed of how we use your data.
- Request correction/rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- 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).
- 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 data portability to either yourself of a third party with some of the data that we hold about you in a structured and commonly used electronic format so that it can be easily transferred within an appropriate time frame.
If you wish to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Team in writing.
Please note we may make changes to this notice from time to time and this will be communicated and reflected on our website. This notice was last updated on 8th April 2022