Privacy notice - customer's representative, attorney and nominated guardian - collecting and retaining personal information

We collect the following information from you as a nominated representative, power of attorney or court appointed guardian for our customers:

• Full name;
• Address;
• Contact details;
• Date of birth; and
• Proof of identity (Representation Mandate only).

We collect your personal information from you via a variety of sources, including:

- When one of our customers submits a completed Representation Mandate form;

- when one of our customers submits a valid Power of Attorney document; or

- when we receive confirmation from a court that you have been appointed as a guardian under a guardianship order for one of our customers.

Our landline phone calls to our Customer First Centre and to our Group Debt Recovery Team are recorded for training and monitoring purposes and our recordings are usually held for a period of one month.

We operate a CCTV system at our office premises and at various locations within the vicinity of our properties for the detection and prevention of crime, to fulfil our legal obligations to keep our staff safe and in pursuit of our legitimate interest to keep our properties safe and secure. Our CCTV cameras operate continuously and recordings are held for one month.

We may transfer information about you to other Wheatley Group subsidiaries for purposes connected to your role as a representative, attorney or guardian for one of our customers or the management of the company’s business.

We need your personal information as we have a legitimate interest to note that you are our customer’s representative, attorney or guardian.  We will use the information you provide to contact you to share information with you about the customer you are acting for.

If you are no longer acting for our customer, please advise us of this. We will note this for our records and cease to share information about that customer with you.

We share limited personal data with our contractors who are carrying out services on our behalf including but not restricted to:

• To provide a language translation service if it is necessary to translate any information into or from a foreign language for you;
• To carry out research, survey and segmentation on our behalf to help us to improve the services we offer to the person you represent; and
• With our professional and legal advisors for the purposes of taking advice.

Our contractors are required to comply with the law and our own Data Processing Agreement or Data Processing Clauses within our contracts to ensure data is managed appropriately and for specified purposes.

We may need to share personal information with local authorities, housing associations, the police, government departments and agencies, with our regulator and auditors, with utility companies or with other organisations and agencies where we are legally allowed or obliged to do so.

In the event that we do share personal information with external third parties, we will only share such personal information strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.

Your personal information is stored on our paper and IT filing systems which may be copied for testing, backup, archiving and disaster recovery purposes. Access to your information is limited to those who require it to provide services to the person you represent. All data is held within the UK.

If any of your personal information is transferred out with the UK by any of our contractors, we will ensure that there are adequate safeguards in place to protect your personal information in accordance with applicable UK data protection legislation

We will only keep your personal information for as long as necessary in your role as representative, attorney or guardian and to safeguard us in the event of any claims, complaints, litigation, enquiries or investigations during or following the termination the person who you are representing’s tenancy.

Unless deleted or moved to Wheatley Group systems by a Wheatley staff member, emails sent and received by Wheatley staff are automatically deleted after 6 months. Any emails which are relevant to a customer’s file are added or summarised within Wheatley Group systems.

We have a data retention policy that sets out the periods for retaining and reviewing all information that we hold.  You can request a copy by contacting us at InformationRequests@wheatley-group.com

You can exercise any of the following rights by writing to us at InformationRequests@wheatley-group.com

Your rights in relation to your personal information are:

• you have a right to request access to the personal information that we hold about you by making a "subject access request";
• if you believe that any of your personal information is inaccurate or incomplete, you have a right to request that we correct or complete your personal information;
• you have a right to request that we restrict the processing of your personal information for specific purposes; and
• if you wish us to delete your personal information, you may request that we do so.

Any requests received by us will be considered under applicable UK Data Protection Legislation.  If you remain dissatisfied, you have a right to raise a complaint with the Information Commissioner's Office at www.ico.org.uk

The accuracy of our information is important to us - please help us keep our records updated by informing us of any changes to your personal information

Our Privacy Notice is regularly kept up to date and this version was updated on 21 August 2024. The latest full version is always available from our website.