Purpose of our privacy statement
Under the Data Protection Act 2018 and the General Data Protection Regulation, we are required to explain to you why we are asking for this information about you, how we intend to use the information you provide and whether we will share this with anyone else.
Who are we?
We are Sanctuary Students, which is a trading name used by Sanctuary Student Homes Limited and Sanctuary Management Services Limited, subsidiaries of Sanctuary Housing Association, an exempt charity and part of Sanctuary Group (“Sanctuary”) one of the UK's leading providers of housing, care and commercial services. Our address is Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ. Sanctuary Addenbrookes is part of Sanctuary Housing Association.
Our data protection officer
Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing firstname.lastname@example.org.
Why are we collecting your information?
The information that you provide us during routine enquiry channels such as via our website, in person, during a telephone call, during the contracting process or while you are staying with us is required by Sanctuary in order for us to provide you with a requested service and meet our contractual obligations. This information is specifically about you and without this information; we will not be able to provide you with a service or indeed enter into a contract with you.
What information are we collecting?
The only information which we are collecting is the information which you provide to us via our booking portal, in person, on forms or during any enquiry. The information we collect may include, for example:
- Name, Address and Contact details
- Date of Birth, Passport Number (if applicable)
- Nationality, Next of Kin details, Guarantor details (if applicable)
- CCTV monitoring
- Passport sized photograph (if applicable)
- Direct Debit mandates (Addenbrookes only)
Some of the information which we collect will be special categories of personal data (also called sensitive personal data), which includes information about your health.
As part of the contracting process, if applicable, we will direct you to our external electronic payment provider who will process payments as agreed in the contract terms.
What we are going to do with your information
The information you provide to us will be used for the following purposes:
- It will be stored and used by us in accordance with this privacy statement and also in accordance with your rights under the Data Protection Act 2018 and the General Data Protection Regulation.
- It will be collected and used by us fairly and openly for the purpose of providing our services to you and tailor such services to your needs
- It will be used to improve the services you receive from us
The information you have provided about yourself will enable us to ensure that we can provide you with the service requested and meet the terms of our contract.
It will allow us to make contact with you in the most appropriate way. For example, we can provide literature in large print if you have difficulty reading smaller print; or provide documents in an alternative language if English is not your first language.
If you have given explicit consent during your enquiry, the registration or application process and have chosen to be included in communication regarding any future accommodation provision we will use the data provided for this purpose.
Some of the information which we collect will be special categories of personal data (also called sensitive personal data), such as any disability you may have. You need to be aware that we will use this information in order to determine if we have suitable accommodation, and enable us to allocate the most appropriate accommodation depending on your specific needs. By providing us with this information, you consent to our use of it for this purpose. Please note that not providing this information may result in unsuitable accommodation being allocated.
What is the legal basis for using your information?
In accordance with the data protection laws, we need a "legal basis" for collecting and using information about you. There are a variety of different legal basis for processing personal data which are set out in the data protection laws.
The lawful basis on which we rely in order to use the information which we collect about you, for the purposes set out in this notice will be:
- Using your information in this way is necessary for us to provide you with information, ensure we can process your enquiry and enter and deliver a contract between us.
- If you have given permission during your enquiry, the registration or application process and have chosen to be included in communication regarding any future accommodation provision we will use the data provided and we will do this under the legal basis of consent.
- Using your information is necessary for us to comply with a legal obligation to which we are subject.
The lawful basis on which we rely in order to use your special categories of personal data which we collect about you, will be that you have provided your explicit consent to our use the information – see section above.
Sharing your information
Members of Sanctuary Group
Sanctuary Group is made up of a number of related companies. We will share your information with other members of Sanctuary Group where necessary in order to best provide the services to you in accordance with your enquiry and any contract between us.
Your information will only be accessed by other companies in the Group where it is necessary to do so in order to provide services to you in accordance with your enquiry and any contract. The obligations which are set out in this notice shall apply to the other members of the Group to the same extent that they apply to us.
For more information on which companies, please refer to Sanctuary Group.
Contractors and sub-contractors
It may be necessary to share information about you with our contractors and sub-contractors in order to provide you with the services in accordance with your enquiry and any future contract between us. We will only share information about you with the contractors and sub-contractors which is relevant and necessary to address your individual needs. The contractors and sub-contractors shall be contractually required to ensure that they adhere to the security requirements imposed by the Data Protection Act 2018 and / or the General Data Protection Regulation (as applicable).
Our contractors and sub-contractors will not share your information with any other parties and will only be able to use the information when completing work on behalf of us.
Regulators and other legal obligations
We may also be required to share your information with our regulators who are permitted access to this information by law and with other organisations where we have a legal obligation to share the information with them.
We may from time to time share your information with other organisations, such as:
- Partner organisations whom we have data sharing agreements with for example University/NHS Trusts/Agencies acting on our behalf;
- Utility companies so they can provide services to you and contact you in respect of utility charges (only if applicable)
- The police for the purpose of detection and prevention of crime;
- To assist the management of our contracts we may utilise debt recovery/deposit protection and credit reference agencies where applicable. If applicable, we will share information with your nominated guarantor;
- Mail or parcel delivery organisations who have incomplete delivery address details in order to facilitate delivery of parcels addressed to you.
Transferring your information abroad
We intend to transfer the information which you provide to us to the United States of America. We are transferring that information to the USA because our e-marketing software provider is located in that country.
We are transferring your information to Campaign Monitor for the purpose of sending e-marketing and communication emails to you.
The European Commission has made an adequacy decision in relation to the USA. This means that the Commission has determined that the data protection laws of the USA adequately protect your personal information. As a result, we are not required to obtain specific authorisation to transfer your information to the USA. You can find details of the adequacy decision on the Commission's website.
Security of your information
The information that you provide will be stored securely on our systems and any paper records you have completed will be shredded. Our security measures and procedures reflect the seriousness with which we approach security and the value we attach to your information.
Only relevant members of staff will access the information you provide to us.
Can we use your information for any other purpose?
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 for the new purpose.
Storing your information and deleting it
We will store the personal data which you provide to us for as long as you remain a service user. Once you are no longer a service user of ours, we will review the information which we hold concerning you and determine whether there are any reasons why we need to continue holding that information. For example, if a service user is in arrears when they leave the property, it may be necessary to retain information about them in order to recover those arrears.
There also may be regulatory and/or our business best practice requirements which dictate the length of time the data is held. Once the identified purpose comes to an end, unless there is another identifiable purpose for which it is necessary to hold on to your information, we will delete your information.
In relation to the information which we hold about you, you are entitled to:
- Ask us for access to the information
- Ask us to rectify the information where it is inaccurate or is incomplete
- Ask us to erase the information and take steps to ask others who we have shared your information with to also erase it
- Ask us to limit what we do with your information
- Object to our use of your information and ask us to stop that use
- Instruct us to provide you with the information we hold about you in a structured and commonly used format or transmit that information directly to another organisation (for example, if you want the information to be sent to another housing provider).
Our obligations to comply with the above rights are subject to certain exemptions.
Where we are using your information because you have provided your consent to that use, you are entitled to withdraw your consent at any time. The lawfulness of our use of your information before consent was withdrawn is not affected.
To exercise any of the rights referred to above, you should contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing email@example.com.
You also have the right to complain to the Information Commissioner's Office (the "ICO") if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.