1. About First Choice Housing

Data we request from organisations referring clients to us or from self-referring clients referring themselves to us includes: full name, email, contact telephone number, previous address, date of birth, ethnicity, and information to help us complete a needs assessment (physical and mental health needs, SEND status, criminal record history, substance or alcohol use, income, cultural or faith related requirements).

Once accepted as a client and receiving services, we will independently collect: client survey responses, case studies, demographic data, service engagement and outcome information including education, employment and training status and levels of engagement with third party services provided by our partners. 

5. Data Storage and Access – where we store the information and who can access it 

We operate a central database, In-form, to help us securely store client and referral partner information. The database is password-protected and access to the database is limited to First Choice Housing staff, with ‘staff’ referring to employees of First Choice Housing and not including our volunteers.

Information about clients may also be recorded in other formats, such as in emails, word processing and spreadsheet applications. Information in these formats may be stored on First Choice Housing devices, in Google Workspace applications such as our Google Drive cloud storage or in Microsoft applications and cloud-based Office 365 applications such as One Drive.

Access to these devices and cloud applications is password-protected and restricted to First Choice Housing staff or third party contractors as outlined below.

6. Retention – how long we keep the information 

We work to ensure that your personal data is only retained for the period that First Choice Housing needs it, or in accordance with laws, regulations and professional obligations that we are subject to.

Client records on our central database, In-form, containing information provided by clients and referring organisations, alongside additional information we have captured independently, are pseudonymised approximately two calendar years after a client last accessed First Choice Housing services. This involves removal of all information from a record which could be used to identify an individual client. This process can only be reversed by specific members of the First Choice Housing team and only under reasonable circumstances, such as to facilitate a safeguarding enquiry.

Any digitised copies of client survey responses with identifying personal data will be archived approximately two calendar years after a client stops accessing our services.

Our best practice for client or referral partner information temporarily stored in other formats, such as word processing or spreadsheet applications, is to delete this information where it is temporarily stored as soon as the purpose for processing the information in the alternative format is complete.

Client records on our central database and any related referral partner information are deleted or permanently anonymised 10 years after they last accessed First Choice Housing services. The anonymisation process can only be reversed by specific members of the First Choice Housing team under reasonable circumstances.

If you would like to find out how long any other information is being retained, please contact us via the details provided in section 12 of this policy.

7. Data Sharing – what information we share with other parties

Client information held by First Choice Housing may be shared with third parties, such as contractors or service providers like software developers, if needed to enable effective coordination of service delivery but only where a data sharing agreement is in place.

First Choice Housing will at times be supported by carefully vetted external contractors who support its IT and In-form functions. These can be both Data Processors and/or Data Controllers. Where such access is granted, it is on the same terms, protocols and basis as applies to First Choice Housing employees. Pseudonymised information about clients may be shared with other third parties for purposes of evaluating the impact of our services and improving service delivery, but only where a data sharing agreement is in place. Clients can choose to opt-out if they do not wish for their information to be shared with third parties for evaluation purposes.

Anonymous and aggregated data relating to clients may be published on the First Choice Housing website and used in published materials, such as First Choice Housing’s annual report for funders.

8. Legal basis – our legal basis for processing the information 

To lawfully process the information outlined in this notice, we rely on:

Legitimate interests: where information we request or collect independently about clients is used to effectively coordinate the delivery of our services, enable the evaluation of our impact, improve the future service delivery, and demonstrate that we are reaching the people who need it as defined by our charity mission. 

Legal obligation: where we may need to use or share information we hold about clients in order to comply with a legal obligation, such as to facilitate the investigation of a safeguarding concern with a local authority.

Consent: in order to facilitate any additional processing of information beyond which is outlined in this privacy notice, we will seek consent from the relevant individuals in order to do so.

9. Security of personal information 

We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed. We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.

We have procedures to handle any potential data security breaches. Data subjects, third parties and any applicable regulators will be notified where we are legally required to do so. If you become aware of a potential data breach involving your personal data, please contact us immediately using the details provided at the end of this notice. 

10. Transfers outside of the EEA

In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the European Economic Area (EEA).

We may share personal information to third parties outside of the European Economic Area (EEA). Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws.

Where personal data is transferred outside of the EEA to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include Standard Contractual Clauses.

For more information about transfers and safeguarding measures, please contact us using the information in section 12.

11. How to control your information and your rights

First Choice Housing is committed to accommodating your rights under the General Data Protection Regulation, which include:

• Your right to be fully informed on how the information we ask you to share with us and the information we collect independently is processed by First Choice Housing. If you have any questions about the guidance provided in this policy notice, or would like further detail on specific sections, then please address your query to the contact details provided below.
• Your right to access the information we have asked you to share with us and the information we collected independently. If you require a copy of this information, please make this request using the contact details provided in this notice and the information will be provided to you in an electronic format as soon as possible, within one month at the latest. We will need to confirm your identity to provide this information.
• Your right to rectify the information we have asked you to share with us and the information we collected independently if it is inaccurate or incomplete. If you believe that any of the information is inaccurate or incomplete, please contact us as soon as possible using the contact details provided below. We will promptly correct any information found to be incorrect.
• Your right to erase the information we have asked you to share with us and the information we collected independently. You may request that this information be placed under restricted access, pseudonymised or deleted where there is no compelling reason for it to be kept. However, we may need to retain some information as stated in section 6. Retention – how long we keep the information.
• Your right to restrict or object to the further processing of the information we have asked you to share with us and the information we collected independently. Please use the contact details provided to inform us of any wish to restrict or object to the further processing of this information. Note that we may need to retain some key information in order to respect your restriction or objection in future.

Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).

Where we make an automated decision which has a legal or substantially similar effect, you have the right to speak to us and we may then review the decision, provide a more detailed explanation and assess if the automated decision was made correctly.

12. How to contact us

To contact us in relation to any of the information contained in this policy notice, to make a complaint, to pursue any rights under the General Data Protection Regulation and to contact our DPO, please 

Email: [email protected]

Or write to us at: First Choice Housing, Suite 9-10 Focal Point, 27-35 Fleet Street, Swindon, SN1 1RQ

Telephone: 01793 286 110

If you are unhappy with the way that we have handled your Personal Information, you can make a complaint to the Information Commissioner’s Office (ICO) which is the UK authority responsible for data protection.