Homes2rent privacy notice
1. Who we are
In these Terms, ‘Group’, ‘We’, ‘Us’ and ‘Our’ mean Homes2Rent Limited (Homes2Rent), a letting agent established as a subsidiary of the National Residential Landlords Association (NRLA), a not-for-profit company limited by guarantee. The registered office for these companies is at 212 Washway Road, Manchester, England M33 6RN.
Homes2Rent is acting as the data controller and determines the purposes for which, and the way in which, your personal data is processed. In this Privacy Notice, ‘our website’ means http://www.homes2rent.org.uk.
This notice explains what information we collect, when we collect it and how we use this. During the course of our activities, we will process personal data (which may be held on paper, electronically, or otherwise) about you and we recognise the need to treat it in an appropriate and lawful manner. The purpose of this notice is to make you aware of how we will handle your information.
We are committed to protecting your privacy and aim to be clear when we collect your information and use it only as you would reasonably expect. You can contact us at data.protection@nrla.org.uk, by telephone on 0300 131 6400, or by writing to the registered office above.
2. Introduction
This privacy notice sets out the relationship between Homes2Rent and you as a prospective or actual tenant (‘you’, ‘your’). It tells you how and why we collect information about you, how it is used and stored and who it is shared with so we are open with you about what information we hold and what we do with it. We act according to the law to protect your rights and ensure the security of the data we hold about you. This Privacy Notice sets out the information we are obliged to give you under the UK Data Protection Act 2018.
The key role of Homes2Rent is to provide advertise properties for rent and facilitate enquiries, viewing requests, offers and the creation of a tenancy agreement. We therefore collect, process and store personal data to help us promote the interests of both tenants & landlords, assist in the process of creating a tenancy, and to introduce appropriate products and services.
We are careful when selecting the persons with whom we share data and do not share data with third parties except with your consent or where we tell you in advance that this will happen. Data is shared across Homes2Rent and between the companies within the group.
3. The information we hold about you
We collect and handle the following information about you from your application for accommodation and any subsequent credit check or tenancy creation:
- Prospective tenants and/or guarantor names, email address, date of birth, address (including any previous addresses, relationship to other prospective tenants, employment status, name of university or college where you are studying (if applicable);
- Tenant name, email address, telephone number, date of birth, address (including any previous addresses), marital status, National Insurance Number, nationality, next of kin, name of university or college where you are studying (if applicable), the name of friends that may stay with you (if applicable);
- Guarantor name, e-mail address, telephone number, date of birth, address (including any previous addresses), marital status, National Insurance number, nationality, next of kin (if applicable);
- Property address; term, rent, deposit, utility and service responsibilities;
- The employment status of tenants and/or guarantors, address, contact details (including email, phone and fax numbers) of the employer/accountant, payroll numbers, length of employment, salary information (including any regular overtime or commission), and any other income received;
- Bank account details of the tenant and prospective tenants, including account number and sort code, and any hire purchase/loan agreements/credit cards or store cards that you have; and
- Any welfare benefits that you may be eligible for or are currently on.
- Your cookie and website preferences on how you would like to be contacted and what about and your activity on our website e.g. pages visited and emails received and read.
- Website visits, including technical information such as how you accessed the site, how you engaged with us during the visit, etc.
- Communications between us, including emails and audio recordings of calls made to and from us, including complaints.
4. How we collect personal information
We collect personal information from you:
- Directly through our website, via our partner websites and over the phone.
- We may collect information about the software on your computer or device (your browser version etc.) and your IP address (your connection with the internet) to improve your interaction with our website and for our records. This may happen automatically without you being aware of it.
- We may use cookies (small text files which we and other website operators store on your computer or device when you visit our website) to deliver a better and more personalised interaction. They enable us to recognise you when you return to our website, store information about your preferences and improve the way your searches are processed. They also enable us to generate anonymised statistics about the number of visitors we have and how they use our website and the internet. You can set your browser to reject non-essential cookies if you wish (you should consult your browser help section for details); this might restrict your use of our website and other websites. For more information about cookies, please see our cookie policy.
5. How we use your personal data
We will not use your personal information unless we have first told you how we will use it, or it is obvious how we will use it. As a membership organisation, we need to collect and use your personal information for:
- to enable us to supply you with the services and information which you have requested;
- to undertake and perform our obligations and duties to facilitating introductions to prospective landlords;
- to carry out due diligence on any prospective tenant and/or guarantor, including whether there are any money judgements against them, or any history of bankruptcy or insolvency;
- to help you to manage your tenancy;
- to analyse the information we collect so that we can administer, support and improve and develop our business and the services we offer;
- to contact you in order to send you details of any changes to our suppliers which may affect you; and
- for all other purposes consistent with the proper performance of our operations and business.
6. Our legal basis for processing personal information
The purposes for which we process personal information are: to introduce you to rental properties and facilitate the introduction to landlords; facilitation of property viewings; for our legitimate interests in informing our members of the activities of Homes2Rent or news in the sector we serve; and, via your consent, to provide you with targeted offers and marketing from us or our partners.
The law allows us to collect and use personal data if it is necessary for our legitimate business interest and so long as its use is fair, balanced and does not unduly impact your rights. In many situations, the best approach is to process personal data because of our legitimate interests as a letting agent rather than through consent. However, we will ask for your consent to send you marketing emails and text messages. You can withdraw consent for this at any time.
In certain instances, we are required by law to process personal data. In extreme situations, we may share your personal details with the emergency services if we believe it is in your ‘vital interests’ to do so; e.g. if someone is taken ill during a viewing. We may also share your personal information where we are compelled by law to do so.
7. Where we store your personal information
Your information will only be stored within the UK or EEA. If information is transferred outside the UK or EEA, we ensure that there are adequate safeguards in place to protect your information in accordance with this notice.
Telephone conversations are recorded electronically for monitoring, auditing and training purposes. This includes advice given to you over the telephone by our advisors.
By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.
All information you provide to us is stored on our or our partners’ secure servers. Any payment transactions are encrypted and Homes2Rent do not store any payment information other than your transaction history. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
8. How we share your personal information
The information you provide to us will be treated by me as confidential and will be processed only by any third party, acting on our behalf, within the UK/EEA.
We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:
- If we enter into a joint venture with or merge with a business entity, your information may be disclosed to our new business partners or owners;
- To carry out due diligence on you as a prospective tenant/ guarantor, including but not limited to the carrying out of affordability checks, due diligence checks and the obtaining of references from relevant parties, whose data you have provided;
- If you request so, your information shall be disclosed in order to determine if there are any money judgements against you, as the prospective tenant/guarantor, or to determine if they have a history of bankruptcy or insolvency;
- If you are unable to make payments under your tenancy, your information may be disclosed to any relevant party assisting in the recovery of this debt or the tracing of you as a tenant; and
- In the creation, renewal or termination of the tenancy, your information will be disclosed to the relevant local authority, tenancy deposit scheme administrator, service/utility provider, freeholder, factor, facilities manager or any other relevant person or organisation in connection with this.
Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.
We share your personal information across the NRLA group of companies to carry out different activities and provide different entitlements and benefits.
We also share your personal information with partners who help us to provide the services offered by Homes2Rent, specifically: Bunk App Limited to provide our property portfolio management service.
9. How we protect your personal information
We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff and contractors. We also provide guidance and regular data protection training to our staff.
We ensure there are appropriate technical controls in place to protect your personal details,
for example, our computer network and servers are protected and routinely monitored to industry standards of good practice (Cyber Essentials).
We store all personal information you supply on secured servers . For your protection, any payment details you provide to us will be encrypted using SSL (Secure Sockets Layers) technology. Unfortunately, the transmission of information over the internet can never be completely secure. Although we will do our best to ensure that your personal information is protected, we cannot guarantee the security of your data transmitted to the website. Any transmission of your personal information by you is, therefore, at your own risk.
10. How long we keep your personal data
We will only keep personal information for as long as we have a valid reason for keeping it. After that, we delete or dispose of the information securely. We keep personal information about:
- Prospective tenants and guarantors for one year from the date of application
- Tenants and guarantors for one years after the conclusion of the tenancy
- Complaints and feedback for two years.
- Surveys of members for three years after the survey so that data can be referenced for statistical analysis.
Analytics information from Google for three years and two months.
11. Your rights
- You have a right to know what personal data we hold, who we acquired it from, how we process it, the logic involved in any automatic processing and to whom we disclose it.
- You have a right to ask us not to process your personal data for direct marketing purposes unrelated to NRLA membership.
- You have a right to ask us not to make decisions based solely on the automatic processing of your personal information.
- You have a right to ask us not to process your personal information in a way that is likely to cause unwarranted and substantial damage or distress.
- You have a right to ask us to erase your personal information.
- These statutory rights are qualified by exceptions and exemptions. To exercise any of these rights, please contact us using the details shown at the start of this Privacy Notice.
- You can find out more about your rights from the Information Commissioner, who regulates data protection and privacy.
12. Complaints
We operate our own internal complaints policy; if you have any concerns about the way we collect, or handle data please contact us at data.protection@nrla.org.uk. You can find out more information on this process on our website.
Additionally, you have the right to lodge a complaint with the Supervisory Authority at The
Information Commissioner, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF www.ico.org.uk.
13. Changes to this policy
We may change this Privacy Notice from time to time. If we make any significant changes in the way we treat your personal information, we will make this clear on our website or by contacting you directly.