Privacy statement

• What data do we collect?

  We collect data about you and members of your household when you first occupy your home or contact us for other services. We only collect data which is necessary, relevant and adequate for the purpose(s) for which you are providing it.

  We collect data about you and your household when you use Moat’s websites, applications and our customer service centre. We may also obtain data about you and your household from your local authority and other agencies (eg. Department for Work and Pensions). Some of this data does not identify you personally, but helps us to understand how you use our services and engage with us (we use this to improve our services and make them more useful to our customers).

  The data we collect includes some or all of the following:

  When you apply to live in one of our properties

  • Name (including title)
  • Address (including former address(es)
  • Phone number(s)
  • Date of birth
  • Proof of identity and address documents
  • Email address(es)
  • Household information (including name(s), date(s) of birth, contact numbers)
  • Information about any disabilities or special requirements for you or members of your household (where you have provided it)
  • Details of any transactions between you and us
  • Voice recordings of calls you make to our customer service centre
  • Any data within correspondence you send to us.

  When you use our online services

  • The date and time you used our services
  • The pages you visited on our website and how long you visited them for
  • ‘Live chat’ records
  • Your IP address
  • The internet browser and devices you are using
  • Cookie information (for more information please see our Cookie Policy)
  • The website address from which you accessed our website.

  Where you engage with us in a business context, we may collect your job title, company contact details (including email addresses) and company details (some of which we may obtain from online or public business directories).

  CCTV footage

  Moat operates CCTV at its head office locations and at some selected housing sites where we own or manage properties in order to prevent and detect anti-social behaviour / criminal activity. We will place ‘CCTV in operation’ signs to inform you when images of you may be captured. We are also aware that CCTV is in operation at some of our regional offices, such as Stanhope and Medway, however this is operated by the building owner.

   

• How do we use this data?

  Moat will only process data that is necessary for the purpose(s) for which it has been collected, for example to consider any application for accommodation, or to respond to any query, complaint or request made by you. You will always have the option not to receive marketing communications from us (and you can withdraw your consent or object at any time). We will never send you unsolicited ‘junk’ email or communications, or share your personal data with anyone else who might do so.

  There are various ways in which we may use or process your personal data, including:

  Consent: where you have provided your consent, we may use and process your data to:

  • Contact you from time to time about shared ownership and market sale housing developments which we think may be of interest to you (don’t worry, we won’t bombard you)
  • Share your personal data with our recommended third party support providers, so that they can contact you about their products and services (we will, of course, give you details about these third parties before you give your permission for us to send data to them).

  You can withdraw your consent at any time by contacting us at customer@moat.co.uk or, in relation to any marketing messages you receive, by using the unsubscribe option included in those messages.

  Contractual performance: we may use and process your personal data where this is necessary to perform a contract with you (most likely your tenancy agreement or lease) and to fulfil any other transactions, such as repairs or support services, entered into with us (or our contractors and partner organisations).

  Legitimate interests: we may use and process your personal data as set out below where it is in our legitimate interests as a business to do so. 

  Processing necessary for us to support customers: to respond to correspondence, you send to us and fulfil the requests you make to us.

  Processing necessary for us to respond to understanding customers’ needs

  • To analyse, evaluate and improve our services so that they are more useful (we will generally use data amalgamated from many people so that it doesn’t identify you personally)
  • To undertake analysis and research (including contacting you with customer surveys) so that we can better understand you as a customer and provide tailored services that we think you will be interested in
  • We will only send marketing communications to you if you have provided your consent for us to do so or which we have obtained in the ways mentioned in the paragraph below
  • In some cases we may use automated methods to analyse, combine and evaluate data that you have provided to us. We collect and analyse this data in this way so that we can continually improve our services and plan for the future.

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• How do we use this data? (continued)

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  Processing necessary for us to promote our activities and measure the reach and effectiveness of our services

  • To identify and record when you have received, opened or engaged with our website or electronic communications (please see our Cookie Policy for more information)
  • To administer promotions that you enter with us from time to time and to distribute prizes
  • To contact you when your local Moat office opens, closes or moves premises

  Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

  • To verify the accuracy of data that we hold about you and create a better understanding of you as a customer
  • For network and information security purposes ie. in order for us to take steps to protect your data against loss, damage, theft or unauthorised access
  • To comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request)
  • To inform you of updates to our terms and conditions and policies.

  Legal obligation: we may process your personal data to comply with our legal requirements (eg. to comply with the regulatory requirements of the Regulator of Social Housing, or to comply with Health and Safety legislation).

  Vital interest: sometimes we will need to process your personal data to contact you if there is an urgent safety issue that we need to tell you about.

• How do we share this data?

  We do not sell your data to third parties. We do work closely with our contractors and partner organisations who deliver services for us (like repairs, satisfaction surveys and market research etc).

  We may from time to time disclose your data to the following categories of companies or organisations to which we pass the responsibility to handle services on our behalf: service providers including repairs and maintenance providers, and legal and other professional advisors.

  We will also share your data in situations where we need to pass it on to manage any request or complaint you have made to us. For example, we may share details of any complaint with the Housing Ombudsman Service.

  We take steps to ensure that any third-party partners who handle your data comply with data protection legislation and protect your data just as we do. We only disclose personal data that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your data or use aggregated, non-specific data sets where ever possible.

  Due to the international nature of modern business technology, there may be some instances where your data is processed or stored outside of the EU. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.

  There are circumstances where we share your data with other companies within our Group in order to deliver services, complete transactions, handle complaints or provide you with information that you have requested.

• How long do we keep your data for?

  We will not hold your personal data in an identifiable format for any longer than is necessary. If you are a customer or otherwise have a relationship with us, we will hold personal data about you for a longer period than if we have obtained your details in connection with a prospective relationship.

  If we have a relationship with you (eg. you are a customer or member of a customer’s household), we hold your personal data for six years from the date our relationship ends. We hold your personal data for this period to establish, bring or defend legal claims.

  Where we have obtained your personal data following an enquiry or application, or a request for information on any of our services, we hold your personal data for one year from the date we collect that data, unless during that period we form a relationship with you.

  The only exceptions to the periods mentioned above are where:

  • The law requires us to hold your personal data for a longer period, or delete it sooner
  • If there are outstanding balances due to us at the end of our relationship, we will retain your data for a period of six years following the collection of all amounts owed to us
  • You have raised a complaint or concern regarding our services, in which case we will retain your data for a period of six years following the conclusion date of that complaint
  • You exercise your right to have the data erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see ‘how you can manage the data we hold about you’ for further information).
• How you can manage the data we hold about you

  You have the right as an individual to access your personal data and make corrections if necessary. You also have the right to withdraw any consent you have previously given us and ask us to erase the data we hold about you. You can also object to us using your personal data (where we rely on our business interests to process and use your personal data).

  You have a number of rights in relation to your personal data under data protection law. In relation to most rights, we will ask you for data to confirm your identity and, where applicable, to help us search for your personal data. Except in rare cases, we will respond to you within one month after we have received any request (including any identification documents requested).

  You have the right to:

  • Ask for a copy of the data that we hold about you
  • Correct and update your data
  • Withdraw your consent (where we rely on it). Please see ‘how do we use this data’ for further information
  • Object to our use of your data (where we rely on the public interest or our legitimate interests to use your personal data) provided we do not have any continuing lawful reason to continue to use and process the data. When we do rely on our legitimate interests to use your personal data for direct marketing, we will always comply with your right to object
  • Erase your data (or restrict the use of it), when we do not have any continuing lawful reason to continue to use and process that data
  • Receive copies of the data you have provided to us in a structured data file (in a commonly used and machine readable format) to transfer to another provider, where we rely on your consent to use and process your personal data or need to process it in connection with your contract.

  You can exercise the above rights and/or manage your data by contacting our Data Protection Officer by emailing customer@moat.co.uk or writing to:

  Data Protection Officer, Moat, Mariner House, Galleon Boulevard, Crossways, Dartford, Kent DA2 6QE.

  If you are unhappy, you have the right to lodge a complaint with the Information Commissioner’s Office, the data protection regulator in the UK. Write to them at:

  Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. You can call them on 0303 123 1113 or email at casework@ico.org.uk.

For the purpose of supplying the services of the website for yourself and future visitors we need to collect some information from you. This is done via cookies (as you traverse the site) and http headers (when you login) where the data resides in your local storage.

• Your consent to collect information

  The ‘cookie’ consent banner on this website is your affirmative action in accessing subsequent pages where data is transmitted. Consent is based on the computer/browser/device being used. If using a shared computer it is advisable to clear local data before and after use. More information on cookies, headers and local storage is available from Wikipedia.

  Search https://en.wikipedia.org/ for 'HTTP cookies', 'HTTP headers' and 'Web_storage' respectively.

• How to withdraw consent at any time

  You have the right withdraw the consent at any time (opt out). There are various ways to do so:

  • Disable your browser from accepting/sending cookies or saving local storage, ornot using the website.
  • However, there will be aspects of the website that will not function, especially the login sections.

  As a customer of Moat you can access your information via the Call Centre or via post.

• Renewal of consent

  Consent will be sought each session/device or when the term have changed.  If you subsequently give consent it will override any withdrawal of consent.

• Overview Cookies and local storage

  Please see our privacy policy for more information on the controller and processors of data.