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.

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  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 (e.g. Health professionals, Department for Work and Pensions, etc.). 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). It is in our legitimate interest to ensure that the service that we provide meets the needs of our service users and their household.

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  The data we collect includes some or all of the information shown in this PDF.
  (Please note: Moat reserves the right to update the contents of the Privacy Statement shown in the downloadable PDF from time to time. Should you decide to download or print a copy, it shall be rendered uncontrolled).

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  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, the Regulator of Social Housing, our buildings insurers, the Courts or other third parties.

  CCTV footage

  Moat operates CCTV at its 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

  Legal obligation to provide data

  We may be legally required to provide information to third party organisations – for instance, in certain circumstances we may be required to provide information about housing benefits to a local authority, address and tenancy information for the purposes of the collection of taxes, or to provide CCTV footage to the police for the purposes of detecting criminal activity.

  When you use our online services we may record:

  • 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 used to access our sites Cookie information (for more information please see our Cookie Policy below)
  • The website address from which you accessed our website

  We also use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.
  
  For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

• 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 by contacting customer@moat.co.uk). 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:

  • Sharing 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). 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)
  • 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
  • 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, i..e. 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.

  Automated decision making and profiling

  Moat carries out profiling in the form of RentSense, a piece of software provided by Mobysoft, in order to prioritise the work of the Customer Accounts department in terms of arrears management. RentSense is therefore acting as Data Processor on Moat’s behalf.

• How do we use this data? (continued)

  (continued from above 'how do we use your data')

  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). Some of our contractors, such as our day to day repairs partners and a select few other partnering organisations providing services on our behalf, have a limited view into our systems. Generally, this will be to enable for appointments to be made, or complaints and feedback to be responded to appropriately.

  We use a secure email facility, called Mimecast, to enable details to be sent securely via email. In situations where TLS email types cannot be received by the recipient, we endeavour to ensure that emails are anonymised where possible, or personal information details are sent within a password protected attachment.

• 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 (e.g. 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 (for information which we rely on your consent to hold it). 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 (in certain circumstances, we may request evidence of the change)
  • Withdraw your consent (where we rely on it). You can do this by contacting us at customer@moat.co.uk. in relation to any marketing messages you receive, you can unsubscribe at any time by using the unsubscribe option included in those messages
  • 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.