Latimer by Clarion Housing Group (referred to as Latimer, is the development arm of Clarion Housing Association Limited, referred to as Clarion, and Latimer Developments Limited, both of which are subsidiaries of Clarion Housing Group Limited) needs to process personal data in order to deliver our services to you as applicable:
- To develop, market, log interest and sell shared ownership and private properties and to manage our website
- To manage the staircasing process (purchasing further percentages of shared ownership properties)
- To deliver on our Group ambition to ‘transform lives and communities’
We receive personal data relating to you from you directly, but it may occasionally be provided to us by third parties with whom you have a separate relationship (such as your solicitor).
We use your data as applicable to facilitate property sales and other related services, manage the staircasing process, correspond with you, meet our legal obligations and improve our website and our products and services.
The legal basis for processing personal data about you falls into one of the following four categories:
- To meet our obligations under a contract (your lease) - or because you have asked us to do something with a view to entering into a contract with you;
- In order to further Latimer’s (or a third party’s) legitimate interests. Our legitimate interests include: ensuring that we monitor, analyse, deliver and improve our services to you and your household members; to properly manage our business; to respond to your enquiries, and promoting our services. We will look to balance your interests with our legitimate interests where we rely on this category.
- Where we have a legal obligation to do so; and/or
- To protect the vital interests of you, your family or others.
We are committed to treating your information securely, with respect and in line with data protection law.
This privacy notice tells you what to expect when Latimer processes your personal information. It applies to information about any individuals who have dealings with Latimer, including visitors to our website.
This is the main privacy notice for Latimer. If you go on to receive any other services from the Clarion Housing Group, you will be referred to the relevant Clarion Housing Group Privacy Notices which can be found on the Clarion Housing Group website.
It is important for you to read this notice in full to understand what information we hold about you, how we may use it and your rights in relation to your data. However, we have also produced a summary version explaining why ‘Privacy Matters at Latimer’.
Latimer by Clarion Housing Group is the development arm of Latimer Developments Limited and Clarion Housing Association Limited, both of which are subsidiaries of Clarion Housing Group Limited. Where purchasing a shared ownership property or staircasing (purchasing an additional percentage in an existing shared ownership property), you will be contracting with Clarion Housing Association Limited. Where purchasing a private sale property, you will contract with Latimer Developments Limited.
Clarion Housing Group includes a number of other subsidiary organisations such as Grange and Clarion Futures. Please see our registered company information, including registration details and registered offices of all the entities associated with Clarion Housing Group.
We keep our privacy notice under regular review and we will place any updates on our website. If you would like to receive a hard copy of our current privacy notice, please let us know.
For further information you can contact the Data Protection Officer as follows:
The Data Protection Officer
Clarion Housing Group Ltd
Level 6, 6 More London Place
London SE1 2DA
For independent advice about data protection, privacy, e-privacy and data sharing issues, you can contact the Information Commissioner. (Lots of useful information is accessible on their website):
Wycliffe House, Water Lane
Cheshire SK9 5AF
What information do we collect about you and how is this used?
We will only collect personal information when we need this. The type of information we need from you will vary depending on our relationship with you. When we ask you for information, we will make it clear why we need it. We will also make it clear when you do not have to provide us with information and any consequences of not providing this.
Most information we hold will be collected from you but depending on your service we may also obtain this from third parties such as:
- property portals like Zoopla and Rightmove,
- our appointed sole selling agents,
- financial advisers,
- mortgage advisors,
- solicitors or legal representatives, or Help to Buy agents.
In addition, we may also obtain information from publicly accessible sources or engage the service of market research organisations to validate, or where appropriate, enhance the information that we hold.
Latimer uses tracking on our property marketing emails and service messages. This means that we can see if these email communications are opened, if you click on links contained within them and if you visit any web pages as a result of receiving our email and if so, how long you spend searching for what you need. Doing this helps us learn what is of interest to our customers so we can improve our content and provide the most relevant materials, saving you time by helping you to find what you need more quickly. We do not track 1 to 1 email communications, for example, between you and a Customer Journey Sales Executive.
We will protect this data to make sure it is only processed appropriately and will make it clear if tracking is being used on any of our emails, but we appreciate that some customers may prefer we didn’t do this. If you would like to opt out of email tracking, you can following the simple instructions that will be included on any tracked email or you can email firstname.lastname@example.org. You can also change your mind at any time.
We collect information from you (as applicable)
To manage our records of people interested in a development:
- We will need details of what locations and type of properties you are interested in and up to date contact details (including telephone numbers, email addresses and details of anyone you may choose to represent you) so we can reach you when we need to discuss details pertaining to your potential purchase. This information is processed at your request. It is in our legitimate interests to respond to queries raised by you and to send you information about properties we think you may be interested in. If you would like us to remove you from our records at any time, please just let us know.
To manage your reservation, sales or staircasing process (as applicable):
- We will hold financial records about any deposits taken. Depending on your method of payment, we may hold your bank account details.
- We will need details of your solicitor and other relevant information to proceed with the related legal process such as proof of your identity (passport/driving licence). This will be fully explained to you at the time.
- If you are applying to purchase a shared ownership property or to staircase in an existing shared ownership property, we will need to carry out an affordability assessment and ensure that you meet applicable eligibility criteria.
- We will hold records of all our contact with you, your contact with us, and any contact from third parties representing you or about you. This may include call recordings.
- We will also use your contact information to tell you about changes to Latimer and Clarion, for example our organisational structure and governance arrangements, and to resolve or investigate complaints.
- We will hold details relating to any works to be carried out to the property during any applicable defects period (although this information will not necessarily constitute your personal data).
Provision of the information is a ‘Contractual Requirement’. Without this information, we may be unable to manage your services. For example, we cannot proceed with a legal process if we do not hold your contact details. Please speak to us with any concerns.
Where the processing of information concerns household members, it is in our legitimate interests to do this. E.g. to ensure we understand all legal effects that a process may have.
To prevent fraud:
- we will collect enough information to verify your identity.
- we will also require proof of bank details and/or source of funds.
- where relevant, we will require proof of eligibility for a certain scheme.
Processing for the purpose of fraud prevention is required in order to meet our legal obligations. Therefore if we are unable to verify your identity or carry out other relevant checks, we may not be able to provide services to you.
To assist with personal security and prevention and detection of crime:
- we may capture your image on our CCTV systems if you visit a sales office or show cabin.
Processing of this information may be required to meet Latimer’s legal obligations and our legitimate business interests around health and safety and crime prevention.
To understand how we’re performing:
- we may use your contact details to carry out market research and customer satisfaction surveys to help us to monitor our performance and to improve our services to our customers. At this time, many of our surveys are carried out by The Leadership Factor (TLF)
- to segment customers to help target our resources and prioritise services
- in managing and analysing complaints
- to monitor the success of our email communications and help us improve how we communicate with our customers
- to monitor our website usage so we can make our website better
- for statistical analysis.
It is in our legitimate interests to understand how we are performing so we can meet our mission statement and objectives.
There may also be a legal obligation for us to process the information or to demonstrate to our regulator that we are fulfilling our obligations, for example around anti-discrimination laws.
We also use your personal information in the following ways:
- Keeping in touch with you, understanding your needs, telling you about Latimer and Clarion news, performance and services that you may benefit from, and inviting you to events.
It is in our legitimate interests to communicate with you and keep you up to date with news and events in order to meet our objectives. We will let you know if you have the option to opt out of receiving communications.
- Prevention and detection of crime, and quality management.
We do this to meet our legal obligations.
- Meeting our legal obligations including the requirements of our funders or regulators.
This is a legal obligation on Clarion Housing Group.
- Providing details of new build sales to the NHBC
This is to assist NHBC in meeting their legal obligation to ensure that new home buyers receive the details of their warranty and insurance policy before exchange of contracts/missives.
We may also process confidential data about you including bank account information and property access codes.
Automated decision making and profiling
There are some occasions where our computer systems are set up to use pre-programmed criteria to make automated decisions about you, for example your affordability and/or eligibility for the purchase of a shared ownership home. Where there is no human intervention (no staff involvement in the decision process) and this has a legal or significant effect on you, you have a right to challenge the validity of any decisions made in this way and / or to ask us not to process your information in this way. Please contact us for more detailed information or to find out if you meet the criteria to opt out.
Special categories of personal data
Latimer sometimes processes special category personal data about you. Special categories of personal data are: racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a person's sex life or sexual orientation and information about criminal convictions or offences including cautions.
Where Latimer processes this type of data about you it will do so:
- With your consent
- Where we need to protect the vital interests (i.e. the health and safety) of you or another person
- Where you have already made your personal information public
- Where we or another person needs to bring or defend legal claims and/or
- Substantial public interest grounds
To process personal data about criminal convictions or offences, we must have both a lawful basis for the processing and either legal authority or official authority for the processing.
We use this special category data to ensure services are delivered appropriately and to monitor equality, diversity and inclusion. In the case of certain health information, this may be needed for health and safety purposes and / or social protection.
We will apply additional security and confidentiality measures when processing your special category data.
Where provision of this information is optional, we will make this clear at the point of collection and we will ask for your specific informed consent at the time of collecting this type of data.
Where you provide consent for us to process sensitive personal information, you have the right to withdraw this consent at any time.
There may be times where we will not need your consent to process (including sharing) this type of data. This will apply where we are permitted or required to do so by law, for example under Health and Safety Legislation or where processing of this data is necessary in order for us to carry out our obligations under Social Protection Law.
How will we protect information about you?
We will apply appropriate technical and organisational measures to ensure your personal information is secure. For example, we have systems in place to ensure that access to personal information is restricted to authorised individuals on a strictly need-to-know basis.
When we need to share personal data with our contractors, third party suppliers, and business partners, our relationships are governed by our contracts with them which include strict data sharing and confidentiality protocols.
To help us ensure confidentiality of your personal information we may ask you (and any of your representatives) security questions to confirm your identity when you call us and as may be necessary when we call you. We will not discuss your personal information with anyone other than you, unless you have given us prior written authorisation to do so, there is a court appointed deputyship or Power of Attorney or where we have received a clear verbal instruction from you (as a one-off circumstance).
Who will we share your information with?
Sometimes we need to share personal information we hold about you with other organisations that we work with or who provide services on our behalf. When sharing information we will comply with all aspects of data protection law.
Where ‘sharing’ is in our ‘legitimate interests’, we may share your information with:
- Our agents who advertise our developments or properties on our behalf.
- Other organisations in the Clarion Housing Group or that we are working in partnership with that provide services. For example, the contractor who manages the defects period.
- Local authority teams such as environmental health.
- Utility companies (and their representatives) to ensure billing details are correct.
- Independent mortgage advisors, help to buy agents and solicitors.
- Third parties providing services on our behalf. For example a mailing company distributing our newsletter; a research company such as The Leadership Factor (TLF) carrying out a customer satisfaction survey, or a debt collection agency pursuing an outstanding debt.
We are also legally permitted to share your information with organisations such as:
- Agencies committed to protecting public funds and/or preventing fraud in line with the National Fraud Initiative. More information on the work undertaken by the Cabinet Office.
- Police and other relevant authorities (e.g. Department of Work & Pensions, Probation Service, HM Revenue and Customs) in relation to the prevention and detection of crime, the apprehension of offenders or the collection of tax or duty.
- Other statutory organisations e.g. social services, health authorities, Homes England, the Greater London Authority (GLA), the National Housing Federation, as necessary for exercising statutory functions.
- Council Tax Departments to ensure billing details are correct.
- NHBC - to ensure that NHBC can meet their legal obligation to ensure that new home buyers receive the details of their warranty and insurance policy before exchange of contracts/missives.
We may also share information when required by law for example where ordered by the Court or to protect an individual from immediate harm.
There may be occasions where we need to process your information outside of the European Economic Area (EEA), for example where we use a third party computer system supported by employees in the USA. Where we do this we will take all necessary steps to ensure that your information remains secure. You can ask us for more information about how our International Processing arrangements affect you by using the contact details above.
Contact arrangements and promotion of our services
We will routinely use your contact details to respond to your queries and send you information about your lease, property sale or staircasing application. If you have a preferred method of contact, you can make this known to us, but we will use all means of contact available should we need to contact you in the event of an emergency or to enforce the terms of any contract.
We will also communicate with you about any properties and developments you have expressed an interest in as well as other properties in the geographical area that you may be interested in or eligible for, important key messages and news about Latimer and Clarion and about events in your area such as development open days, and information about products and services (of ours and other reputable companies we work with) that we think may be of interest to you and where this will assist us in meeting our objectives. This would include information such as accessing training and employment, financial guidance, energy efficiency and digital support.
It is in our legitimate interests to call you or send you communications of this nature using the contact details we hold for you (text, email or post). You can follow the ‘unsubscribe’ link on any emails you receive or contact us at email@example.com to ask us to stop sending you these types of messages.
Please note, if you opt out of marketing messages, but are still receiving services from Latimer, we will still send you service messages which sometimes may contain a paragraph on marketing.
We will never sell your personal data to 3rd party organisations for marketing purposes.
How long will you keep my data?
Latimer only holds records during the period of our relationship and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us.
We have a document retention schedule which sets out how long we keep different types of information for. This is based on National Housing Federation guidance, legal requirements and best practice. Please contact us if you would like any more information.
Your rights in relation to your data
Latimer is committed to upholding your rights in respect of your personal data.
The right to be informed
Through the provision of our suite of privacy notices, we will be open and transparent about how and why we use your personal information.
The right of access
You have a right to ask us what personal information we hold about you and to request a copy of your information. This is known as a ‘subject access request’ (SAR).
The best way to do this is to put your request in writing or ask us for a copy of our template form. When a Subject Access request is made, we will take reasonable steps to verify your identity before we can proceed so you may wish to submit a copy of your photo ID with your request to save time.
If you are seeking to obtain specific information (e.g. about a particular matter or from a particular time period), it helps if you clarify the details of what you would like to receive in your request. Very broad requests are likely to require clarification so we can make sure we know what information you require.
If someone is requesting information on your behalf they will need written confirmation from you to evidence your authority for us to release this and proof of ID (both yours and theirs).
Where you are unable to put your request in writing, you can contact the Data Protection Team to arrange for your request to be documented on your behalf.
If you choose to make a verbal SAR request, please contact the Contact Centre and request a call back from the Data Protection Team. We aim to contact you within 2 working days and will then send you a copy of the request to verify and attach ID before we start processing your request.
We have 1 calendar month to provide you with the information you’ve asked for (although we will try to provide this to you as promptly as possible). In response to SARs, we will provide you with a copy of the information we hold that relates to you.
Property information such as details of contractor visits, surveys or general property maintenance information is unlikely to constitute your ‘personal information’. If you ONLY require property related information, you do not need to submit a SAR – you can just contact our Contact Centre.
The right to rectification
You can ask us to rectify your personal data if it is inaccurate or incomplete. Please help us to keep our records accurate by keeping us informed if your details change.
The right to erasure
The right to erasure is also known as ‘the right to be forgotten’. In some circumstances, you can ask us to delete or remove personal data where there is no compelling reason for its continued processing. This is not an absolute right, and we will need to consider the circumstances of any such request and balance this against our need to continue processing the data. Our response will also be guided by the provisions of our retention schedule.
The right to restrict processing
In some circumstances you can ask us to restrict processing, for example
- if you disagree with the accuracy of personal data
- if we’re processing your data on the grounds of legitimate interests (as detailed earlier), and whilst we consider whether our legitimate interests override those of yours.
The right to data portability
If the situation arises where it would be helpful for you to move, copy or transfer personal data we hold about you, across different services, you may be able to ask us to do this. Please contact us to discuss.
The right to object
You can tell us if you object to our processing of your personal data:
- based on legitimate interests (including profiling) or for the purpose of historical research purposes. This is not an absolute right and we will need to consider your objection.
- for the purpose of direct marketing (including profiling).
Rights in relation to automated decision making and profiling.
Where a decision which has legal or significant effect on you is made solely by way of automated means (i.e. there is no human intervention in a computer’s decision) you have the right to object to this and depending on the reason for processing, either ask that we stop doing this or we show that we have implemented suitable measures to protect you, for example by explaining how the decision has been made and checking that the system is set up and functioning correctly.
If you’d like to talk to us about your rights, or report a concern our processing of your data you can contact us at firstname.lastname@example.org. Alternatively, if you want to seek an independent view, or report a complaint once we have had the opportunity to respond to you, you can contact the Information Commissioner using the contact details provided at the start of this notice.
Website and cookies
As a website user, we will collect:
- Information about your computer and about your visits to and use of this website (including your IP address, your cookie preferences, geographical location, browser type, referral source, length of visit and number of page views);
- Information relating to any transactions carried out between you and us on or in relation to this website;
- Information that you provide to us for the purpose of registering with us or subscribing to our website services including name, address, email, telephone number and, where relevant, the type of property you are looking for;
- Any other information that you choose to send to us.
We will use this to:
- administer the website and improve your browsing experience by personalising the website;
- provide relevant website services, for example, raising a request for us to contact you, arranging a viewing, submitting a staircasing or property sales application;
- monitor the useage of website to help us improve our services;
- produce anonymous statistical information about our website users to help us develop our website and services;
- deliver tailored advertising to you, on and off our website.
If at any time you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the permission you grant to us.
We also use third party cookies and may share information about your use of our site with our trusted advertising, analytics and social media partners.
Clarion Housing Group is not responsible for the privacy policies or practices of third party websites accessed through links on our site.
Alternatively, you can set your browser so that it will not accept and store any cookie, or if you have a little more time and knowledge you are able to allow only certain ‘trusted’ sites to store cookies on your computer.