Complaints Privacy Statement

1. Purpose of our privacy statement
1.1 Under the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), we are required to explain to you why we are asking for this information about you, how we intend to use the information you provide and whether we will share this with anyone else.

2.Who are we?
2.1 Sanctuary LumaLiving is a brand name used by Sanctuary Home Care Limited and Sanctuary Housing Association, each a part of Sanctuary Group (“Sanctuary”). We are one of the UK’s leading providers of housing, care and commercial services. Our address is Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ.

3. Our data protection officer
3.1 Our Data Protection Officer is responsible for overseeing what we do with your information and monitoring our compliance with data protection laws.
3.2 If you have any concerns or questions about our use of your personal data, you can contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing dataprotection@sanctuary.co.uk.

4. Why are we collecting your information?
4.1 Sanctuary aims to provide good quality homes and deliver high quality services. However, it is recognised that there may be times when something goes wrong, or customers are dissatisfied.
4.2 The information you provide will be used to process, investigate, and respond to your complaint.
4.3 It will also be used to identify service failure and improve our services more widely. Information may be passported to other parts of Sanctuary to address the specific service failure identified.
4.4 We may also receive personal information indirectly, from the Housing Ombudsman or your Member of Parliament if you have raised the matter with them, as well as our contractors as part of our investigation.

5. What information are we collecting?
5.1We collect and process the following information:
• Name
• Contact details
• Complaint details
• Third party authority (if applicable)
• Financial / bank details (if applicable for the payment of a good will gesture or compensation).
5.2 Depending on the nature of your complaint, some of the information which we collect may be special categories of personal data (also called sensitive personal data), including information relating to your health.

6. What is our lawful basis for using your information?
6.1Under Article 6 of the UK GDPR, the lawful basis we rely on for processing this information is:
(f) Our legitimate interests or that of a third party, enabling customers to raise a complaint, identify and address failures in service.
6.2 In accordance with Article 9 (UK GDPR) the condition we rely on for processing special categories of personal data is:
(a) Explicit consent

7.Sharing your information
Members of Sanctuary Group
7.1 Sanctuary Group is made up of a number of related companies. We will share your information with other members of Sanctuary Group where necessary to investigate and resolve your complaint.
7.2 For more information on which companies make up Sanctuary Group, please go to www.sanctuary.co.uk/about-sanctuary.
Regulators and other legal obligations
7.3 We may also be required to share your information with our regulators who are permitted access to this information by law and with other organisations where we have a legal obligation to share the information with them.
7.4 We may share your information with the Housing Ombudsmen if you have raised a complaint with them about Sanctuary to support this process.
Other Organisations
7.5 Where issues of service failure have been identified, it may be necessary to share information about you with our contractors and sub-contractors in order to address this, for example where a repair has not been completed or to your satisfaction. We will only share your information about you with contractors and sub-contractors where it is relevant and necessary to address your individual needs.
Data Transfers
7.6 We use a third-party processor, for technical IT support with our internal systems, who may transfer your data outside the UK to India.
7.7 This transfer is made in accordance with Article 46 of the UK GDPR as we have ensured a similar degree of protection is afforded to it through our processor implementing an International Data Transfer Agreement.
7.8 For further information on the safeguards implemented, or to access a copy please email dataprotection@sanctuary.co.uk.

8. Can we use your information for any other purpose?
8.1 In limited circumstances, we may use your information for a purpose other than those set out in this policy. If we intend to do so, we will provide you with information relating to that other purpose before using it for the new purpose.

9. Security of your information
9.1 The information that you provide will be stored securely. Our technological and organisational security measures and procedures reflect the seriousness with which we attach to the confidentiality, integrity and availability of your information.
9.2 Only relevant members of staff will access the information you provide to us.

10. Storing your information and deleting it
10.1 We will not keep your personal data for longer than we need it or are required to by law.
10.2 Information relating to complaints raised by tenants, will be retained for 6 years following the end of your tenancy.
10.3 Complaints raised by members of the public will be retained for 5 years following closure of the complaint.
10.4 Financial Information relating to payments of compensation and gestures of goodwill will be retained for 6 years from the end of the last financial year to which they relate.

11. Your rights
11.1 In relation to the information which we hold about you, you are entitled to:
11.1.1 Ask us for access to the information;
11.1.2 Ask us to rectify the information where it is inaccurate or is incomplete;
11.1.3 Ask us to erase the information and take steps to ask others who we have shared your information with to also erase it;
11.1.4 Ask us to limit and restrict what we do with your information;
11.1.5 Object to our use of your information and ask us to stop that use;
11.1.6 Ask us to provide the data you have provided us in a structured, commonly used, and machine-readable format (for example, a CSV file) in order transmit the data to another data controller.
11.1.7 Where we are using your information because you have provided your consent to that use, you are entitled to withdraw your consent at any time. The lawfulness of our use of your information before consent was withdrawn is not affected;
11.1.8 Challenge the decision of any automated decision-making and/or profiling that is applied to your personal data as part of the processing;
11.2 Our obligations to comply with the above rights are subject to certain exemptions.
11.3 To exercise any of the rights referred to above, you should contact our Data Protection Officer by writing to The Data Protection Officer, Sanctuary House, Chamber Court, Castle Street, Worcester, Worcestershire, WR1 3ZQ or emailing dataprotection@sanctuary.co.uk.

12. How to complain
12.1 If you have any concerns about our use of your personal information, you can contact our Data Protection Team on dataprotection@sanctuary.co.uk.
12.2 You also have the right to complain to the Information Commissioner’s Office (the ‘ICO’) if you are not satisfied with the way we use your information. You can contact the ICO by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.