Equity, Diversity, and Inclusion (EDI) and Reasonable Adjustment (RA) data collection
What EDI and RA data do we collect about you?
We collect data at various points when you live in a home we provide. We’ll only collect data when it’s relevant, appropriate, and adds value to our service.
For example, we'll collect data at the first point of contact. This enables us to address and communicate with you appropriately.
We may ask for data about your household and any vulnerabilities experienced by those living there. You don’t have to provide this data if you don’t want to, but it helps us understand customers and ensure our services are fully inclusive and accessible. For example, if someone in your household has difficulty walking, and we’re aware of this, we’ll allow extra time for them to answer the door.
We also ask for diversity data. Although you don’t have to provide this, it helps us get to know customers better and offer fair, equal, and accessible services.
Diversity data includes information about:
- ethnicity
- religion
- sexual orientation
- gender
- disability.
How do we collect this data?
EDI data is collected at various points throughout your journey with us, such as during our lettings / sign-up process, over the phone, through surveys, during home visits, and when using online services. We’ll ask you to review and update the personal information every 12 months.
Why do we collect this data, and how do we use it?
There are many reasons we collect customer data. These include:
- to communicate effectively with customers, colleagues, and stakeholders
- to ensure the advancement of equality, equity, and opportunity by demographics and geographic monitoring
- to manage any requested reasonable adjustments
- to make informed decisions about engagement with our customers
- to identify problems and gaps in our services
- to gain valuable insights to improve services.
Our lawful reason for collecting diversity monitoring data is classified as legitimate interests under Article 6 and Article 9 (g) reasons of substantial public interest of the Data Protection Act 2018.
We collect information about vulnerabilities and disabilities when they're provided to us to manage requests for reasonable adjustments as part of our legal obligations under the Equality Act 2010.
All EDI data is provided to us voluntarily, and you won’t be penalised for not giving us this information. However, where this information is required for reasonable adjustment requests, we may be unable to offer them without further information.
Where is EDI and RA data stored?
All EDI data is stored on our housing management system, Open Housing. We also record the information you provide us about reasonable adjustment requirements.
This information is accessible to employees who require access to your information for work purposes.
Phone calls made to our Customer Resolution Centre are recorded. These recordings are stored on our systems for six months to help us train our employees.
Who has access to this data?
The information provided for EDI monitoring is held in a restricted area on our housing management system, Open Housing. Our service follows best practices and stores EDI information in fields that can be separated and only visible to or editable by the employees who require it to enable them to provide an effective service.
The information you’ve provided about your contact preferences or any requests for reasonable adjustments is held on your record. This information is collected to manage our communication with you and to facilitate any reasonable adjustments agreed. This information is accessible on a need-to-know basis.
This information is also accessible to our housing management system supplier, Open Housing, who hosts this system on our behalf. However, access is limited by request for specific maintenance/development or support purposes only.
Who might we share the data with?
We may share your personal data with companies and individuals who work with us to provide and improve the housing-related services you receive.
These are known as ‘third parties’. Any third parties that we may share your data with must keep your details secure. They must also use them only to fulfil the service they provide you on our behalf. This could include servicing your boiler, conducting maintenance, dealing with new build defects, or improvement works on your home. It could be to help you apply for social security benefits or to protect customers from anti-social behaviour. It could also help us improve services for our customers and communities.
When third parties no longer need your data to carry out this service, they’ll erase your details in line with our procedures. If we need to pass your sensitive personal information on to a third party, we’ll only do so once we’ve got your permission unless we’re legally required to do otherwise.
Examples of the types of organisations we may share your data with are:
- contractors who work with us to provide housing-related services to you, such as heating engineers, plumbers, or carpenters
- local councils, including social services, council tax and housing benefit departments
- government agencies such as the Department for Work and Pensions, HMRC, and Jobcentre Plus
- the Police, Probation Service, or Fire Service.
For more examples, see our Privacy Notice.
How long is the data kept for?
We keep EDI and RA data for the life of your tenancy with us, plus six years after it ends.
How do we protect your EDI data?
We follow best practices, and only employees who require the information to perform their role and provide an effective service will access your record.
It’s important to note that some data will be collected purely for the purposes of equality and diversity monitoring to ensure we’re advancing equality, not unintentionally or unconsciously discriminating against an equality protected characteristic group or missing an equality opportunity.
When assessing access to data, it’s important that we have clarity of purpose and understand when it’s appropriate to withhold data. Having access to data will help employees deliver a great service and support the development of targeted services across CHP that really deliver for our customers.
For us to assess appropriate access to your data, it’s important that the information you provide is accurate and kept up to date. If your circumstances change, which may affect the reasonable adjustment(s) we've put in place for you, please let us know as soon as you can.
Your rights
The law gives you a number of rights to control what personal data is used by us and how we use it. You can find more information on this in the ‘Your rights’ section of our Privacy Notice.