Privacy Policy

FlexMyRent Privacy Policy

Introduction
The FlexMyRent platform is owned by the Centre for Responsible Credit Ltd.

In this Privacy Policy when we refer to “us”, “we”, and “our” we mean the Centre for Responsible Credit Ltd.

Your privacy is important to us. This privacy statement explains what personal data we collect, why we collect it, and how we use it.  

We comply with data protection law and its principles in respect of your personal data.  This means that your personal data will only ever be collected and treated lawfully, fairly, and transparently:

• Personal data is only collected and retained if relevant to the purpose that has been agreed by you;
• Personal data is kept accurately and up to date;
• Personal data is only retained for as long as necessary, and only for the agreed purpose;
• Your personal data is protected securely.

We only obtain and share personal data with your express consent, and any personal information that you provide to us is only kept for the duration of your FlexMyRent account.  You can request that we delete your FlexMyRent account at any time.

Hosting and maintenance of the FlexMyRent platform.
The FlexMyRent digital platform is hosted on Amazon Web Services by the Centre for Responsible Credit Ltd.

This means that all your rent account information, and any other data provided to us by your Housing Association, is retained and processed on secure, encrypted, UK based servers.  However, we use a third party provider, MailChimp, to send out our e-mails to you.  This means that your name and e-mail address are sent to U.S servers.  You can read about their data security policy at https://mailchimp.com/en-gb/about\security

We provide access to your FlexMyRent proposals and your answers to our questionnaire to your Housing Association through our platform, but only when you expressly give your permission by submitting these.  

What information do we collect?
The FlexMyRent platform collects the following personal information directly from you:

• Your name
• Gender
• Address
• Telephone number
• Tenancy Reference number
• Date of birth
• The name of your Housing Association

The platform also asks for sensitive information from you in respect of your ethnicity, employment status, health, and household and financial circumstances.  

With your express consent, the platform also obtains information from your Housing Association concerning your rent account, including your annual rent liability, outstanding balance, and any Housing Benefit entitlement that you have.  This information is collected directly from your Housing Association by secure data transfer from their software systems to our platform.

The platform also collects and stores the FlexMyRent proposals that you generate on the platform.  

Why do we collect this information?
We collect this information:

• To verify your identity with your Housing Association.
• To help you generate your preferred, personalised, rent payment proposal.
• To identify any additional support needs that you may have, and
• To help us evaluate the take-up, operation, and impact of the FlexMyRent scheme.

Who do we share your personal information with?
The FlexMyRent platform shares information with these other parties:

• Your Housing Association and
• Our Research Evaluation Partners.

However, the extent of data sharing with each of these organisations differs.

Your Housing Association
With your express consent, we share your personal information with your Housing Association.  This allows them to consider, and make a decision on, your rent payment proposal and to offer any additional support that you may need.

In order to share this information, we provide your Housing Association with a secure log in to a separate interface with our platform.  This provides them with access to your FlexMyRent proposal and personal data.  However, your Housing Association will only be able to see this information once you have provided your express consent for them to do so.  We also do not allow them to see the sensitive information that you have provided to us concerning your ethnicity.  We only provide them with access to the information needed for them to make a decision about your rent payment proposal and help them to offer you appropriate support.

Our Research Evaluation Partners
We are working with external research organisations who are helping us to evaluate the FlexMyRent programme.  

These may be provided with your e-mail address and telephone number in order for them to contact you and ask about your experience of using the FlexMyRent platform and the impacts that FlexMyRent has had on your financial circumstances. We may also provide them with some background information about your use of the scheme and the proposals you have created to inform those discussions.

The information that you provide to them is covered by their own data protection and privacy policies, which they will explain to you if you are contacted.

We may also share anonymised profiling information concerning the usage of the FlexMyRent platform and the plans that have been generated with external consultants.  With your consent, your Housing Association may also provide us with anonymised information concerning your rent account over the preceding 12 months.  This is to allow us to assess what difference the FlexMyRent scheme is making to rent payments and arrears levels.  

Anonymised data regarding historic rent account information and the use of the FlexMyRent scheme is retained for two years following the closure of your FlexMyRent account to allow us to evaluate the programme.

When transferring any data to or from our research evaluation partners we use secure, encrypted, file transfer software and we store this on secure cloud based servers. Access to the data is limited to only those staff who need to analyse it and all data is deleted once the research findings have been written up on an anonymised basis.

Our Project Directors
The FlexMyRent project is being directed by the Centre for Responsible Credit Ltd.

As Directors of the project, the Centre for Responsible Credit Ltd has access to information concerning all aspects of the FlexMyRent platform’s operations.  This includes details of the individuals using the service, the plans generated, and their performance. To protect this information and maintain confidentiality, we ensure that all personal data is encryptyed and stored by Amazon Web Services on UK based systems.  

However, in some circumstances, such as when problems have been reported with performance of the platform or a complaint has been made, it may be necessary for the Centre for Responsible Credit Ltd to store your information on its own secure cloud-based systems for a temporary period.  Should such a situation arise you will be informed of this.

From time to time, Centre for Responsible Credit Ltd may contact you to ask if you would be willing to participate in our other research projects. However, you are under no obligation to do so, and this will not affect your access to the FlexMyRent scheme. 

We don’t sell or share your personal data to anyone else
We will never sell your personal data to any other parties, and will only ever share it with others for the reasons above. 

Your rights
You have the following rights in respect of information held on the FlexMyRent platform:

The right of access
You have the right to be provided with a copy of your personal information (the right of access).  You can view the information that we hold by logging into your FlexMyRent account and viewing this on the summary page.

The right to withdraw your consent
You can ask us to stop processing your data at any time.

The right to restrict processing
You can ask us to suspend the processing of your data at any time, for example where you need to amend the data that we hold about you.

The right to be forgotten
You can delete your FlexMyRent account at any time.  Further information about this is available in the Frequently Asked Questions section of the platform.

The right of rectification
You can amend the information we hold about you at any time by logging into your FlexMyRent account and changing any of the entries on the system.

The right to data portability
You have the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or to transmit that data to a third party

The right to object
You have the right to object to our processing of your personal data for profiling or any other purposes.  This will ordinarily require you to delete your FlexMyRent account.

The right not to be subject to automated decision-making including profiling
The FlexMyRent platform does not currently involve any automated decision-making.  The platform does generate profiling reports about its users, but these are anonymised.  You have the right not to have your data included in these reports, but this will ordinarily require you to delete your FlexMyRent account.

Your right to complain
Our Chief Executive oversees our data protection policies, protocols and Privacy Policy. For questions about this Privacy Policy, our data protection policies or how we handle and use your personal data, please contact damon.gibbons@responsible-credit.org.uk 

You also have the right to contact the Information Commissioners Office to file a complaint https://ico.org.uk/make-a-complaint/  The Centre for Responsible Credit Ltd is registered with the Information Commissioners Office (reference number ZB264836).

Amendments to this privacy policy
We may amend this privacy policy from time to time to keep it up to date with legal requirements and the way we operate our business. 

This privacy policy was last amended on 6th July 2022.