Privacy Policy

Rent-flex Privacy Policy

Introduction
The rent-flex platform is jointly owned by the Centre for Responsible Credit Ltd and Well Thought Ltd.

In this Privacy Policy when we refer to “us”, “we”, and “our” we mean the Centre for Responsible Credit Ltd and Well Thought 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 rent-flex account.  You can request that we delete your rent-flex account at any time.

Hosting and maintenance of the rent-flex platform.
The rent-flex digital platform is hosted on Amazon Web Services by the Centre for Responsible Credit Ltd.  It is maintained on our behalf by our software developers, Projektant Ltd who trade under the name ‘Djangohouse’. 

This means that the information you supply to us is retained and processed on secure UK based servers and all your personal data is encrypted.  We provide access to your rent-flex 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 rent-flex platform collects the following personal information directly from you:

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

The rent-flex 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 rent-flex 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 rent-flex platform also collects and stores the rent-flex 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-flex proposal.
  • To identify any additional support needs that you may have, and
  • To help us evaluate the take-up, operation, and impact of the rent-flex scheme.

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

  • Your Housing Association.
  • Well Thought Limited, and
  • Our Research Evaluation Partner, IFF Research Ltd.

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-flex 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 rent-flex 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 determine your rent-flex plan and help them to offer you appropriate support.

Our Research Evaluation Partner
We are working with IFF Research Ltd, who are evaluating the rent-flex programme.  

IFF Research Ltd. 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 rent-flex platform and the impacts that rent-flex has had on your financial circumstances.  

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 do not share any other personal information with them.  

However, we do share anonymised profiling information concerning the usage of the rent-flex platform and the plans that have been generated.  

Our Communications Partner
One of the co-owners of the platform, Well Thought Ltd, have a responsibility to maintain contact with people using rent-flex over the course of the year.

We only share your e-mail address with Well Thought in order for them to send you a monthly e-mail asking about any changes of circumstance you have experienced, as well as to provide tips on budgeting and how to deal with common financial problems.  

This e-mail may ask you to provide further information about any changes of circumstance that you have experienced.  Responding to the e-mail will take you back to our digital platform where your responses will be stored securely.  Your responses will not be made available to Well Thought Ltd.

However, we do share anonymised profiling information concerning the responses to their e-mails.

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

As Directors of the project, the Centre for Responsible Credit Ltd receives anonymised information concerning all aspects of the rent-flex platform’s operations.  This includes the numbers of plans generated and their performance, together with profiling information.

In some very limited circumstances, such as when problems with performance of the platform have been reported or complaints have been made, it may be necessary for the Centre for Responsible Credit Ltd to view individual records on the platform.  In these instances, Centre for Responsible Credit Ltd, will maintain the confidentiality of your personal information. Centre for Responsible Credit Ltd may need to store your information on its own secure cloud-based systems for a temporary period in order to respond to any complaints on our behalf.  Should such a situation arise you will be informed of this.

We don’t sell or share your personal data to anyone else
We will never share or sell your personal data to any other third parties.

Your rights
You have the following rights in respect of information held on the rent-flex 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 rent-flex 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 rent-flex 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 rent-flex 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 rent-flex account.

The right not to be subject to automated decision-making including profiling
The rent-flex 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 rent-flex account.

Your right to complain
Our Executive Director 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/ 

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 14th January 2021.