Membership privacy and data submission notice

1. Controller and contact

HOUSING ASSURED LIMITED, trading as HousingAssured, is the controller for its own website account, application, scheme administration, review moderation and decision records. It is registered in England and Wales, company number 17526556, with registered office at Ashton Old Baths, Stamford Street West, Ashton Under Lyne, United Kingdom, OL6 7FW. Contact info@housingassured.co.uk, subject Privacy, or write to the Privacy contact at that address.

The operator-provided email is now published for privacy enquiries and complaints. The team allocates a responsible privacy handler and cover internally; individual names are not published. Any legally required data protection officer or representative arrangements remain subject to the actual service and legal review. This is a draft notice; it does not claim that supplier, transfer, deletion or live-referral arrangements have been completed.

2. Information covered

The platform uses signed-in account identity and verified email; application and business contact details; terms/declaration acknowledgements and their dates/versions; membership and assessment decisions; notifications; company reviews and moderation records; private operational audit returns; and eligible property, enquiry and referral records. Payment-service identifiers and status may be stored when payments are enabled. Full payment card details are handled by the payment service, not collected by the membership form.

Business accounts can still contain personal information about representatives or sole traders. Public-register information, relevant regulator findings and material supplied by members or reviewers may be used for proportionate verification. The operator must record sources and provide additional transparency where required for information obtained indirectly.

3. Purposes and proposed lawful bases

Proposed purposes are to assess applications and evidence, administer accounts and subscriptions, record agreement versions, operate permitted tools, moderate content, communicate service decisions, protect platform security and handle disputes. For business representatives, the proposed basis is legitimate interests in operating and protecting an accountable business service, subject to a documented balancing assessment. Where an individual is personally party to the contract, necessary pre-contract/contract processing may apply instead.

Relevant legal obligations may support tax, accounting or legally required disclosures once applicable. Establishing or defending legal claims can justify necessary records subject to the correct basis and safeguards. These proposed bases must be confirmed against actual operations before live use. Optional marketing would require its own lawful approach and choice; this application does not enrol a person in marketing.

4. Aggregate audit returns

The structured audit return accepts reporting dates, a source category, organisation-wide counts, overdue age bands and declarations. It has no field for resident names, resident IDs, addresses, exact last-seen dates, diagnoses, convictions, safeguarding narratives or files. Measures can be marked not applicable, not recorded or withheld for privacy. Unknown or withheld information is not treated as zero exceptions.

Providers must assess whether totals could identify someone through a small population, rare event, other published information or linkage across measures. Withhold affected measures and agree a broader or controlled verification approach where necessary. Removing names is not sufficient by itself. Keep resident-level source reports within the provider's controlled systems.

5. Sensitive information and data roles

Only fictional resident and referral examples are accepted in the pilot. Do not send actual referral packs, health information, criminal-offence details, safeguarding narratives or resident identifiers through preview forms, email or uploads. Aggregate reports must also be checked for identification through small numbers or linked data.

For a future live portal, assess each purpose and lawful basis, the necessary Article 9 condition for special-category data and the separate legal authorisation/condition for criminal-offence data under Article 10 and UK law. Complete a DPIA where required and an appropriate policy document where applicable. General membership agreement, an application checkbox, claimed anonymisation or a two-step code is not blanket permission.

The fictional staged pilot first shares a limited summary with selected verified providers, then allows named-account requests and referrer-approved assessment and separate handover permissions, with MFA, purpose restrictions, expiry, revocation and case access history. The administrator sandbox is isolated by its owner. Real confidential referrals remain disabled. Pseudonymised or linkable summaries can still be personal data.

Providers and referrers remain responsible for their own source records and lawful disclosures. HousingAssured remains responsible for its own purposes and handling. Establish controller/processor or joint-controller roles and the appropriate written agreements; these terms do not substitute for Article 28 or Article 26 arrangements or a person's rights.

6. Access publication and recipients

Private application evidence and audit returns are available to the applicant's authorised account and authorised membership reviewers. The staged trial accepts fictional information only: its limited summaries are restricted to invited eligible provider accounts and private packs need separate named-account approval. The administrator sandbox is isolated from other accounts and is not a live cross-company sensitive-data service. Before live release, receiving organisations, access criteria, onward-sharing restrictions and audit trails must be documented and tested.

Public profile summaries, score reasons and moderated reviews can be read without paid membership, within the pilot's existing audience restriction. Private audit figures, resident records, evidence uploads and reporter account identity are not public directory content. A provider may receive a notification about a submitted review and appropriate redacted details to respond; this is not permission to disclose the reviewer's identity or confidential case evidence.

An enabled property QR opens a public read-only brief immediately, without an inspector code, staff contact, membership or sign-in. The brief excludes occupancy and permission references, private property names/addresses, resident details, raw notes and files. Sensitive-location briefs also omit free-text notices and contacts and use generic maintenance wording. Work contacts are published only where approved for non-sensitive briefs; use role/team contacts and explain this sharing to staff. A copied link opens the same limited information. Disable the link if even that brief could expose a protected location.

Necessary information may also be received by the identified hosting, identity, lookup, payment or mailbox suppliers, authorised advisers, or an appropriate authority where there is a lawful reason. Log the purpose and minimum disclosure. The final notice must complete supplier roles and any other actual recipients before live operation.

7. Services transfers and security

Identified services in the current implementation are Sites hosting and ChatGPT sign-in supplied through OpenAI, with Cloudflare hosting/storage infrastructure; Postcodes.io postcode/place lookup; and the Photon address service at photon.komoot.io. Address searches pass the location query through our server to those lookup services, without account credentials or resident case records. Do not enter sensitive-location or resident details in a general search. Our application caches address suggestions for up to five minutes; supplier request logs have their own retention.

Stripe is selected for future subscriptions: account/customer/subscription identifiers, price, billing status and necessary organisation/contact information will be exchanged when enabled. Checkout collects payment details on Stripe's hosted service; our application does not collect full card numbers. Live Checkout is disabled. Postmark is supported by the code for future transactional email but no production sender is configured; it is not described as an active email recipient. Mail sent to info@housingassured.co.uk is handled by the operator's mailbox provider, whose identity and retention must be added to the supplier register.

The above identifies implemented services, not a completed processor/transfer assessment. Confirm each contracting legal entity, its role, subprocessors, processing locations, contractual protections and appropriate UK transfer mechanism before live use. Do not assume UK-only processing. Ask the Privacy contact for the current supplier/transfer information and copies or explanations of applicable safeguards; do not claim an agreement or safeguard is in place before it is verified.

Application controls include signed-in ownership and reviewer checks, restricted file access, raw-body Stripe signature checking when configured, and separate revocable noticeboard access. Complete staff access reviews, incident response, backup handling and operational security arrangements before launch. No system promises absolute security.

8. Draft retention schedule

Proposed live periods for approval are: unsuccessful applications, 12 months after final closure; aggregate audit returns, 24 months after submission; closed minimal referral records, 6 months after closure; and necessary contract acceptance, final decision and financial records, normally up to 6 years after the relationship or relevant accounting period ends. These are proposed maximum routine periods, with earlier deletion where records are unnecessary and lawful exceptions recorded.

Property/noticeboard records, review evidence, access logs, mail, complaint files and backups need a completed category-by-category schedule before live use. Limit them to what is necessary for the service, security, fair moderation, handover or legal claims. Revoke inspector access on expiry, withdrawal or lost entitlement; revocation is not the same as deletion of underlying records. Do not retain sensitive referral packs simply because membership existed.

There are no automatic physical-deletion jobs enforcing these proposed live-service periods. In the fictional staged trial, a closed case becomes unreadable after 30 days and a referrer cleanup action removes due private details and files, with minimum audit history retained. Complete the live deletion/export workflow, backup lifecycle, supplier deletion and approved audit retention before launch. Document any legal hold, its scope and review date; explain an applicable exemption when responding to a request.

9. Your rights and objections

Depending on the lawful basis and circumstances, you may have rights to access, correction, erasure, restriction, portability and objection. In particular, you may object to processing based on legitimate interests by emailing info@housingassured.co.uk with subject Privacy - objection. We must consider that objection. Consent for an optional purpose can be withdrawn without affecting earlier lawful processing.

Use the same Privacy contact or registered-office postal address for other rights requests. You need not be a member or use a prescribed form. We will make proportionate identity checks and follow the legal time limits and any lawful extension rules, explain our decision and any refusal or retention exception. A privacy complaint and a data-access request have different procedures; the 30-day complaint acknowledgement is not an extension of a rights-request deadline.

You may complain to the Information Commissioner's Office at https://ico.org.uk/make-a-complaint/ and retain your other remedies. Contacting us does not waive that right. Do not include another person's sensitive case material in an initial email; ask for an appropriate secure route.

10. Required information and automated decisions

Application identity, service scope and the relevant declarations are needed to administer an application. Without sufficient evidence, assessment or paid access may be unavailable. Applicants should raise an excessive or unlawful information request so an appropriate alternative can be agreed. Providing a privacy acknowledgement does not require giving up data rights.

The current audit return does not automatically determine a provider's score or certification. Standards and adverse decisions require human review and reasons. Payment access uses verified subscription and approval status. Any future solely automated decision-making or material new processing requires assessment and updated information before it is introduced.

11. Changes and cookies

Record and publish the notice version and explain material processing changes before they apply where required. Keep a record of privacy information provided. Terms acceptance and privacy acknowledgement are separate from consent to cookies or marketing.

Before live launch, complete a cookie/storage and analytics inventory, provide the appropriate notice and obtain consent for non-essential technologies where required. This draft does not assert that every supplier uses only essential cookies or that a consent mechanism has already been implemented.

12. Privacy complaints procedure

Anyone can raise a concern about how we handle personal information. Email info@housingassured.co.uk with subject Privacy complaint, or write to the Privacy contact at our registered office. Give a brief description, relevant dates/reference and the outcome sought, using only necessary information. We will help identify an accessible alternative where needed; no paid membership or particular form is required.

We will acknowledge a data-protection complaint within 30 days of receipt, take appropriate steps to investigate without undue delay, and keep you informed of progress and the outcome. Record the complaint, assign a responsible handler, check conflicts and access only necessary evidence. Communicate the findings, reasons, corrective action where needed and how to challenge the outcome or contact the ICO.

If the complaint concerns its handler or a conflict, allocate it to someone else. Internal privacy case ownership, cover and tracking/escalation arrangements must be in place before live operation; individual names and signed declarations are kept private. The statutory acknowledgement requirement applies to the operator's actual personal-data handling now; describing the procedure is not a claim that a completed complaints-management programme or automated acknowledgement is operating.