Equality, Diversity and Inclusivity (EDI) privacy notice

What EDI and RA data do we collect about you?

Data will be collected at different points throughout your journey with The Housing Ombudsman Service (HOS). HOS will only collect data at the point that is relevant, appropriate and adds value.

For example, at the first point of contact - we will collect data that enables the reception team to address and communicate with you appropriately, plus other demographic data that provides insight into who is contacting us.

If the contact results in a case being created, additional data will be collected that will help the Housing Ombudsman Service manage the case and support you; this approach will continue throughout the customer journey with the Housing Ombudsman. We may ask for data about your household and any vulnerabilities experienced by those living at the address. This information is not compulsory but where provided, may be recorded and used in order to risk assess your case and ensure that it is triaged appropriately.

Diversity monitoring data is provided to us directly by you or your authorised representative where you choose to provide it. Providing this data to us is not compulsory but it will help us to understand our service users and ensure our services are fully inclusive and accessible.

Diversity monitoring data is special category data under the UK GDPR and includes information regarding:

• ethnicity
• health data including information about disability
• sexuality and gender identification, including reassignment
• religious beliefs

How do we collect this data?

Information about Equality, Diversity and Inclusivity is collected at various stages of the Dispute Resolution process such as:

• via the EDI section of our complaint webform
• via telephone when speaking to one of our Advisors or reception services
• via feedback surveys at complaint resolution

Information about reasonable adjustments can be obtained:

• via the complaint webform
• via telephone when speaking to one of our Advisors or reception services
• via correspondence between yourself or your authorised representative, and the Housing Ombudsman Service

Why do we collect this data and how do we use it?

There are many reasons we collect customer data, and data is collected for a range of purposes, these include:

• to effectively communicate 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 your case and engagement with our customers
• to identify problems and gaps in service, both ours and member landlords
• to gain valuable insights to improve services
• to invest resources to maximise their return on investment

Our lawful basis for the collection of diversity monitoring data is the public task obligations as it is in the public interest for us to ensure compliance with the Equality Act 2010 and monitor and promote equal accessibility for all customers.

As diversity monitoring data is special category data, we also require an additional legal basis for processing. We process diversity monitoring data under Article 9 of the UK GDPR for reasons of substantial public interest to ensure compliance with the Equality Act 2010 and Schedule 1 of the Data Protection Act 2018 to promote and maintain equality inaccessibility of services.

We collect information about vulnerabilities and disabilities when it is provided to us in order to manage requests for reasonable adjustments as part of our legal obligations under the Equality Act 2010.

All EDI monitoring data is provided to us voluntarily and you will not be penalised for not offering us this information however, where this information is required for requests for reasonable adjustment, we may not be able to offer requested adjustments without further information being provided.

Where is EDI and RA data stored?

All EDI monitoring data is stored on our case management system; WorkPro. As detailed above, this data is kept separate from other information relating to the case management and is only accessible to staff who require access to compile our EDI monitoring dashboards or make decisions about EDI monitoring and accessibility in the Organisation.

Information provided to us by you about reasonable adjustments requirements is also recorded in appropriate record fields on our casework management system; WorkPro. This information is accessible to caseworkers and those who require access to the case for work purposes. Any correspondence you submit to the Housing Ombudsman Service which details any needs related to EDI and RA are retained as document files and saved to the case record. These too are accessible to caseworkers and anyone requiring access to the case record for work purposes.

Recordings of telephone calls to the Housing Ombudsman Service are stored by our outsourced reception service on a system called MaxContact or on our own telephony system.

Who has access to this data?

Information provided to us for the purpose of EDI monitoring only, is contained in a restricted area on our case management system; WorkPro. The Housing Ombudsman Service follows best practices and stores EDI information in fields that can be separated and then only visible to or editable by the colleagues who require the information in the performance of their role to enable them to provide an effective service. Caseworkers working on your case will not see this data on your case record.

Information you have provided to us regarding contact preferences or the request of a reasonable adjustment is held on your personal profile record which is then attached to any case you raise with the Housing Ombudsman Service. This information is gathered to manage contact with you and to facilitate any reasonable adjustments agreed. This information is accessible to caseworkers and HOS staff with access to the casework management system. It is also accessible to our outsourced reception services; HGS.

This information is also accessible to the suppliers of our case management system WorkPro who host 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?

Aggregated data in respect of EDI monitoring can be shared with colleagues and stakeholders in a non-identifiable way in the format of EDI dashboards.

We do not routinely share personal information about EDI and RA characteristics with any external agencies however we are obliged to consider one off disclosure requests where exemptions in the Data Protection Act allow for this. These can include:

• requests from law enforcement agencies where the information is required to prevent and detect criminal activity or apprehend and prosecute offenders
• requests from Legal representatives where the information is required to facilitate legal claims or the obtaining of legal advice
• requests from individuals relating to their rights of access under the Data Protection Act
• requests from agencies involved in safeguarding where the information is required to protect children and vulnerable adults.

In each case, disclosure will be considered on a case by case basis and a proportionate response provided.

How long is the data kept for?

We scan all documents and usually destroy paper copies of the documents unless you ask us to return those documents.

All electronic documents are deleted three years from the date of closure of a case unless there is a specific reason to retain them longer. The personal information on the case itself will remain on our case management system for 7 years after which, the personal information from that record is deleted and remains as a skeleton record only.

Telephone recordings are deleted after 6 months.

How do we protect your EDI data?

Access to WorkPro data is recorded, and every action by colleagues is logged in the History tab to show who has viewed, downloaded, created, edited or deleted any data.

HOS follows best practices and stores EDI and personal information in fields that can be separated and then only visible to or editable by the colleagues who require the information in the performance of their role to enable them to provide an effective service.

It is important to note that some data will be collected purely for the purposes of equality and diversity monitoring to ensure we are advancing equality, not unintentionally or unconsciously discriminating against an equality protected characteristic group or missing an equality opportunity.

Therefore, not all data is visible to colleagues in their daily activities.

When assessing access to data it is important that we have clarity of the purpose and when it is appropriate for the data to be withheld.   Data should be hidden when it holds no value to the process and removes the potential for unconscious bias, where judgements and assumptions about people could be made based on previous experience and stereotyping.   And equally important to recognise that having access to the data will help colleagues process the case, and assist in the decision-making processes during an investigation.

In order for us to assess appropriate access to your data, It is important that the information you provide to us is accurate and kept up to date. If your circumstances change which may affect the reasonable adjustment(s) we have put in place for you, please inform us at your earliest opportunity.

Your rights

The UK GDPR provides you with Individual Rights which you can submit to the Housing Ombudsman Service for our consideration. To view these rights and how to submit them, please view the ‘Your rights’ section of our Privacy Notice.