Privacy Policy

​This Privacy Notice explains what personal information Housing Action Management Ltd ("HAM", "we", "us") collects, why we collect it, how we use it, and what rights you have. It complies with the UK General Data Protection Regulation, the Data Protection Act 2018, and the Data (Use and Access) Act 2025.

If you have any questions about this Notice, or would like a copy in an alternative format (such as large print, Braille, or audio), please contact us using the details at the end of this page.

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1. Who We Are

Housing Action Management Ltd is a temporary accommodation and supported housing provider. Our registered office is 73 Cornhill, London, EC3V 3QQ, and our operational office is at 22 Barrack Street, Colchester, Essex, CO1 2LJ. We are registered with the Information Commissioner's Office (ICO) as a data controller.

 

2. Our Data Protection Officer

We have appointed a Data Protection Officer (DPO), who is responsible for overseeing our compliance with data protection law and acting as our point of contact for the ICO. You can contact our DPO directly at **dpo@housingactionmanagement.co.uk**, or by writing to us at the address in Section 14, marked "For the attention of the Data Protection Officer."

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3. Who This Notice Applies To

This Notice applies to anyone whose personal information HAM may process in the course of our work, including:

- Service users — our tenants, licensees, and residents of our supported and temporary accommodation, and those applying to become one
- Neighbours and members of the local community — people living or working near our properties, including those who contact us with a concern, complaint, or enquiry about a property or resident
- Members of the general public — anyone who contacts us, visits our website, or visits our offices, including landlords, contractors, job applicants, and local authority or partner-agency contacts

Each section below explains what we collect and why. The sections that don't involve you simply won't apply to you.

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4. Information We Collect

If you are a service user or applicant, we collect information:

- when you apply for housing with us, become a tenant, or request services or repairs
- when you apply to become a member of the Association
- from your arrangements to make payment to us (such as bank details, payment card numbers, employment details, benefit entitlement, and other income and expenditure information)

This may include your name, address, telephone number, e-mail address, National Insurance number, next of kin details, proof of identity or photo ID, and — where relevant to your housing or support needs — health information (including disability) and ethnicity.

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If you are a neighbour or member of the local community, we may collect your name and contact details, and the details of any concern, complaint, or report you raise with us — for example, in relation to the conduct of one of our residents or the condition of one of our properties. If you are a witness to an incident we are investigating, we may also record a statement from you.

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If you are a member of the general public, we may collect your name and contact details when you contact us by phone, e-mail, post, or through our website, along with the details of your enquiry. We also collect information from your use of our website, including from cookies and analytics, and from CCTV images if you visit one of our offices or properties fitted with CCTV.

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5. Information We Receive From Third Parties

- benefits information, including awards of Housing Benefit or Universal Credit
- payments made to us
- complaints or other communications regarding a resident's conduct or alleged breaches of their tenancy, including reports from neighbours, other residents, or information obtained from police officials
- reports on the conduct or condition of a tenancy, including references from previous tenancies
- welfare information from relevant Social Services
- enquiries made on someone's behalf, and with their consent, from local councillors and MPs

 

6. Why We Need This Information and How It Is Used

For service users, we use your information to:

- perform our obligations to you under the terms of your Tenancy Agreement
- supply you with the services and information you have requested
- respond to your repair requests, housing applications, and complaints
- administer, support, and improve the services we offer
- contact you about changes to our services that may affect you
- seek your views on our products and services

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For neighbours and members of the local community, we use your information to investigate and respond to the concern or complaint you have raised, to manage tenancy conduct and anti-social behaviour, and to keep you updated on the outcome where appropriate.

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For members of the general public, we use your information to respond to your enquiry, to monitor and improve how our website is used, and to maintain the security of our offices and properties.

Our legal basis for using your personal information is that:

- we need to use it to perform our contract with you
- we need to use it to comply with our legal or regulatory obligations as a housing provider
- you have given us consent to use it for a particular purpose (where consent is required, we will ask for this separately)
- it is in our legitimate interests, or the legitimate interests of a third party, to process it — for example, to identify service improvements, obtain feedback, investigate a complaint from a neighbour, manage tenancy conduct, respond to a general enquiry, or maintain the security of our sites — provided this does not override your rights and freedoms

Where we process special category data (such as health information or ethnicity), we do so where necessary for reasons connected to a service user's housing or support needs, to protect vital interests, for reasons of substantial public interest, or on another basis permitted by law.

Providing your personal information to us is generally necessary for us to enter into and perform your Tenancy Agreement, or to comply with a legal or regulatory obligation. Where provision of information is optional — for example, ethnicity data for equalities monitoring — we will make this clear at the point of collection. If you do not provide information we have asked for, we may not be able to offer you our services, continue to administer any services you already have with us, or investigate a concern or enquiry you have raised.

 

7. Automated Decision-Making and Profiling

We do not use your personal information to make decisions about you through automated means alone, including profiling, that would produce legal effects concerning you or similarly significantly affect you. All decisions that materially affect you — such as housing allocation or tenancy enforcement decisions — are made by a member of our staff. If this changes in the future, we will update this Notice accordingly.

 

8. Our Use of Google Analytics

We use Google Analytics to monitor how our website is used so we can make improvements. This requires us to pass your IP address (but no other information) to Google, which prepares site usage reports for us. Google may also share this information with other Google services and may use it to personalise the ads shown through its own advertising network.

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9. Sharing of Your Information

We treat the information you provide as confidential and it is processed only by our employees or by third-party suppliers based in the UK. We may disclose your information to other third parties, including:

- new business partners or owners, if we enter into a joint venture with or merge with another business
- contractors, if we instruct repair or maintenance works
- Police officials, Local Authority departments, the Fire & Rescue Service, and others involved in a complaint we are investigating
- utility companies and the Local Authority, if we are updating tenancy details
- payment processors, the Local Authority, and the Department for Work & Pensions, if we are investigating payments
- third parties assisting with the compilation and analysis of survey results, where we are conducting a service survey

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If you have raised a complaint with us as a neighbour or witness, we may need to share the substance of your report with the resident concerned in order to investigate it fairly, though we will only share your identity where necessary and, where possible, will discuss this with you first.

Unless required to do so by law, we will not otherwise share, sell, or distribute your information without your consent.

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10. How We Keep Your Information Secure

We take steps to keep your personal information secure, including network passwords, password-protected devices, firewall and anti-virus protection, a secure office environment with CCTV coverage, strict control over removable media, and a Clear Desk Policy in our offices.

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11. How Long We Keep Your Information

We review our data retention periods regularly and will only hold your personal data for as long as necessary for the purpose it was collected, as required by law, or as set out in any relevant contract with you. For service users, this is generally the duration of your tenancy. For neighbours and members of the public, we generally retain your information only for as long as needed to investigate and resolve your enquiry or complaint. After the relevant retention period has expired, your information is securely destroyed or put beyond use.

 

12. Your Rights

You have the right, at any time, to:

- ask for a copy of the information we hold about you (Subject Access Request)
- require us to correct any inaccuracies in your information (Right to Rectification)
- ask us to delete the personal data we hold about you, where applicable (Right to Erasure / Right to be Forgotten)
- ask us to restrict our processing of your personal data in certain circumstances (Right to Restriction)
- object to our processing of your personal data in certain circumstances (Right to Object)
- ask for a copy of your personal information to be provided to you, or to a third party, in a portable format (Right to Data Portability)

- withdraw your consent to processing at any time, where we have relied on your consent

Where you ask us for a copy of your information, we will respond within one month of confirming your identity. Under the Data (Use and Access) Act 2025, we may pause this period where we reasonably need further information from you to locate the data — the clock resumes once you provide it.

If we receive a written request to stop using your information for direct marketing, we will do so immediately. Other requests will be considered on their own merits, and where we refuse a request, we will explain our reasoning in writing.

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13. Data Protection Complaints

You have the right to make a complaint directly to us if you believe we have infringed your data protection rights. We will acknowledge your complaint within 30 days of receipt, and provide a full response without undue delay following investigation by our Data Protection Officer.

If we are unable to resolve your complaint to your satisfaction, you retain the right to escalate it to the Information Commissioner's Office (ICO) at any time. Further information is available at [www.ico.org.uk](https://www.ico.org.uk).

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14. How to Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your rights, or wish to make a complaint, please contact us:

- **By post:** Housing Action Management Ltd, 22 Barrack Street, Colchester, Essex, CO1 2LJ
- **By telephone:** 01206 860271
- **By email (general enquiries):** admin@housingactionmanagement.co.uk
- **By email (Data Protection Officer):** dpo@housingactionmanagement.co.uk

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Housing Action Management Ltd is registered in England and Wales at Companies House (Company No. 07559799). Registered office: 73 Cornhill, London, EC3V 3QQ.

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*This page was last reviewed in August 2026.*