Privacy Notice for Shared Ownership

1. Service Area: Help to Buy: Shared Ownership
In order to provide services to residents and applicants, St. Arthur Homes Ltd may need to process personal
details held about you and your household. This document (Privacy Notice) explains how your information will
be held and processed by St. Arthur Homes in relation to these services. The Privacy Notice contains
information about:
• Who we are
• Why we are collecting your personal information
• The legal basis for using your information
• Who we may share your information with
• How you can access the information we hold about you
• How long we keep information about you

2. Who we are:
St. Arthur Homes is the data controller responsible for your personal data and is a Private limited Company
and a Registered Social Landlord (registered in England under company registration number 05948739), and a for profit Registered Provider (registration number 4753) regulated by the Regulator of Social Housing. Our registered office address is located at 95 Handel House High Street, Edgware, Middlesex, England, HA8 7DB.

3. What personal data we collect and why
Personal data we collect includes name, address, employment status, date of birth, telephone number,
employment details, financial details, family details, housing details. St. Arthur Homes will use your
information for the following purposes:
• to offer shared ownership homes for you to purchase;
• to offer any services which may be accessed by you or your household;
• to train our employees who are delivering these services to you;
• to deal with customer service queries/ support you;
• to monitor the quality of our goods and services;
• to research and plan new services;
• to send you marketing communications; and
• for business administration and legal compliance.

This document covers information you have provided direct to St. Arthur Homes and information which has
been shared with us by other organisations. If we don’t need your personal information we won’t ask you for
it.

4. The legal basis for using your personal data
We rely on the following legal bases for collecting and processing your personal data:
• our legitimate interests to provide you with services, to provide you with good customer service and
to provide you with marketing communications (where we are not relying on your consent);
• to perform our obligations in accordance with any contract we may have with you;
• your consent, where relevant in relation to email marketing communications; and
• any legal obligations imposed on us.

5. Special Category Data
Special category data is personal data which the GDPR says is more sensitive, and so needs more protection.
For example information about an individual’s race, ethnic origin, politics, religion, trade union membership,
genetics, health, sex life, or sexual orientation.

6. Sharing your Information
We will only share personal information with others when we are legally permitted to do so. When we share
personal information with others, we put contractual arrangements and security mechanisms in place to
protect the personal information and to comply with our data protection, confidentiality and security
standards. Organisations we may share your information with:
• Other organisations within our group of companies
• Financial Advisors
• Consultants supporting St Arthur Homes
• Managing Agents
• Estate Agents
• Government housing agencies
• Local Authorities
• Service persons requiring legal and legitimate access
• Third party organisations that support us in providing our services to you, e.g. running and managing our
internal IT systems, cloud based software systems and security and storage
• Payment providers
• Third parties who assist our business, for example in relation to marketing and other services.
• Auditors, lawyers, accountants and other related organisations
• Law enforcement or other government and regulatory agencies
This list is non-exhaustive and there may be circumstances where we need to share personal information with
other third parties in order to provide our services and carry out our regulatory duties as effectively as we
can.

7. Data Retention
We will hold your personal information for as long as necessary for the purposes it has been collected. We
generally envisage this to be a period of 2 years where your application does not proceed to completion.
Where you do proceed to completion, we will hold this information for 6 years from the date of the end of
your tenancy/ownership. If you have opted out of receiving marketing communications from us, we will need
to retain certain personal information indefinitely so we know not to send you further marketing
communications in the future.

8. What if you fail to provide your personal information?
Where we are required by law to collect your personal information, or we need to collect your personal
information under the terms of a contract we have with you, and you fail to provide that personal information
when we request it, we may not be able to perform the contract we have or are trying to enter into with you.
This may apply where you do not provide the personal information we require in connection with an
application for tenancy or ownership with us. In this case, we may have to cancel the provision of the relevant
services to you, in which case we will notify you.

9. Accessing the information we hold about you and other rights

You have the following rights in relation to the personal information we hold about you:

• Access: You have the right to request, in writing, details of the personal information that is held about
you and also the right to access a copy of the personal information. St. Arthur Homes will not charge a
fee to access your data.
• Restriction: Your right to ask us to block or suppress the processing of your personal information in
certain circumstances, for example if you object to the processing or you contest the accuracy of the
information.
• Rectification: Your right to request us to amend any of your data which you feel is inaccurate.
• Erasure: Your right to ask for information to be erased, in certain circumstances, for example where
we no longer need it or you withdraw your consent (where applicable).
• Data portability: Transfer your information electronically to another service provider.
• Object: Your right to ask us to stop processing your information where:
o We are relying on our own or someone else’s legitimate interests to process your personal
information, except if we can demonstrate compelling legal grounds for the processing; or
o Processing your personal information for direct marketing. St. Arthur Homes will only market to
you offers relating to your tenancy and ownership.
• Withdraw consent: If we rely on your consent (or explicit consent) as our legal basis for processing
your personal information, you have the right to withdraw that consent at any time.
• Your right to lodge a complaint with the supervisory authority: If you have a concern about any aspect
of our privacy practices, including the way we have handled your personal information, you can
report it to the Information Commissioner’s Office (ICO). You can find details about how to report a
concern on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123
1113

If you give consent for us to use your information, you may withdraw this at any time. However, this may
affect our ability to continue to provide you with a service.

10. Further Information
If you have questions about how we process your information or want to exercise your rights set out above,
we would ask you to contact our data protection officer using the email or postal address below.

Email: info@starthurhomes.com
St. Arthur Homes
16 Bakers Mews,
London, W1U 3HE

Changes to this Privacy Notice
To ensure that you are always aware of how we use your personal information we will update this Privacy
Notice from time to time to reflect any changes to our use of your personal information. We may also make
changes as required to comply with changes in applicable law or regulatory requirements. We will notify you
by email, if we have your email address, of any significant changes.

Last updated July 2022