Our Privacy Policy

5. MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Should you wish to change your preferences at any time, please contact us.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or used our services or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Homewise Group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages by speaking with us or contacting us on marketing@homewise.co.uk at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service experience or other transaction.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see www.homewise.co.uk/cookies.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Compliance Team.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.

• Internal third parties: other companies in the Homewise Group acting as joint controllers or processors and who are based in the UK where a service is being provided to you.
• External third parties:
  • Service providers acting as processors based in the UK who provide IT and system administration services and analysis of our database
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances
  • Our estate agent partners or other partners who we work with based in the UK whose services may be of interest to you and where you have requested that we pass your details to them on your behalf
  • Third party lenders, partners or other third parties otherwise involved in a transaction (such as funders, purchasers or investors) where a Homewise Group company is providing you services
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers who are processing your personal data as a data processor to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Where we share your personal data with a third party on a data controller to data controller basis, each party will be responsible for their use of your data.

7. INTERNATIONAL TRANSFERS

An investor and/or lender may purchase (or provide finance for) the long-term interest on the property on which you are being granted a Home for Life Plan, i.e. the interest in the property that survives the termination of the Home for Life lease.

If you have been granted a Home for Life lease we may need to give the investor your personal information. Such disclosures will be subject to a duty of confidentiality, as referred in ‘Data Security’ below. If the investor is based outside of the EU then we will send your personal information to the country that the investor is based in. The investor is required to meet all data protection legislation requirements in order to ensure the security of your data. We can make this transfer because:

• the transfer is necessary for the performance of a contract between you and us (or the implementation of pre-contractual measures taken at your request); or
• the transfer is necessary for the conclusion or performance of a contract concluded in your interest between us and the investor

Please contact our Compliance Team if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have policies in place to deal with any suspected personal data breach and will notify you where appropriate, and any applicable regulator where we are legally required to do so, of any breaches which occur.

9. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our Data Retention Policy which you can request from us by contacting our Compliance Team.

10. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact our Compliance Team (compliance@homewise.co.uk)

You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). The ICO can be contacted on 0303 123 113, or via their website, www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

This page was last edited on: 10/01/2022

APPLICANT PRIVACY NOTICE

Data controller:                           Homewise Ltd.

                                                         1 Liverpool Gardens

                                                         Worthing

                                                         West Sussex

                                                         BN11 1TF

As part of any recruitment process, Homewise (we, us, our) collects and processes personal data relating to job applicants. Homewise is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

What information does Homewise collect?

Homewise collects a range of information about you. This includes:

• The information you have provided to us in your curriculum vitae and covering letter
• The information you have provided on [our application form], including name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications
• Any information you provide to us during an interview

We may also collect, store and use the following types of more sensitive personal information:

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
• Information about your health, including any medical condition, health and sickness records
• Any criminal convictions (this does not include spent convictions under the Rehabilitation of Offenders Act 1974)

How is your personal information collected?

Homewise may collect this information in a variety of ways. For example:

• You, the candidate
• Recruitment agencies, from which we collect the following categories of data: information about you including your name, title, address, telephone number, personal email address, date of birth, gender, employment history and qualifications
•  Credit reference agencies, from which we collect the following categories of data: information about your creditworthiness and financial background
• Your named referees, from whom we collect the following categories of data: the dates of your employment and your job title

Homewise will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.

Why does Homewise process personal data?

Homewise will use the personal information we collect about you to:

• Assess your skills, qualifications, and suitability for the role
• Carry out reference checks, where applicable
• Communicate with you about the recruitment process
• Keep records related to our hiring processes
• Comply with legal or regulatory requirements

It is in our legitimate interests to decide whether to appoint you to role since it would be beneficial to our business to appoint someone to that role.

We also need to process your personal information to decide whether to enter into a contract of employment with you.

Having received your CV and covering letter and/or your application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references before confirming your appointment.

If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.

How Homewise uses particularly sensitive personal information

We will use your particularly sensitive personal information in the following ways:

• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting

Homewise may also need to process particularly sensitive data from job applicants to respond to and defend against legal claims.

Homewise will use your data for the purposes we have explained in this policy; we will not use it in any way that is incompatible with these purposes.

Who has access to data?

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area for which you may be considered and IT staff if access to the data is necessary for the performance of their roles.

For some technical areas of the business, Homewise may ask its partners, for example its IT supplier, to assist with the recruitment process. This may include conducting a telephone interview, providing additional testing, or providing a presence at a face to face interview for example.  In these circumstances Homewise will share your personal information with the relevant partner with whom we share a data sharing agreement.

Homewise will not share your data with any other third parties, unless your application for employment is successful and it makes you an offer of employment. Homewise will then share your data with former employers to obtain references for you.

Homewise will not transfer your data outside the European Economic Area.

How does Homewise protect data?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our Customer Care & Compliance Manager.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

For how long does Homewise keep data?

If your application for employment is unsuccessful, Homewise will hold your data on file for 12 months after the end of the relevant recruitment process. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds, that we have conducted the recruitment exercise in a fair and transparent way, and in order to allow us to identify that you have applied to work with us previously in the event of any subsequent application. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice which applies to your employment.

Your rights

As a data subject, you have a number of rights. You can:

• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below)
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it
• Request the transfer of your personal information to another party

If you would like to exercise any of these rights, please contact our Compliance Team at the above address, or by emailing compliance@homewise.co.uk.

Right to withdraw consent

When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact our HR team. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.