Introduction
Welcome to our privacy policy.
Please note that this privacy policy relates to the activities of Shared Ownership Code Limited (company number: 16769801), (referred to as “Shared Ownership Code“, which is a wholly owned subsidiary of New Homes Quality Board Limited. “We“, “us” or “our” in this privacy policy) who is the controller and responsible for your personal data.
Shared Ownership Code respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit www.sharedownershipcode.org.uk (our Website) (regardless of where you visit from) and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Shared Ownership Code collects and processes your personal data through your use of this Website, including any data you may provide through this Website when you and/or your employer:
- registers with us for use of the Website;
- contacts us for further information;
- orders publications or reference materials;
- enters surveys sent by us;
- participates in mailing list initiatives; and/or
- registers for events and conferences,
Who is Shared Ownership Code and how to get in touch
- Full name of legal entity: Shared Ownership Code Limited, a private limited company by guarantee (company number: 16769801)
- Email address: info@sharedownershipcode.org.uk
- Postal address: Shared Ownership Code Limited, 86-90 Paul Street, London, EC2A 4NE
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us, and our customer service teams, in the first instance.
Changes to the privacy policy and your duty to inform us of changes
Third-party links
2. The data we collect about you
- Contact Data includes full name, title, job title, office address, business email addresses and business telephone numbers;
- Profile Data includes user’s screen name;
- Usage Data includes information about how you use our Website and services;
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website; and
- Marketing and Communications Data includes your preferences in participating in mailing list initiatives, ordering publications and reference materials as well as entering surveys.
We may also collect your personal data indirectly via our relationship with your employer, housing provider or third parties who may register for events and conferences on your behalf.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions– You or your employer may give us your Contact Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you interact with us for any one or more of the Purposes;
- Automated technologies or interactions– As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details; and
- Third parties or publicly available sources– We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers; and
- search information providers.
- Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- where we need to perform the contract we are about to enter into or have entered into with you;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
- where we need to comply with a legal obligation.
If you choose to send us an email via the Website, we simply collect your email address and the nature of your enquiry. This allows us to respond to your query quickly and efficiently.
Please go to the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of Data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To respond to any queries raised or contact made with us through the website and/or the portal as applicable. | (a) Contact (b) Technical | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to respond to your queries) |
| To keep internal records. | (a) Contact (b) Usage (c) Technical | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep records) |
| To notify relevant External Third Parties who may need to know of changes to a developers registration status if they have previously been provided with your personal details. | (a) Contact | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep records) |
| To report on page views and general content consumption of our Website. | (a) Usage (b) Technical | (a) Necessary for our legitimate interests (to monitor use of our Website) |
| To facilitate registration of events, courses, and conferences | (a) Contact (b) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to ensure we provide events and conferences to a high standard and for the benefit of you) |
| To administer and allow entry into our surveys | (a) Contact (b) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to ensure we are providing you with the best possible service) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy; and (b) Providing marketing materials (such as mailing list initiatives, publications, or reference materials) to you subject to you having opting-in to such marketing materials. | (a) Contact (b) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to keep our records updated and to allow members use our products/services) |
| To facilitate access to certain aspects of our Website through registration | (a) Contact (b) Profile (c) Technical | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to allow you access to different areas of our Website) |
| To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data). | (a) Contact (b) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and to prevent fraud) (b) Necessary to comply with a legal obligation |
| To use data analytics to improve our Website, services, marketing, and experiences. | (a) Technical (b) Usage | Necessary for our legitimate interests (to keep our Website updated and relevant, to develop our business and to inform our marketing strategy) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
- Promotional offers from us: We may use your Contact, Technical and 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 services and offers may be relevant for you (we call this marketing). You will only receive marketing communications from us if you have opted-in to receive direct marketing. You may withdraw your consent to receive direct marketing or object to direct marketing at any time by contacting us using the contact details provided in this privacy policy or by following the unsubscribe link in any marketing communication.
- Third-party marketing: We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
- Opting out: You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us 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 purchase, service experience or other transactions.
- Cookies: You can set your browser to refuse all or some browser cookies, or to alert you to 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 our cookies policy.
- 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 us. 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. Where our processing activities are likely to result in high risk to your rights and freedoms, we will conduct Data Protection Impact Assessments (DPIAs) to identify and mitigate such risks. We will consult with the ICO where required by law.
5. Disclosures of your personal data
- External Third Parties as set out in the Glossary;
- Specific third parties such as:
- Google Analytics – web analytic services in relation to our Website; and
- 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 policy.
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 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.
We will not sell your personal data on to third parties.
6. International transfers
Shared Ownership Code is based in the United Kingdom (UK) and your personal data is predominantly held on servers within the UK and we do not usually transfer or store your personal data outside the UK.
In the event that we, or some of our External Third Parties, transfer or store personal data on servers outside of the UK we take additional steps to ensure that your information is protected to at least an equivalent level, as required by applicable data protection laws.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; and
- where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
8. How long will you use my personal data for?
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
- Request access to your personal data;
- Request correction of your personal data;
- Request erasure of your personal data;
- Object to processing of your personal data;
- Request restriction of processing your personal data;
- Request transfer of your personal data; and
- Right to withdraw consent.
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 could 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 could 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.
10. Glossary
Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Third Parties
External Third Parties
- Course, event and/or conference organisers or owners who operate events that you or your employer may register for;
- Your employer where you register or are registered for a course, event or conference;
- Warranty providers, lenders and the Ombudsman;
- Service providers who provide IT and system administration services;
- Professional advisers acting as processors including lawyers, agents, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services;
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances;
- Website designers and marketing agents acting as processors based in the United Kingdom who provide their services which may require access to personal data; and
- Analytics and search engine providers that assist us in the improvement and optimisation of our Website.
Your Legal Rights
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;
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- 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; and/or
- 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; and