Privacy Notice: how we use your personal information

This notice applies if you are a customer of SNG, if you use our services, visit our website, contact us email, call, send us a message on social media, text, in person, or write to us.

A ‘customer’ is any individual whose personal data SNG processes in connection with the provision of housing or related services. This includes:

• Residents: anyone living in a property owned or managed by SNG, whether or not named on the tenancy or lease, including household members.
• Tenants: individuals renting their home from SNG under any tenancy agreement, including assured, assured shorthold, secure and starter tenancies.
• Leaseholders: individuals holding a long lease, including shared ownership and full leaseholders.
• Applicants for housing, whether or not subsequently housed.
• Former customers whose personal data SNG continues to hold.
• Authorised representatives acting on a customer's behalf with appropriate authority (for example, a power of attorney, advocate, appointee, or written authorisation).

The type of information we collect depends on how you interact with us and our needs. For example, if you contact us or visit us, we may only need limited information about you to respond to your query. If you are one of our customers, we may collect more information to provide housing services, manage your tenancy, comply with legal requirements or offer support services.

The information we may need from you includes

• Contact details
• Financial information (including the receipt of benefits)
• Mental or physical health information (including disabilities, where this is relevant)

We may also collect certain information to meet our statutory obligations.

We only use your personal information for the purposes it was collected, and we keep it only for as long as is necessary:

• Manage your tenancy, lease, or shared ownership agreement
• Meet our legal and regulatory obligations
• Process payments related to your home

We may need to share some information with third parties, such as local authorities, benefits departments, our repairs and maintenance contractors, social services, other social landlords and government departments as required, and the emergency services.

We may also use AI and data analysis tools to help us understand patterns, improve our services, and identify where additional support may be needed. We do this carefully and responsibly, always respecting your data protection rights.

We will only use your information for those purposes with your knowledge and in line with your rights. The rights you have in relation to your personal data, include the right to see copies of the personal data we hold about you, or to make a complaint to the regulator, the Information Commissioner's Office (ICO).

This is only a simple overview of how we use your personal data. The rest of this notice is split into sections to make it easier to read and understand. In each of the sections you can see more detailed information about what personal data we have and what we do with it.

If you have any queries about this notice, please email the Data Privacy team: dpo@SNG.org.uk.

Sovereign Network Group
Sovereign House
Basing View
Basingstoke
RG21 4FA

In this notice, the words “we”, “us”, “our” or “SNG” refer to Sovereign Network Group. Our ICO registration number is ZA221241.

We are a Registered Social Landlord (RSL) regulated by the Regulator of Social Housing.

As a social housing provider, our core activities include:

1. Providing social and other types of housing.
2. Property and grounds maintenance and repair.
3. Managing your housing, tenancy/lease and account as your landlord.

We also offer additional optional services, including:

1. Offering opportunities for tenant and customer involvement (co-regulation).
2. Providing welfare, benefits and debt advice (WBDA).
3. Offering residents employment and skills training and development.
4. Organising and supporting community events.
5. Making adaptations to the properties we manage.
6. Offering residents the opportunity for electric vehicle charging
7. Selling properties
8. Homelessness prevention programme

We collect and retain personal data about:

Customers: This includes current, former, and prospective customers who live in our properties or access our support and other services. It also includes members of their household, family members, and people associated with them.

Visitors: This includes visitors to our websites and offices, as well as individuals who contact us by email, phone, social media, text or in writing, including anyone who makes a complaint or enquiry to Sovereign Network Group (SNG).

We collect personal information in a variety of ways. You may provide personal data by:

• Completing forms, for example at tenancy sign-up or becoming a leaseholder
• By registering to use our online customer portals
• When you contact us by phone, email, live chat, video call, chatbot, virtual agent or in person
• Subscribing to research, or
• Taking part in promotions or surveys.

We gather information through ongoing contact with you, from other support agencies involved in your care or support, and from people associated with you such as family members, friends, or neighbours.

Calls to our offices and customer service management centres ** may be monitored or recorded. Some schemes and offices use Closed Circuit Television (CCTV) to record activity in public areas.

If you provide us with personal information about your family members or associates, you should make sure that you have their permission to do this.

Please tell us about any changes to your personal information so we can keep our records up to date and also contact you easily.

**We may monitor, record, store, and use communications such as phone calls, CCTV footage, emails, and portal messages for training, quality assurance, and service improvement. We retain this information in line with our Data Retention Schedule.

When you apply to become a Sovereign Network Group customer, we collect information to assess your housing needs.

You provide us with this information through your application form, and we may also use information from third parties, such as other housing providers or private landlords, your mortgage lender (if you own or have owned your own home), the police, probation service, support workers, social workers, mental health professionals, and credit reference agencies where appropriate.

We typically collect the following information from tenants and leaseholders:

• Full name and proof of identity (photo ID)
• Date of birth
• National Insurance number
• Contact details (telephone, email, or correspondence address)
• Details of anyone authorised to act on your behalf
• Personal details of all household members
• Banking or payment card details if you make payments to us
• Benefit and Council Tax information
• Proof of housing eligibility

Other personal information may be collected to help resolve tenancy breaches, alleged anti-social behaviour, or suspected fraud.

We may also collect further information, including:

• Disabilities or vulnerabilities: we use this information to tailor our services to meet your needs, and we may use this information for safeguarding of staff.
• Health information: where required, we use this to support funding for property adaptations made to the home you are living in or moving to. If you use this service, we will give you more specific details.
• Financial information: if it is necessary we may use this information to work out a repayment plan with you with you to make sure arrears payments are settled quickly. This information may also be used to provide welfare, benefits, and debt advice as a free service to help you budget and pay your bills or to apply for funding on your behalf.
• Identification documents: such as photo ID, bank statements, payslips, or income details may be used during the processing of property sales or purchases.

We also record information whenever you contact us or use our services, and we will record any action taken. This includes logging repairs actions taken, and feedback from contractors about appointments with you. This means we can keep an accurate record of our contact with you.

We keep a record of your contact with us, noting any action taken, whether it occurs by phone, email, text message, chatbot, virtual agent, live chat, in writing, or in person. This may include:

• CCTV images
• Call recordings from our customer management centre
• Chat records from our chatbot, virtual agent, or live agent chat
• Notes on actions taken as a result of your contact

For example, this could include collecting a unique boiler ID to raise and carry out emergency repairs.

When you visit our website, we automatically collect certain information to make sure the site works properly. Technical Information will include:

• Your IP address
• Your login information
• Device type and operating system
• Browser type and version
• Browser plug-in types and versions
• If you use a mobile device, a unique phone identifier for your phone

Information about your visit:

• Pages you visit and how you navigate through the site
• Products you view or search for and terms you use to search
• How long you spend on each page
• Errors or problems you encounter
• How you interact with the page (clicks, scrolling, mouse movements)
• Any phone numbers you use to contact us

Some parts of our websites, like customer portals, are only available once you register.

For further information, please see our website terms and conditions and cookies notice.

Some of our offices and locations have CCTV, so you might be recorded when you visit. We use CCTV to keep our visitors, staff, and communities safe.

We use CCTV, surveillance systems within our localities, some of our locality officers will also use body worn cameras in certain situations. Footage is only accessed, when necessary (for example, to prevent or investigate crime), and all footage is stored for a limited time. We follow the ICO’s CCTV Code of Practice and in all places where we operate CCTV surveillance systems, we have put up signs to let you know when CCTV is in use.

We may take photos or carry out filming at our events, in our properties, or in our communities for marketing and publicity. You will always be informed when we do this, and you can opt out; we will not use your image if you ask us not to.

We use advanced analytics, artificial intelligence (AI), machine learning, and profiling (also known as automated decision making). We use these technologies to help us improve our services and better meet the needs of our customers.

SNG may undertake advanced analytics and data science using AI and data analysis to process personal data to understand patterns, improve services, and provide additional support where needed. We do this carefully, always respecting your data protection rights.

For example, our Customer Segmentation Model helps us identify groups of customers who might benefit from extra support or services. The model uses existing information through machine learning to spot where extra help could be useful. If this applies to you, we may contact you to discuss the support available and point you to the appropriate services.

Using this model does not change the services you currently receive from us but aims to make them easier to access and improve outcomes for our customers. We do not make any solely automated decisions that can affect individuals. All decisions involve appropriate human review.

We use personal data in this way to meet our legal and regulatory obligations, including those under the Social Housing (Regulation) Act 2023 and the Consumer Standards Code of Practice, to make sure our services meet the diverse needs of our customers.

We collect and use your personal information to help us provide services, carry out tasks you request, manage your tenancy, lease, or shared ownership agreement, meet legal obligations and to respond to your enquiries.

How we use your information depends on our relationship with you and how you interact with our services, websites, or customer portals.

To process your personal data, we rely on a variety lawful bases under the UK GDPR and the Data Protection Act 2018, as set out in this notice.

Enter into, or manage any contract with you including:

• Process applications and requests for:
  • Rental accommodation (including private market rent)
  • Home ownership
  • Keyworker accommodation
  • Garage rental
  • Careline services
  • Electric vehicle charging and parking
• Manage tenancies, including collecting rent and service charges
• Ensure compliance with the terms of agreements between us
• Provide repairs, maintenance and adaptations to our properties
• Provide home ownership products
• Provide care and support services for elderly and vulnerable customers

Support you and manage both yours and our legitimate interests including the proper management of your tenancy and giving you the appropriate support.

This could include:

• Offering help with debt management and benefits advice
• Assisting you with managing your account, payments and arrears, including via online portals
• Providing support services to help customers achieve their goals
• Keeping in touch to understand your needs, preferences and to invite you to events
• Providing information about Home Contents Insurance schemes
• Engaging with customers to improve our products and services
• Delivering support services through your preferred communication channels, including chatbots and live agents
• Working with our partners including charities and local organisations to provide independent advice and advocacy services to you
• Processing your data in connection with any mergers, acquisitions or business reorganisation of our business, where we may share limited personal data with prospective target organisations but only where this is strictly necessary.

Comply with our legal and regulatory obligations and act in the public interest

This includes:

• Preventing and detecting crime and resolving disputes
• Preventing and detecting fraud and money laundering
• Promoting safety and the quiet enjoyment of our neighbourhoods and communities
• Promoting equality, fairness and equal opportunities for all our customers
• Meeting obligations to our funders and regulators

Use of ‘special category data’

Some personal information is classed as ‘special category data’ under data protection law. This includes information about:

• Racial or ethnic origin
• Physical or mental health
• Sex life or sexual orientation
• Religious or philosophical beliefs
• Political opinions
• Trade union membership
• Criminal offence allegations, convictions and offences
• Biometric data, such as fingerprints

We minimise our holding and use of special category data. However, due to the nature of our services, we may need to process this information to better understand and support the needs of our customers — for example:

• Providing accommodation or support for disabled people
• Supporting individuals with problems around substance misuse
• Resolving neighbourhood disputes involving alleged criminal activity
• Helping customers access care or support services

We process special category data only where there is a lawful reason, such as to meet our legal obligations, act in the substantial public interest in relation to the services we provide, provide social care, or manage legal claims. In some cases, we may ask for your explicit consent, and we will always make this clear when we do so.

We do not routinely process personal data relating to children under the age of 18, as all our tenants are adults. Where children live in one of our properties, we record limited information about them, such as their name and date of birth.

This information is required to:

• Check that a property is not overcrowded; and
• Support other tenancy management activities where it is necessary to understand the ages and composition of the household.

We may also receive information about children where we are involved in the housing or tenancy aspects of a welfare case, as part of a multi-agency working solution.

We keep your personal information safe and confidential. Only our staff and volunteers who need your information to do their job can access it on a need-to-know basis.

We may share your information with trusted third parties when it is necessary, including:

• Contractors and sub-contractors who carry out maintenance and building management;
• IT infrastructure and cloud service providers;
• Utility companies
• Agencies and authorities we work with, such as local councils, social services, the police, and other social landlords
• With fire and safety agencies where there is a need to implement personal fire risk assessments

We may also share certain information in appropriate circumstances, such as:

• With our regulators, funders, purchasers or potential purchasers of the business;
• When we believe it is in your or the public’s interest to do so, such as to keep people safe or where the law requires it.

In particular:

• We may share your current or forwarding address with utility companies and Council Tax offices, to ensure billing details are correct.
• If you break the terms of your tenancy, lease or licence, we may share information with authorised debt recovery agencies to help recover the debt. This may affect future applications for housing, credit, or insurance.
• We may discuss your financial situation, rent payments, arrears, and any claims made for welfare benefits with:
  • external debt advice agencies,
  • welfare right advisors,
  • housing benefit department, or
  • local housing authorities housing advice and homelessness prevention teams to make sure benefits are paid correctly.
• We may share information about your rent payment history with credit reference agencies. This will help them assist other organisations assess your financial standing if you apply for products or services.
• We may share your contact details to third parties that carry out surveys or research on our behalf, this allows us to gather feedback and to improve the services we offer you. The third party are bound by strict terms and conditions outlined by us and must keep your information secure and cannot share it with others. If you choose not to take part, the third party will securely delete your information.
• We may share your National Insurance number to verify:
  • Universal Credit claims and manage these payments
  • prevent or investigate tenancy or right-to-buy applications fraud.
• If you use our chatbot, virtual agent, or live chat services, your information may be shared with our web services provider to store and manage the interaction.
• When solicitors or third parties act on our behalf, we control what information they see, how long they see it for and what they are allowed to do with it. We do not sell your personal information or allow other organisations to use it for their own purposes.

Core stands for Continuous Recording of Social Housing Lettings and Sales (England).

As a social housing provider, we are required by the Ministry of Housing and Local Government (MHCLG) to submit information relating to social lettings, as part of the national monitoring requirements for the allocation of social housing. This is a national information source that provides characteristics on both new private registered and local authority social housing tenants and the homes that they rent.

The data is provided to central government in a highly pseudonymised form, which means that the individual cannot instantly be directly identified. The data is submitted through a website and only accessible by individual logins and passwords.

CORE is a national database that collects information about the letting or sale, including:

• The type of tenancy or sale
• Rents and charges
• Demographic information about the tenant

The CORE dataset does not include names or direct personal identifiers, but when taken as a whole the data allows social tenants to be identified. This is because the dataset may contain unique property reference numbers or even full postcode data

Some of the information collected may also be sensitive, for example whether a social housing tenant has previously spent time in prison, been on probation, or was referred by a mental health service.

Why is the data shared with CORE?

The data is protected by standards aligned with Government Security Standards. The legal reason for sharing this data for carrying out a task in the public interest for research and analytical purposes.

For more information, or if you have any questions about CORE, please contact dataprotection@communities.gsi.gov.uk

We take part in the National Fraud Initiative (NFI), which is a data-matching exercise run by the Cabinet Office. This helps us prevent and detect fraud affecting SNG and other public sector organisations.

Our involvement in the NFI is voluntary. When we take part, we share specific sets of information with the Minister for the Cabinet Office so they can be matched, as explained on the Government's National Fraud Initiative webpage.

We are also members of the National Anti-Fraud Network (NAFN) and therefore share information as required.

The Cabinet Office uses this information under legal powers set out under Part 6 of the Local Audit and Accountability Act 2014. Individual consent is not required for data to be used in these data-matching exercises.

 Data matching by the Cabinet Office is subject to a Code of Practice .

Further information on the NFI is detailed in the Cabinet Office’s fair processing notice .

Protecting your information is important to us therefore Information system and data security is imperative to us to ensure that we are keeping your data safe.

We operate a robust and thorough process for assessing, managing and protecting new and existing systems which ensures that they are up to date and secure against the ever-changing threat landscape. In addition to this, we follow an in-depth security model, which means that your data is protected by multiple layers of security.

Personal information is stored and managed within a variety of IT software systems which are maintained to achieve a high level of security and confidentiality. We hold information in IT systems which may be copied for testing, backup, archiving and disaster recovery purposes.

Our employees complete mandatory information security and data protection training at the start of their employment, and annually thereafter to reinforce responsibilities and requirements set out in our information security policies. Only those staff members and third parties who require access to your information will be able to access it.

When you trust us with your data, we will always keep your information secure to maintain your confidentiality. We use strong encryption to protect your information both when it’s stored and in transit. This means the risk of unauthorised disclosure or access is reduced. When visiting our websites, you can check your connection is secure by looking for the padlock in your browser’s address bar.

SNG is based in the United Kingdom (UK) and most of the data we collect is stored within the UK and the European Union (EU). Some organisations which provide services to us may transfer data outside the European Economic Area but we’ll only allow this if your data is adequately protected.

We will store your personal information for as long as it’s needed for the purposes for which it was collected. How long information will be stored for depends on what it is being used for. In some cases, we must keep it to meet statutory, regulatory or contractual purposes, or to deal with legal claims.

We will usually keep:

• Applications for accommodation for 6 years after you accept an offer for accommodation
• Housing benefit notifications and rent statements for 2 years
• Tenancy files for 6 years after your tenancy ends, including all interactions with us regarding your tenancy
• Care plans for children and adults in line with our legal obligations
• Chatbot and virtual agent interactions for 2 years
• Recordings of telephone calls for 6 months

You have various rights in your personal data including the right in certain circumstances:

• to ask us for access to information about you that we hold;
• to have your personal data rectified, if it is inaccurate or incomplete;
• to request the deletion or removal of personal data unless there is a compelling reason for its continued processing, for example if we are required to retain it for statutory purposes, or to protect our legal interests;
• to restrict our use of your personal data (i.e. permitting its storage but nothing further), although in some cases we will not be able to restrict our uses of your information, for example if we are required to process it for statutory purposes or to protect our interests;
• to object to certain ways we use your information;
• not to be subject to decisions made automatically through the use of technology and with no human consideration where it produces a legal or similarly significant effect on you; and
• to request that we transfer your information directly to a new landlord or other third party.

Further information about your data protection rights appears on the Information Commissioner’s website .

If you would like further information or to exercise any of these rights, please email our Data Privacy team at DPO@sng.org.uk.  

We may sometimes process your data for specific purposes which need your consent. If we do this, we will always ask for your written consent. Where we are processing your personal data based on your consent, you have the right to withdraw that consent at any time. This may affect the services that we can make available to you, but this will be explained in the consent form. Please contact us if this is the case.

If you have any questions about this notice or how we use your personal data, please contact our Data Privacy team at  DPO@sng.org.uk. Please talk to us directly so that we can help to resolve the issue.

If you have a concern about the way we have collected, used, stored or shared your personal data, you have the right to make a complaint directly to us. This right is in addition to your right to complain to the Information Commissioner’s Office (‘ICO’), the UK’s independent data protection regulator.

We will acknowledge your complaint within 30 calendar days of receiving it and will investigate it without unnecessary delay. We will keep you informed of the progress of your complaint and will provide you with a written outcome, including the steps we have taken, our findings, and the reasons for our decision. We aim to provide a full response within three months of receiving your complaint, although more complex matters may take longer.

You can make a complaint in any of the following ways, and you do not need to use formal or legal language:

• By email: dpo@sng.org.uk
• By post: Sovereign Network Group
  Sovereign House
  Basing View
  Basingstoke
  RG21 4FA

If you are not satisfied with the outcome of your complaint, or if we do not respond within a reasonable time, you have the right to escalate your complaint to the ICO. The ICO will generally expect you to have raised the matter with us first before it will investigate.

The ICO can be contacted via the website or by calling 0303 123 1113.

This Privacy Notice was updated in August 2026 and will be updated annually and/or to reflect changes, either to the way in which we operate, or changes to data protection legislation. We will bring any significant changes to your attention but, to make sure that you keep up to date, we suggest that you revisit this notice from time to time.