Privacy notices, cookie notice, company information and other legal information

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‘Customer’ means anyone who receives a service (such as renting a home or other property) from Curo.

Curo Group and its associated companies (‘Curo’) is a housing association and house-builder based in Bath providing homes and high quality care and support services across the West of England. Curo is committed to respecting your right to privacy and to processing your personal information in a lawful, fair and transparent way. As a Data Controller, all personal data we hold about you will be processed in line with the UK General Data Protection Regulations (‘GDPR’) and the Data Protection Act 2018.

The following summarises:

• How we use personal data
• What personal data we need
• Why we need it
• How we use it
• Who we might share it with, and
• How long we will keep it for

It also sets out the rights you have regarding any of the personal data held by Curo.   From time to time we may update this Notice. Any updates will be posted on our website.

What is personal data?

Personal data is any information relating directly or indirectly to a living individual. This information includes things such as a name, an identification number, location data, online identifier or factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

What personal data do we process?

We only collect personal data for specific, clear and legitimate purposes and we will not process it for purposes that differ from those we have notified you about.   We will limit our use of your personal data to what is needed, relevant to, and necessary for the purposes we have identified. Access to your personal data is given only to those who need to process it for the purposes identified. We will ensure that we keep your personal data accurate and up to date, and will not store it for longer than is necessary.

The types of personal data we collect includes (but are not limited to):

Name, address, phone number(s), email address(es), other identifiers (for example social media user names), financial, medical/health, behavioural, criminal offence/conviction, religious beliefs, trades union membership or political opinions, images, CCTV, audio recordings, location data, disability information, profiling information and other information such as next of kin and copies of ID documentation.

We collect this information in a number of ways, including (but not limited to) information we collect directly from you, for example when you:

• interact with our website and social media platforms 
• become a customer
• access your account online
• call our customer contact department
• make an enquiry
• book a repair
• participate in surveys
• attend meetings with us
• purchase services or products from us
• raise a complaint or request
• participate in our events
• attend our business premises covered by CCTV

We also collect information from third party sources, for example, credit referencing agencies, landlord and other references, data analysis companies and local authorities.

Why do we process personal data?

Our processing of your personal data is necessary for us to provide services to you, maintain our relationship with you and to fulfil our legal obligations. We use personal data for the following reasons:

• Finding you a suitable home
• Managing your property and delivering home improvements
• Managing tenancies and compliance
• Providing community services
• Health, safety and wellbeing
• Managing enquiries
• Managing your accounts
• Selling properties or shares in properties
• Supporting you in your home
• Managing our suppliers and contractors
• Improving customer experience
• The management and governance of our businesses
• Fulfilling our legal obligations
• Supporting you to build a credit history

How do we process your personal data?

The GDPR gives companies a number of lawful reasons to collect and process personal data. Below are the lawful reasons we rely upon and the types of processing activities that relate to each:

Performance of a Contract: In some circumstances it is necessary to process your personal data in order to fulfil our contractual obligations with you. Without this information we would not be able to provide a service to you. For example:

• Setting up and administering leasehold, shared owner and freehold accounts
• Pursuing overdue payments
• Managing and delivering repairs
• Issuing notices
• Administering grants
• Managing tenancies and Estates queries
• Property sales
• Delivering services to support independent living
• Administering customer accounts
• Making payments to customers and suppliers
• Tenancy compliance and management
• Administering resident involvement groups
• Creating and administering tenancy agreements and lettings
• Trade enquiries and requests and managing subcontractors/suppliers
• Administering abandoned goods

Legal Obligation:

In some circumstances it is necessary to process your personal data so we can comply with our legal obligations. Without this information we would not be able to fulfil our legal obligations to you, the authorities, or regulatory and statutory bodies. For example:

• Service of notices in connection with residential and commercial property management
• Supplier/subcontractor compliance
• Preparation of legal matters
• Administering public liability claims
• Sharing benefit payment information with the relevant authority
• Risk and assurance, including fraud monitoring and investigation
• Tenancy/lettings management and administration, for example processing ID for Right to Rent and Direct Lets, and processing documentation for signature
• Home Safety compliance and complaint resolution
• Providing support to and protection of customers, for example administering safeguarding procedures
• Sharing information with local authorities, such as electoral register

Legitimate Interest:

There are situations where processing your personal data is necessary to pursue our legitimate interests as a business. We have to balance our interests as a business with yours as an individual, so that our legitimate interests do not override your interests, rights or freedoms.

For example:

• Planning and delivering home improvements
• Delivering health and safety standards
• Conducting surveys and reports including customer feedback surveys and quality assurance
• Managing our properties and tenancies
• Administering customer accounts and properties
• Providing customer support, for example texting customers about rent statements and referring to other agencies
• Receiving and recording enquiries from the public, customers and suppliers and administration
• Recording calls for monitoring, training, complaint and auditing purposes
• Housebuilding project work
• Supplier and subcontractor checks and administration
• Carrying out and administering suitability assessments and reports in relation to the Independent Living Service
• Generating records in the course of carrying out our business activities, including notes, meeting minutes and associated documentation, general correspondence
• Organising, planning and administering events, including generic publicity material
• Processing details of properties and tenants on Curo’s ICT systems
• Customer segmentation analysis
• Recording images via CCTV or other photographic means and noise monitoring for security and investigation purposes
• Carrying out audits, quality assurance and maintaining databases
• Investigating, monitoring and reporting issues and reportable events
• Managing complaints and enquiries
• Lettings management, for example administration of credit checks and referencing
• Tendering and procurement processes
• Supporting tenants to build a credit history through the Rental Exchange programme with Experian
• Administering applications for Curo grants
• Sending customers and stakeholders information about Curo services via email, text, social media and letter
• Providing customers with translations and interpretations
• Management of resident involvement groups
• Risk assessment and social value monitoring
• Case management
• Risk flag management
• Business continuity and emergency
• Business continuity and emergency
• Progressing open market sales
• Analysing traffic to our website
• To facilitate colleague training and improvement
• Graduate schemes and scholarships

Consent:

In some situations, we will ask you for your consent to collect and process your personal data, for example:

• When you interact with us via our website and social media, for example Twitter and Livechat
• Through cookies when interacting with our website
• Attending events
• Contact information when purchasing a home from us or making an expression of interest in our properties
• Administering our Working Well and Employability schemes
• Parolee resettlement
• Requests from customers
• Taking photographs for publicity
• Customer support in connection with tenancy compliance
• Recording third party permissions

Vital Interests:

Occasionally, we may need to process your personal data when it is necessary to protect your life, for example, in an emergency situation where you cannot give consent.

Special category data

Sometimes, we will need to process more sensitive personal data, known as ‘Special Category’ data. This type of information includes personal data about your race, ethnic origin, political opinions, religious beliefs, trade union memberships, biometrics, health/medical information and sexual orientation. We use special category data to better understand your needs, provide a better service and to comply with our legal and statutory duties for example under health and safety, social protection and/or equality legislation. When we collect and process (including sharing) this data we will rely on one of the following additional purposes to process it:

• Explicit consent;
• Employment, social security and social protection law;
• Already made public by you;
• Legal claims;
• Substantial public interest purposes including equality of opportunity/treatment or
• Health or Social Care law

Sometimes it will be necessary to process personal information relating to criminal prosecutions, proceedings, sentencing or convictions. In those circumstances we will rely on one of the following additional grounds to process (including sharing) this personal data:

• Consent;
• Employment, social security and social protection law;
• Protecting vital interests;
• Already made public by you;
• Legal claims;
• Judicial acts;
• Preventing or detecting unlawful acts or
• Health or Social Care purposes

Who we share your personal data with

In order to provide you with a service and to fulfil our business objectives and legal obligations, there are many situations where it is necessary to share your personal data with third parties. In such circumstances we will share your data with the following categories of organisations/individuals:

• Regulatory requirements , legal and compliance, such as the Department for Work and Pensions, NHS, legal representatives, auditors
• Suppliers and contractors such as mortgage advisors, trades and sites, Sirona, subcontractors, trades or organisations tendering for work, All Pay, MailChimp
• Referencing and credit checking companies
• Utilities companies
• Other housing associations
• Platforms for electronic signature of documents, such as SignRequest
• CCTV, security and safety device providers
• Local authorities, police, our external partners, social services, contract funders and support agencies, such as HCRG Care Group, to fulfil our contractual or legal obligations
• ICT service providers and software companies, such as Microsoft, Survey Monkey, Eventbrite and hosted and in- house providers including MyCuro and Voicebox, and Google
• Other colleagues, departments and companies within Curo Group

How long will we keep your personal data?

We will only keep your personal data for as long as necessary and for the purpose for which it was collected. When it is no longer necessary to keep your personal data we will delete it. Our policy for deciding how long we keep personal data is based on National Housing Federation best practice guidance and our legal obligations.

Examples:

• When we obtain your bank details to make a refund we will destroy the personal data once the refund has been processed
• Personal data collected from credit checks is kept until the start of a tenancy or acceptance of it
• Tenancy agreements will be retained for six years after the end of the tenancy to comply with our legal obligations and industry guidance.

Sometimes, we may need to retain data for analytical, statistical or research purposes. In these circumstances we will anonymise or pseudonymise your personal data so you will not identifiable.

Profiling

Sometimes we use personal data (including personal data obtained from third-party data gathering organisations) to help us generate customer profiles based on lifestyle and behaviours. We use this information to deliver a more customised customer experience and ensure services are delivered appropriately.

Security and sharing your personal data outside the EEA

We ensure that appropriate security measures are in place when handling your personal data. Occasionally, we may share your data with third party suppliers outside of the European Economic Area (‘EEA’), for example we use Survey Monkey which has servers in the USA. In such circumstances, we ensure that your personal data will receive the same protection as if it were being shared within the EEA by ensuring that our contracts contain a requirement for suppliers to adhere to the same strict data privacy requirements as us.

Your data rights

You have the following rights over your personal data:

The right to request:

• Access to your personal data free of charge, unless the request is unfounded or excessive.
• Correction of your personal data if it is inaccurate or incomplete.
• To have your personal data deleted or removed where there is no good reason for processing to continue.
• Processing of your data to be restricted, subject to certain criteria.
• Your data is moved, copied or transferred to another platform, subject to certain criteria.

If you make such a request, we will respond to it within one month of your request. In some circumstances we may require an extension to this time period and will notify you of the reasons for this. If we refuse your request, we will inform you of the reason(s) and of your right to complain to the Information Commissioner’s Office (see details below) within one month of your request.

You also have the following rights:

• To object to us processing your personal data where we have relied upon legitimate interests to process, subject to certain criteria.
• Not to be subject to a decision made on the basis of automated profiling, if that decision produces legal or a similarly significant effect on you, subject to certain criteria.

The right to withdraw your consent

Where you have given consent for us to process your personal data, you have the right to withdraw your consent at any time. Please contact us at the email or phone number below.

Direct Marketing

You have the right to object to us processing your personal data for direct marketing purposes. If you would like to stop receiving our marketing communications, please contact us at the email or phone number below.

Checking Identity

In order to protect confidentiality we will ask you to verify your identity before responding to any request made under this privacy notice. If a third party makes a request on your behalf, we require proof that you have given your permission for them to act on your behalf.

Contact Details for Further Information

The Curo Group incorporates the following two companies and four charitable registered societies in England and Wales. Each company and society is a Data Controller:

• Curo Enterprise Limited (ICO ZA223885)
• Curo Market Rented Services Limited (ZA236884) Four charitable registered societies:
• Curo Group (Albion) Limited (ICO Z659867X)
• Curo Places Limited (ICO Z6598589)
• Curo Choice Limited (ICO Z6627936)
• Mulberry Park Community Benefit Society (ICO ZA461268)

The registered office for all organisations in the Group is: The Maltings, River Place, Lower Bristol Road, Bath BA2 1EP.

If you have any queries or questions about the data we hold about you, please contact our Data Protection Officer at privacy@curo-group.co.uk or phone 01225 366000.

Contacting the Information Commissioner’s Office

If you are unhappy with the way we have handled your personal data or our response to a request you have made to us, you have the right to complain to the Information Commissioner’s Office:

Information Commissioner's Office details: Wycliffe House

Water Lane Wilmslow Cheshire SK9 5AF

0303 123 1113
casework@ico.org.uk
www.ico.org.uk/concerns

Curo Customer Privacy Notice. Reference number: G001. Version number 008

'Other stakeholders' includes members of the public, suppliers, partner organisations and any other interested parties.

Curo Group and its associated companies (‘Curo’) is a housing association and house-builder based in Bath providing homes and high quality care and support services across the West of England.  Curo is committed to respecting your right to privacy and to processing your personal information in a lawful, fair and transparent way. As a Data Controller, all personal data we hold about you will be processed in line with the General Data Protection Regulations (‘GDPR’) and data protection laws. 

The following summarises:

• How we use personal data
• What personal data we need
• Why we need it
• How we use it
• Who we might share it with, and
• How long we will keep it for

It also sets out the rights you have regarding any of the personal data held by Curo. From time to time we may update this Notice, any updates will be posted on our website. 

What is personal data? 

Personal data is any information relating directly or indirectly to a living individual.  This information includes ‘identifiers’ such as a name, an identification number, location data, email address or social media name, or factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

What personal data do we process?

We only collect personal data for specific, clear and legitimate purposes and we will not process it for purposes that differ from those we have notified you about.   We will limit our use of your personal data to what is needed, relevant to, and necessary for, the purposes we have identified. Access to your personal data is given only to those who need to process it for the purposes identified. We will ensure that we keep your personal data accurate and up to date, and will not store it for longer than is necessary. 

The types of personal data we collect includes (but is not limited to):

Name, address, phone number(s), email address(es) (including work email addresses), other identifiers (for example social media user names), financial, medical/ health, behavioural, criminal offence/ conviction, religious beliefs, Trades Union Membership or political opinions, images, CCTV, audio recordings, location data, disability information, profiling information and other information such as next of kin, copies of ID documentation.

We collect this information in a number of ways, including (but not limited to):

Information we collect directly from you, for example when you:

• Interact with our website and social media platforms
• Become a business partner or tender for contracts with us
• Provide information to us, including via phone, email or other correspondence
• Generate documents, records and other information in the course of your relationship with us, for example, when carrying out work on our behalf
• Make an application to us, for example applying to work with us or applying for a Curo grant
• Participate in surveys or provide feedback to us
• Attend meetings with us
• Provide services or products to us or deliver services on our behalf
• Raise a complaint or request or are involved in an incident on our premises
• Participate in our events
• Attend any of our premises covered by CCTV surveillance
• Are engaged in a sale or purchase of leasehold, shared ownership or freehold property
• You are a guarantor, next of kin, power of attorney or agent acting on behalf of a Curo customer or stakeholder

Please note that "us", "we" and "our" in the list above includes times where we are operating as Homes for the South West.

We also collect information from third party sources, for example, private and organisational references, the Data Barring Service and the Bath and North East Somerset Homesearch Register.

Why do we process personal data?

Our processing of your personal data is necessary for us to provide services to our customers, to maintain relationships with our stakeholders, and to fulfil our business objectives and legal obligations. We use personal data for the following reasons:

• Providing homes and general properties
• Managing properties and delivering home improvements
• Managing tenancies and compliance
• Providing community services
• Health, safety and wellbeing
• Managing enquiries
• Managing our customers’ accounts
• Selling properties
• Supporting out tenants in their homes
• Managing our suppliers and contractors
• Improving customer experience
• The management and governance of our businesses
• Fulfilling our legal obligations

How do we process your personal data?

The GDPR gives companies a number of lawful reasons to collect and process personal data.  Below are the lawful reasons we rely upon and the types of processing activities that relate to each:

Performance of a Contract:

In some circumstances it is necessary to process your personal data in order to fulfil our contractual obligations with you. Without this information we would not be able to fulfil our business and legal obligations to you.  For example:

• Your provision of goods and services to us, or on our behalf, such as making payment to you
• When you make a request for a Direct Let Form
• Using the documents, paperwork and other information given and generated by you during your engagement with us (whether contractual or pre-contractual)
• Tenancy and customer account management, such as contacting family members and householders following the death of a tenant, or when carrying out a success plan
• Completing reservation forms in connection with house purchases
• Administering trade enquiries, including processing information contained in request forms
• Carrying out sub-contractor and supplier company search administration, such as conducting company financial and background checks
• Processing purchase orders
• Carrying out assessments before being housed by Curo
• Providing support to customers in our Enabling Independent Lives schemes, such as providing contact details of a partner organisation support worker to a customer or completing assessments containing third party support worker details
• In the preparation of our company records, such as processing emoluments
• In the preparation of agreements, such as confidentiality agreements
• Processing next of kin details, for example in connection with the creation of tenancies or providing support
• In connection with customer tenancy compliance and management, such as investigating incidents connected with the Housing Management Function

Legal Obligation:

In some circumstances it is necessary to process your personal data so we can comply with our legal obligations.  Without this information we would not be able to fulfil our legal obligations to you, the authorities, or regulatory and statutory bodies. For example:

• Recording, investigating and administering health and safety related matters
• Carrying out and administering subcontractor and supplier checks, such as checking appropriate insurance and carrying out fraud checks
• In connection with legal matters, such as disputes, infringements and public liability claims
• For risk and assurance purposes, such as monitoring, investigating and reporting issues and reportable events
• Carrying out Right to Rent checks
• Tenancy management and compliance, including administering and attending multi agency meetings, administering tenancies following the death of a tenant
• Carrying out our company secretarial duties, including preparing and maintaining company records

Legitimate Interest:

There are situations where processing your personal data is necessary to pursue our legitimate interests as a business. We have to balance our interests as a business with yours as an individual, so that our legitimate interests do not override your interests, rights or freedoms.  For example:

• Administering applications for Curo grants
• Carrying out financial checks on new suppliers and subcontractors
• Maintaining procurement schedules
• Administering next of kin details
• Carrying out surveys, for example to gain opinion on Universal Credit
• Providing support services to our customers, such as processing third party information contained in assessments and other documentation to support Independent Living Service customers
• Managing suppliers and contractors
• Recording images via CCTV or other photographic means and using noise monitoring for security and investigation purposes
• Sharing safeguarding information with the local authority or police
• For targeted media releases
• Maintaining a key contacts list for emergency situations, including details of journalists and partner organisation contacts
• To support tenancy compliance and management, including investigating third party incidents connected with the Housing Management Function and managing risk
• Carrying out risk assessments and impact assessments
• Business strategy, financial management, budgeting and forecasting
• Shaping and influencing regional and national policy
• Gathering information relating to planned housing regeneration and refurbishment projects
• Key management relating to our properties, including monitoring and investigating breaches of our key management policy
• In connection with recruitment and candidate selection
• Sending information about Curo services and activities to stakeholders on a business to business basis
• Administering and organising events
• To carry out general administration of our business, including, recording meetings, producing minutes, agendas, distribution lists, contact directories, and general correspondence
• Maintaining our supplier database and records
• Carrying out third party checks, including Data Barring Service and qualifications checks
• Carrying out and administering tender submissions
• Maintaining our CRM, Finance and Housing Management Systems, for example recording information relating to our properties
• Responding to queries and complaints
• Maintaining records relating to suppliers, developers and subcontractors
• Administering sales, including recording progress, completed and withdrawn applications
• Analysing traffic to our websites, including the Homes for the South West website 
• Taking photographs for publicity or marketing

Consent: 

In some situations, we will ask you for your consent to collect and process your personal data, for example:

• Interacting with us via social media, for example Twitter and Live chat
• Through cookies when interacting with our website
• When attending our events
• Obtaining contact information when purchasing a home from us or making an expression of interest in our properties so we can to send you information about our products and services
• Making a request or notification to us
• Acting as a guarantor, next of kin, power of attorney or other agent
• Administering our Employability and Working Well schemes
• Assessing volunteering viability and linking community support across our Social Prescribing schemes in North East Somerset Community Connect and South Gloucestershire Community Connectors
• Administering general enquiries and requests, such as those received via social media platforms and phone
• Parolee resettlement
• Recording third party permissions 

Vital Interests:

Occasionally, we may need to process your personal data when it is necessary to protect your life, for example, in an emergency situation where you cannot give consent.

Special category data

Sometimes, we will need to process more sensitive personal data, known as ‘Special Category’ data.  This type of information includes personal data about your race, ethnic origin, political opinions, religious beliefs, trade union memberships, biometrics, health/ medical information and sexual orientation.   When we collect and process this data we will rely on the following additional purposes to process it:

• Explicit Consent
• Employment, social security and social protection law
• Already made public by you
• Legal Claims
• Public Interest

Sometimes it will be necessary to process personal information relating to criminal prosecutions, proceedings, sentencing or convictions.  In those circumstances we will rely on one the additional grounds to process this personal data:

• Consent
• Protecting vital interests
• Already made public by you
• Legal claims
• Judicial acts
• Substantial public interest

Who we share your personal data with

In order to provide you with a service and to fulfil our business objectives and obligations, there are many situations where it is necessary to share your personal data with third parties.  In such circumstances we will share your data with the following categories of organisations/individuals:

• Regulatory, legal and compliance, such as the Department for Work and Pensions, NHS, legal representatives and auditors
• Suppliers and contractors, such as trades and sites, subcontractors, All Pay and consultants
• Referencing and credit checking companies
• Other housing associations
• CCTV, security and safety device providers
• Local authorities, police, our external partners, social services, contract funders, support agencies
• IT service providers and software companies, such as Microsoft, Survey Monkey, Eventbrite, Google and hosted in-house providers such as MyCuro and VoiceBox 
• Other colleagues, departments and companies within Curo Group 

How long will we keep your personal data?

We will only keep your personal data for as long as necessary and for the purpose for which it was collected.  When it is no longer necessary to keep your personal data we will delete it.  Our policy for deciding how long we keep personal data is based on National Housing Federation best practice guidance and our legal obligations.

Examples: 

• Contracts will be retained for 6 years after the end of the contract
• Emails from members of the public making general enquiries will be kept for as long as necessary to deal with the enquiry and deleted as soon as possible thereafter

Sometimes, we may need to retain data for analytical, statistical or research purposes.  In these circumstances we will anonymise or pseudonymise your personal data so you will not be identifiable.

Profiling

Sometimes we use personal data obtained from Greenstone, a third party data gathering organisation, to help us generate customer profiles based on lifestyle and behaviours. We use this information to deliver a more customised customer experience. 

Security and sharing your personal data outside the EEA

We ensure that appropriate security measures are in place when handling your personal data.

Occasionally, we may share your data with third party suppliers outside of the European Economic Area (‘EEA’), for example we use Survey Monkey which has servers in the USA.  In such circumstances, we ensure that your personal data will receive the same protection as if it were being shared within the EEU by ensuring that our contracts contain a requirement for suppliers to adhere to the same strict data privacy requirements as us. 

Your data rights

You have the following rights over your personal data:

The right to request:

• Access to your personal data free of charge, unless the request is unfounded or excessive. 
• Correction of your personal data if it is inaccurate or incomplete.
• To have your personal data deleted or removed where there is no good reason for processing to continue. 
• Processing of your data to be restricted, subject to certain criteria.
• Your data is moved, copied or transferred to another platform, subject to certain criteria.

If you make such a request, we will respond to it within one month of your request. In some circumstances we may require an extension to this time period and will notify you of the reasons for this. If we refuse your request, we will inform you of the reason(s) and of your right to complain to the Information Commissioner’s Office (see details below) within one month of your request. 

You also have the following rights:

• To object to us processing your personal data where we have relied upon legitimate interests to process, subject to certain criteria. 
• Not to be subject to a decision made on the basis of automated profiling, if that decision produces legal or a similarly significant effect on you, subject to certain criteria. 

The right to withdraw your consent: 

Where you have given consent for us to process your personal data, you have the right to withdraw your consent at any time.  Please contact us via the contacts below. 

Direct Marketing

You have the right to object to us processing your personal data for direct marketing purposes.  If you would like to stop receiving our marketing communications, please contact us at the email or phone number below. 

Checking Identity

In order to protect confidentiality we will ask you to verify your identity before responding to any request made under this privacy notice.  If a third party makes a request on your behalf, we require proof that you have given your permission for them to act on your behalf. 

Contact details for further information

The Curo Group incorporates the following two companies and four charitable registered societies in England and Wales.  Each company and society is a Data Controller:

• Curo Enterprise Limited (ICO No. ZA223885)
• Curo Market Rented Services Limited (ICO No. ZA236884) 

Four charitable registered societies:

• Curo Group (Albion) Limited (ICO No. Z659867X)
• Curo Places Limited (ICO No. Z6598589)
• Curo Choice Limited (ICO No. Z6627936)
• Mulberry Park Community Benefit Society (ICO No. ZA461268) 

The registered office for all organisations in the Group is: The Maltings, River Place, Lower Bristol Road, Bath BA2 1EP.

If you have any queries or questions about the data we hold about you, please contact our Data Protection Officer at privacy@curo-group.co.uk or phone 01225 366000.

Contacting the Information Commissioner’s Office

If you are unhappy with the way we have handled your personal data or our response to a request you have made to us, you have the right to complain to the Information Commissioner’s Office:

Information Commissioner's Office details:
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF                                    

0303 123 1113

casework@ico.org.uk

www.ico.org.uk/concerns

Curo Stakeholder Privacy Notice. Reference number: G002. Version number 004.

Curo Privacy Notice for Job Applicants

This Privacy Notice explains how Curo (‘Data Controller’) collects and processes personal data relating to you, as a Curo job applicant. It also explains your rights.

The recruitment software we use (via this website) is supplied by Net-Worx Ltd (trading as Networx) (‘Data Processor’). Networx will only process your data in accordance with our instructions. Networx can be contacted at The Engine House, Wharfebank Business Centre, Ilkley Road, Otley LS21 3JP. The Data Protection Officer at Networx can be contacted at dop@networxrecruitment.com

1. The personal data we collect

We collect a range of information about you and this includes:

• your name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience and employment history;
• whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process;
• information about ethnicity, gender, faith etc for the purposes of monitoring and analysing equality in our recruitment process (which you are not obliged to provide) and;
• information about your entitlement to work in the UK.

2. How we collect data

We may collect information from:

• your application form
• your CV
• your passport or other identity documents
• interviews or other forms of assessment, including online tests
• We may also collect personal data about you from third parties, such as references supplied by former employers. We will only seek information from third parties once a job offer to you has been made. We will inform you when we do so.

3. Why we need to process personal data

We collect and process your personal data for a number of purposes but only where we have a lawful basis to do so as follows:

• We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job;
• As a benefit to both parties, there is a legitimate interest in retaining your personal data where your application is unsuccessful but we believe you may be suitable for a role in the future. You may opt-out of this at any time and request that we delete your data.
• We may need to process data from job applicants to respond to and defend legal claims;
• In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, where we are required to check a successful applicant's eligibility to work in the UK before employment starts;
• We may process health information if we need to make reasonable adjustments to the recruitment process for candidates who have a disability.
• For some roles, we must seek information about criminal convictions and offences. This is because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment.

4. Access to your 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 with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

We will not share your data with third parties, unless your application for employment is successful and we make you an offer of employment. We will then share your data with former employers to get references for you, and the Disclosure and Barring Service for criminal records checks if appropriate for the role to which you are applying.

In addition, we may need to share your personal information with a regulator or otherwise to comply with the law.

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

5. How we protect your data

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed. Your personal data is only accessed by Curo employees in the proper performance of their duties.

6. How long we keep your data

If your application for employment is unsuccessful (including when you have speculatively applied to us in respect of a role which is not available), we will hold your data on file for 13 months after the end of the recruitment process.

At the end of this period your data will be deleted or destroyed (unless we need to retain it for longer to exercise or defend any legal claims).

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 employee data is held will be provided to you in a separate privacy notice.

7. Your rights

As a data subject, you can:

• make a request to us and obtain a copy of your data;
• require us to change incorrect or incomplete data;
• require us to delete or stop processing your data
• object to the processing of your data where we are relying on our legitimate interests as the lawful basis for processing; and
• ask us to stop processing data for a period if the data is inaccurate or there is a dispute about whether or not your interests override our legitimate interests for processing the data.

If you wish to exercise any of these rights, have any questions about this notice or our processing of your personal data, please contact Curo’s Data Protection Officer at privacy@curo-group.co.uk.

If you believe that Curo has not complied with your data protection rights, you can make a complaint to the Information Commissioner’s Office (ICO) at any time (www.ico.org.uk). The ICO is the UK regulator for data protection issues.

You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Our website may contain links to other websites of interest. If you click a link to an external website you will leave our site; you should note that we do not have any control over that other website. We cannot, therefore, be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Curo authorises you to copy documents or pages published by Curo on this website for your own non-commercial use only, provided that your copies retain all copyright or other proprietary notices and any disclaimer contained in such documents or pages.

Our website uses Google Analytics to analyse the traffic on our website. For more information on Google's services please see here.

Curo does not represent or endorse the accuracy or reliability of any of the content contained in or distributed through, linked, downloaded or accessed from any of the pages contained in this website. Links on this site may lead to websites and servers maintained by third parties over whom Curo has no control.

All mapping on this website is © Crown copyright 2010. All rights reserved. Ordnance Survey Licence number 0100031184.

Download our retention database here:

The Curo Group incorporates:

Three companies registered in England and Wales:

• Curo Enterprise Limited (Co. No. 08103621) 
• Curo Market Rented Services Limited (Co. No. 4705482)
• Curo Finance Limited (Co. No. 13596265)

Four charitable registered societies under the Co-operative & Community Benefit Societies Act 2014.

• Curo Group (Albion) Limited (FCA No. 7945, Registered Provider registration number No. LH4336)
• Curo Places Limited (FCA No. 7091, Registered Provider registration number No LH4209)
• Curo Choice Limited (FCA No. 24208R) and
• Mulberry Park Community Benefit Society (FCA No. 7696)

The registered office for all organisations in the Group is The Maltings, River Place, Lower Bristol Road, Bath BA2 1EP.

VAT registration numbers

• Curo Group, Curo Places, Curo Market Rented Services and Curo Choice (known as Curo VAT Group) VAT Registration No. 791 1340 40.
• Curo Enterprise VAT Registration No. 165 0574 10.

If you’re a third-party solicitor enquiring about our insurance policy details and Portal ID:

• For Employers Liability our insurer is Zurich Municipal, policy number JHA-22S078-0073 and the portal compensator ID C00108. 
• For Public Liability our insurer is Zurich Municipal, policy number JHA-22S078-0073 and the portal compensator ID C00108. 

These terms shall be governed by and construed in accordance with English law. By using this website you hereby agree to submit to the exclusive jurisdiction of the English courts.