Privacy policy

Who is responsible for your information

Bluebell Housing is the data controller for the information described here. That means we decide what is collected and why, and we are the organisation you can hold to account for it.

Where a council or a charity refers somebody to us, that organisation is a controller of its own records too. We are each responsible for our own.

Registered name, number and office

TBD — Bluebell Housing’s registered company name, company number, the part of the UK it is registered in, and its registered office address. A company must show all of these on its website in any event; a privacy notice that cannot name its controller is not a privacy notice. The directors hold all of it already.

Registration with the data protection regulator

TBD — Bluebell’s data protection fee registration number with the UK data protection regulator. Registration is a legal requirement for most controllers and the register is public, so this is checkable the day it exists. It is the client’s to supply.

Data protection officer

TBD — Whether Bluebell has appointed a data protection officer, and the contact route for them. Given that the core activity involves special category and criminal offence data about people at risk, on any meaningful scale, the assessment under Article 37 points strongly towards needing one. That assessment is Bluebell’s to make and to record.

What we hold, and where it comes from

From this website: only what you type into a form and choose to send — your name, a way of replying to you, the area you are asking about, which service, who the enquiry is about, anything you write in the message box, and whether you need us to reply in a particular format. If you are enquiring as a professional, your organisation and role.

We use no analytics, advertising or tracking on this website, so we do not build a record of the pages you looked at. Our cookies policy explains the one thing this site stores and why it needs no consent banner.

If you live in one of our homes, or have been referred to us, we hold considerably more:

Referral information

What the person or organisation referring you told us: your situation, your needs, any risks to you or from you, and why supported housing was suggested. This often reaches us before we have met you.

Tenancy and occupancy records

Your agreement, who lives with you, identity and right to rent documents, the condition of the property, keys, and any notices.

Rent and housing benefit records

Your rent account, payments and arrears, and the information needed to make and maintain a housing benefit claim — which has a clause of its own below.

Support records

Your support plan, what you want to achieve, appointments, what support was given, and notes of conversations. Written on the basis that you can ask to read them.

Health, risk and safeguarding information

Where it affects your housing or your safety or somebody else’s — a condition that affects how you use the home, a risk assessment, a safeguarding concern, an incident.

Offending history and immigration status

Where a referral comes from prison or probation, or where the law requires a check on your right to rent.

Repairs, complaints and anti-social behaviour records

What you reported, what we did, and what was decided — under our repairs, damp and mould policy, our complaints policy and our anti-social behaviour policy.

Images from cameras in shared areas

Where a scheme has them — see the clause on cameras.

Where it comes from. From you; from whoever referred you — a council, a charity, probation, a hospital or prison discharge team, a refuge; from a relative or a support worker acting for you; from the council’s housing benefit service; and from our own staff and contractors recording what happened. Where information about you reaches us from somebody else, we will tell you what we hold and where it came from within a month at the latest, or sooner if we contact you before then.

Why we use it, and what allows us to

The law requires a specific basis for each thing we do with your information, not just a good intention. These are ours.

Letting and managing your home

Performance of the contract between us — your agreement for the home, whether that is a tenancy or a licence — and steps taken before it, such as assessing a referral.

Providing housing-related support

Performance of that contract, or our legitimate interests in supporting somebody to keep their home, or the performance of a task in the public interest where your placement is arranged and funded by a council.

Meeting our legal obligations as a landlord

Gas and electrical safety records, alarms, fire safety, right to rent checks, licensing applications, health and safety, and responding to a council’s enforcement enquiries.

Rent, housing benefit and arrears

Performance of the contract, and compliance with a legal obligation where the law requires us to give information to a council’s benefit service.

Protecting somebody who may be at risk

A task carried out in the public interest, or protecting somebody’s vital interests. We may act on a safeguarding concern without asking you first, and our safeguarding policy explains when and why.

Answering your enquiry

Our legitimate interests. You asked us a question; replying to it is the obvious and expected use of what you sent, and you can object at any time.

Reporting to the council or charity that commissioned a placement

Performance of a contract with them, or our legitimate interests in being accountable for work somebody else is paying for. We report what the contract requires and not more.

Recruitment

Taking steps towards an employment contract with you.

Giving us information is not usually a legal requirement, but some of it is necessary for us to house you: we cannot complete an agreement, a right to rent check or a housing benefit claim without it, and we will tell you when that is the position rather than leaving you to find out.

Health, risk and criminal record information

Information about health, disability, mental health, race, religion, sex life or sexual orientation is special category data. Information about offences and alleged offences is criminal offence data. Both need a second, stricter condition on top of the reason above. In supported housing this is not an edge case — a single paragraph in a referral often contains both.

Safeguarding somebody at risk

The safeguarding condition in Part 2 of Schedule 1 of the Data Protection Act 2018. It applies where we are protecting somebody from neglect or harm and asking for consent would be impossible or would get in the way of protecting them.

Meeting needs and keeping people safe in shared housing

A substantial public interest condition in Schedule 1, together with our obligations as a landlord. Risk information is used to decide whether a home is suitable and to keep the people living there safe — including you.

Offending history from a prison or probation referral

A Schedule 1 condition for criminal offence data. It is used to assess suitability and risk, and it is not shared with other residents.

An emergency where you cannot tell us anything

Vital interests, under Article 9(2)(c). A narrow last resort for genuine emergencies, not a routine basis.

Making reasonable adjustments

Where you tell us about a disability so that we can change how we do something, as set out in our equality and diversity policy.

Where we rely on most of these conditions we are also required to keep an appropriate policy document setting out how we comply with the data protection principles and how long we keep the information. It is an accountability record for the regulator rather than a published page, and the regulator can require us to produce it.

Housing benefit, and what we share with the council

Most people we house have their rent met through housing benefit, administered by the council rather than through universal credit. That is how supported housing of this kind is funded, and it means a continuous exchange of information between us and the council’s benefit service.

What passes between us:

• Confirmation that you live there, from when, and what the rent and service charge are.
• What the accommodation is and what support goes with it, so the claim can be assessed.
• Changes — when you move in, move out, go into hospital or are away.
• Rent account information where the council asks for it to verify a claim.

The claim is yours, not ours. Entitlement is decided by the council on each claim, and no provider is “approved” for it. We can help you claim and act as your representative if you ask us to, and we will tell you what we have sent.

Councils and the Department for Work and Pensions also check information against other records to prevent fraud, and we have to answer their enquiries. If a question is raised about your claim we will tell you, unless we are prevented from doing so.

Cameras in shared areas

Some supported housing has cameras in shared parts of a building — entrances, hallways, bin stores — usually because of a specific risk. A camera in the place somebody lives is far more intrusive than a camera in a shop, and it is treated that way here.

The rules we operate to:

• A data protection impact assessment before any camera is installed, and again before any change to what it covers. For this setting the regulator’s guidance makes that effectively mandatory: it is systematic monitoring of a communal area, and of people who may be at risk, in their home.
• No cameras in private areas. Never in a bedroom or a bathroom, and not pointed at an individual front door.
• No audio recording — it is rarely justifiable and we do not do it.
• No covert surveillance except in a specific, documented and exceptional case, authorised in advance and recorded.
• Signs saying who operates the cameras and why, where anybody can see them before they are recorded.
• Footage kept no longer than needed, viewed only by the people who have to, and released only to the police or another body with a lawful reason.
• You can ask for footage of yourself. We may have to obscure other people in it, which we will do rather than refuse.

Door entry systems and body-worn video are separate decisions with separate assessments, and neither is treated as covered by a general CCTV arrangement.

TBD — what is actually installed. Which schemes have CCTV, where the cameras point, how long footage is kept, who can view it, and whether a data protection impact assessment has been completed for each installation. Until this exists the notice describes the rules we will operate to rather than an installation we have. Operations has to answer it scheme by scheme.

Who else sees it

Inside Bluebell, your information goes to the people who need it to do their job — your support worker, the housing team, whoever is dealing with a repair — and not to everybody.

Outside Bluebell, we may share information with:

• The council — the housing benefit service, the team that commissioned your placement, adult safeguarding, environmental health, and the housing options team where you are at risk of homelessness.
• The organisation that referred you — a charity, probation, a hospital or prison discharge team, a refuge — where the referral or the contract requires us to report back.
• Health services and other support providers working with you, where you have agreed or where somebody is at risk.
• The police, where somebody is at risk of harm or to prevent or detect crime.
• Contractors coming to your home — your name, the address, and what is wrong. Not your support records.
• The owner of the building we lease from, where they need to know about the property. Not about you.
• Our professional advisers, and a court, where there is a legal claim.
• Suppliers who process information on our behalf and under our instructions.

TBD — the named suppliers. The named suppliers who process personal data on Bluebell’s behalf and what each one does — hosting, email, housing management system, repairs contractors, CCTV maintenance — and whether any of them store or access data outside the UK. A list that is wrong is worse than one that is honestly incomplete. Whoever manages the systems has to supply it.

We do not sell your information, we never share it for advertising, and we do not tell other residents anything about you.

How long we keep it

The law lets us state either a period or the criteria we use to work one out. Where we have confirmed a period we will state it. Where we have not, these are the criteria.

• An enquiry that goes no further. Kept long enough to answer it and to show we answered it, then deleted.
• A referral that did not result in a placement. Kept long enough to show how the decision was made and to answer a challenge to it, then deleted.
• Agreement and rent records. Kept for as long as the agreement lasts and then for the period in which a claim about it could still be brought — by you or by us. That is what sets the period, not a preference of ours.
• Support records. Kept while we are supporting you and for a period afterwards, because people ask for their own records later and are entitled to find them.
• Complaints and anti-social behaviour case records. Kept for as long as the agreement they relate to, and then for the period in which the decision could still be challenged — by you, by us, or by anybody reviewing how it was handled.
• Records about applying to work here. Kept for the period in which a claim about the recruitment decision could still be brought, then deleted.
• Safeguarding and serious incident records. Kept considerably longer, because they may be needed for a safeguarding adults review years afterwards.
• Gas, electrical and fire safety records. Kept for the periods the safety regulations themselves set.
• Camera footage. Kept for the shortest period that serves the reason the cameras exist, and overwritten after that unless it has been preserved for a specific incident.

TBD — the confirmed periods. The confirmed retention period for each record type — enquiries, referrals that did not proceed, occupancy agreement files, rent accounts, support records, complaints and anti-social behaviour case records, safeguarding records, incident records, recruitment records, equality monitoring data and CCTV footage. This is a decision for Bluebell and its data protection adviser, informed by the limitation periods for housing claims and by the safeguarding review horizon, and it is not one a website can make for them.

Whether it leaves the UK

Your enquiry and your records are held in the UK. Two things do leave, and neither of them is your information. The icon typeface on this site is served by Google, so your browser makes a request to Google’s servers and Google sees the IP address it comes from. The photographs are served by Cloudflare, so on pages carrying a photograph your browser fetches them from Cloudflare, which sees the same thing and may serve the image from outside the UK.

Neither is sent anything else about you, and neither stores anything on your device. We intend to remove both by serving the typeface and the photographs ourselves. Our cookies policy sets out exactly what each request involves.

TBD — whether any of our suppliers hold data outside the UK. The named suppliers who process personal data on Bluebell’s behalf and what each one does — hosting, email, housing management system, repairs contractors, CCTV maintenance — and whether any of them store or access data outside the UK. A list that is wrong is worse than one that is honestly incomplete. Whoever manages the systems has to supply it. If any of them store or access information outside the UK we will say so here and name the safeguard we rely on, and you will be able to ask us for a copy of it.

What you can tell us to do

These are rights, not requests we may grant. Some have limits, and where a limit applies we will tell you which one and why.

• See it. Ask for a copy of what we hold about you, including your support records and your rent account. Free, and normally within one month. We may have to take out information about other people, and we will tell you when we have.
• Correct it. Have something inaccurate put right. If we disagree about whether it is accurate, we record your view alongside ours.
• Have it deleted. Though not where we are required to keep it — a housing record or a safeguarding record cannot simply be erased on request.
• Pause our use of it while a disagreement about it is sorted out.
• Object to our using it, where we rely on legitimate interests or a public task.
• Take it elsewhere, in a portable form, where we hold it on the basis of consent or a contract.
• Withdraw consent at any time, where consent is what we relied on. Withdrawing it does not undo what was lawful before.

Ask through any route on our contact page, or tell any member of staff. We may need to check who you are first, which protects you rather than us. Since February 2026 we may stop the clock while we wait for information we genuinely need to answer a request, and we only have to make a reasonable and proportionate search — we will tell you if either applies to yours.

Asking for your records will never be treated as a complaint about us, and it will never affect your home.

Decisions made by a computer

We do not make any decision about you by automated means alone. No part of this website decides whether you are eligible for a home, no algorithm scores a referral, and nothing sorts people into risk bands. A person reads it. If that ever changes we will say so here, and you will have the right to have a human involved, to make your case, and to contest the outcome.

If you are unhappy with how we have handled your information

Tell us first. Since June 2026 you have a statutory right to complain directly to us about how we have used your personal information, and we have a duty to take it seriously. We will acknowledge it within 30 days and respond substantively without undue delay.

Then the regulator. If you are not satisfied with our answer — or if you would rather not come to us at all, which is your right — you can complain to the UK’s data protection regulator at ico.org.uk/make-a-complaint. Complaining to us first does not take away that right, and it does not affect your right to claim compensation through the courts.

A complaint about your home or your support, rather than about your information, goes down a different route with a different escalation body — our complaints policy sets out both stages and the time limits.

Changes to this notice

TBD — the date this notice was last reviewed. We will publish it here, and we will not backdate it. Where a change is significant we will say what changed rather than only moving the date.