Grosvenor Hart Homes design of support services privacy notice


The data controller for the purposes of the Data Protection Act and the General Data Protection Regulation is GHH (POC) Limited of 70 Grosvenor Street, London, W1K 3JP.

GHH (POC) Limited strongly believes in protecting your privacy and the confidentiality of your personal information. To explain how GHH (POC) Limited collects, uses and protects personal information in connection with tenant management we have developed the following privacy notice. In this privacy notice, ‘We’ and ‘Us’ means GHH (POC) Limited.

This privacy notice applies to those who are taking part in GHH (POC) focus groups to help us design a range of support services that meet the needs of local children, young people, and families. 

1. Contact details

You can contact us with any questions you may have about privacy and/or data protection. 

Please write to us at hello@grosvenorhart.com 

2. About this privacy notice

We explain in detail below the types of information that we collect, how and why we use that information, and what rights you have in connection with your personal information.

We must have a lawful basis to process your personal information, and this privacy notice explains what our lawful basis is in respect of each purpose for which we keep and use personal information about you. Generally, we are allowed to process your personal information where we have a legitimate interest to do so (but we will always consider whether your right to privacy overrides our interest).

3. What personal information do we collect about you?

3.1 When you contact us for the first time

We may collect and use the following personal information about you:

  • Identification and contact information, such as your full name, postal address, email address and telephone number(s)

3.2 Information collected during focus groups

We may collect and use the following personal information about you, so that we can understand how the services we design can help you and others across the local community: 

  • Age
  • Nature of support previously received
  • Housing status
  • Education or employment status

If appropriate we may ask for sensitive personal information about you such as:

  • Racial or ethnic origin
  • Information about your physical and/or mental health

For further information about this, please see information on ‘Sensitive personal information’ and ‘Information about criminal convictions’ under the section on ‘How we use your personal information’.  

The information we record may be in the form of notes on what you say during workshops, advice you give us over email on any materials we send you or photographs of things you complete during the workshop activities e.g. post-it notes or worksheets.

3.3 Improving your experience

With your consent we may use your name, photo, video, and experience with us for brochures, advertising, or press releases.

We will process your personal information if you contact us with compliments and/or complaints about our services.

If you attend our events, we may contact you for feedback on how they have helped you.

3.4 Additional services

We pride ourselves on being active in the communities we work in.  Your personal information may be used to help develop our services within localities.

We may collect and use the following personal information about you if you participate in any of our involvement or community projects.

4. How is your personal information collected?

We collect personal data in two phases, and by the following means:

  1. In small groups of fewer than 20 people during online and physical workshops. This will use tools such as storytelling, visual diagrams, and activity templates; and
  2. One to One interviews with participants.

5. How do we use your personal information?

5.1 Legal basis to use your personal information

The principal legal bases on which we use your personal information are to pursue legitimate interests of taking part in GHH (POC) focus groups to help us design a range of support services that meet the needs of local children, young people and families.  This is provided your interests and fundamental rights do not override those interests.

The information you provide will be used for the purposes of contacting you to organise workshops or to share information about the project with you. It will also be used to help us to spot themes and understand the needs of families so we can make sure we are creating the right services.

5.2 Telling you about events and activities that we think may be of interest to you

We may use your personal information to identify and tell you about events and activities that we think may be of interest to you. We will only do this by email where you have informed us that you would like to receive these communications via email. Whether you choose to receive this information via email is entirely up to you. Your choice will not affect your access to support. You can update your preferences by responding to our emails to you, or by contacting us (see contact details above).

We may also use your information to invite you to participate in market-research. If we do contact you about market-research, you do not have to participate. If you tell us that you do not want to receive market-research communications, we will respect this.

5.3 Change of purpose

We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.4 Sensitive personal information 

Sensitive Personal information, such as ethnicity, religion, sexual orientation, and physical and mental health requires higher levels of protection. We need to have further justification for collecting, storing, and using this type of personal information and this may require your explicit consent. 

6. Who do we share your personal information with?

6.1 Sharing your personal information internally

We may share your personal information with our employees where this is necessary, such as for internal administration purposes. Your personal information will only be shared with such employees as are reasonably necessary for these purposes.

6.2 Sharing your personal information with third parties

GHH (POC) is working with two external service design companies, Dartington Service Design Lab and Engine Service Design, to design a range of services that meet the needs of local children, young people and families.

Representatives from these external service design companies may be present at focus group sessions so they can better understand local needs and therefore may be present when you are sharing information about your life experiences as part of the focus groups. They may also contact you with your consent to get your feedback and input on the shape of GHH (POC) services.

We will not share anything that would identify you with anyone outside of the research team without your consent unless we are required to do so by law; or if we feel we need to do so to keep you, your family, our employees or the public safe; or where we have another legitimate interest in doing so.  This may include sharing your personal information to do with any of the following:   

  • Local authorities, government departments and the NHS for providing any support services
  • Police for crime prevention or detection, resolutions of complaints or other issues
  • Providing professional advice and support
  • To comply with judicial proceedings, court orders or legal or regulatory proceedings

7. How long do we keep your personal information?

We will hold your personal information for the duration of the service design process which is expected to take place over the course of 18 months.  

We will remove any personal information that is provided with your explicit consent, as soon as possible after you have requested its removal.  

8. How do we protect your personal information?

We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this notice.

All personal information you provide to us is stored securely, including in a physically secure environment, on our secure servers.

Access to your personal information will be restricted to such employees and other individuals as are necessary for the purposes for which the information was collected.

Due diligence has been carried out to ensure that the service design companies also store your data securely and safely in line with data protection and information security requirements.

9. What rights do you have in respect of your personal information?

9.1 You have the right to be informed

We have a legal obligation to provide you with concise, transparent, intelligible, and easily accessible information about your personal information and our use of it. We have written this notice to do just that, but if you have any questions or require more specific personal information, you can contact us (see contact details above).

9.2 You have the right to access your personal information

You have the right to ask us to confirm whether we hold any of your personal information. If we do, you have the right to have a copy of your information and to be informed of the following:

  • Why we have been using your personal information
  • What categories of personal information we were using
  • Who we have shared your personal information with
  • How long we envisage holding your personal information

To maintain the security of your personal information, we will have to verify your identity before we provide you with a copy of the information we hold.

9.3 You have the right to correct any inaccurate or incomplete personal information

You have the right to amend any inaccurate personal information about you which we hold. If you need any support, please contact us (see contact details above).

9.4 You have the right to be forgotten

There may be times where it is no longer necessary for us to hold personal information about you. This only relates to the following:

  • The personal information is no longer needed for the original purpose that we collected it for
  • You withdraw your consent for us to use the personal information (and we do not have another lawful reason to use it)
  • You object to us using your personal information and we have no overriding reason to keep using it
  • We have used your personal information unlawfully
  • We are subject to a legal requirement to delete your personal information

In those situations, you have the right to have your personal information deleted. If you believe one of these situations applies to you, please contact us (see contact details above).

9.5 You have the right to object to participating in the focus groups and receiving emails from us about events and activities

You can tell us at any time that you no longer want to participate in GHH(POC) focus groups for service design or would prefer that we do not use your email address to be contacted about events and activities. If you would like to no longer be part of GHH(POC) service design focus groups or to stop receiving emails about events and activities please contact us (see contact details above) or respond to the emails that we send, and we will stop sending these immediately.

9.6 You have the right to object to us using your personal information for our own legitimate interests

Sometimes, we use your personal information to pursue our own legitimate interests, or those of third parties (please see ‘How do we use your personal information?’ above for more information about such interests).

We aim to always ensure that your rights and personal information are properly protected. If you believe that the way we are using your personal information is not justified due to its impact on you or your rights, you have the right to object. Unless we have a compelling reason to continue, we must stop using your personal information for these purposes.

To exercise your right to object to our use of your personal information for the purposes above, please contact us (see contact details above).

9.7 You have the right to restrict how we use your personal information

You have the right to ask us to stop using your personal information in any way other than simply keeping a copy of it. This right is available where:

  • You have informed us that the personal information we hold about you is inaccurate, and we have not yet been able to verify this
  • You have objected to us using your personal information for our own legitimate interests and we are in the process of considering your objection
  • We have used your personal information in an unlawful way, but you do not want us to delete your personal information
  • We no longer need to use the personal information, but you need it for a legal claim

If you believe any of these situations apply, please contact us (see contact details above).

10. Complaints

If you wish to make a complaint about our collection or use of your personal information, please contact us in the first instance so that we may seek to resolve your complaint.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the statutory body which oversees data protection law in the UK.  The ICO’s website is www.ico.org.uk

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