This policy describes how mhs homes will use any personal data you provide us.  Please read this policy carefully and make sure that you understand your rights and responsibilities.  In this policy, when we refer to the ‘site’ we mean anywhere on our website

About us

The mhs homes group (Company number 10704997, Charity number 1177565) which includes: mhs homes ltd, mhs community charity ltd, Heart of Medway Housing Association Ltd, Chatham Maritime K1 Construction Ltd, Chatham Maritime K1 Development Ltd, mhs commercial services ltd and Lord Kitchener Almshouse Trust, generates records from our contact with you, including records of some personal information which is subject to the General Data Protection Regulations (GDPR).

Registration with the Information Commissioner’s Office

For the purpose of the Data Protection Act (1998) the following companies are registered as a data controller with the Information Commissioners Office with registration numbers of:

mhs homes ltd Z629086

Heart of Medway ZA079387

mhs community charity ltd Z5296068

Data Protection Officer

mhs homes’s Data Protection Officer is:

Catherine Hardy-Smith
mhs homes, Broadside, Leviathan Way, Chatham, Kent, ME4
(t) 01634 565333

Personal data processed by mhs homes

How we collect information from you

We collect information from you in a range of ways and at a number of different times.

These include:

  • on forms, tenancy agreements, and contracts;
  • through our on going contact with you;
  • in some cases CCTV images;
  • recording calls to and from our 01634 565333 phone number;
  • via our website (see information we collect via our website and our Cookie Policy page)

How we use personal information

We collect, process, share and securely store personal information in compliance with the GDPR. We collect and process personal information to allow us to allocate and manage homes and to improve services.

‘Special’ personal information

Under GDPR certain personal information is classified as “special”. Special data is information relating to physical or mental health, gender, religious or philosophical beliefs, political opinions, membership of a Trade Union, allegations of criminal offences and criminal convictions and offences. We minimise holding and using sensitive categories of personal information but, given the services we provide, there are times when we need to collect it and use it, for example when providing accommodation for disabled people, people with substance abuse problems, when resolving neighbourhood disputes involving alleged criminal activity or when helping someone to access care services.
When we collect special categories of data we will notify you of how we will use it, including who it may be shared with.

What do we collect

When you apply to become an mhs customer, we request and hold on file any information necessary to assess your application including: (as appropriate but not limited to) references from other housing providers/private landlords, your mortgage lender (if you own/have owned your own home), the Police, the Probation Service, support workers, social workers, mental health workers and credit reference agencies.
If you provide us with personal information relating to members of your family or your associates we will assume that you do so with their knowledge and their consent to the collection and processing of the information.
It is important that you notify us of any changes to your personal information.

In connection with queries, complaints, reports of anti-social behaviour and other communications

We may process information disclosed to us by any party (including yourself) in connection with allegations of anti-social behaviour where you are identified as an alleged victim, witness or perpetrator or are the reporting party. This may include your name, address and contact details, witness and other statements describing the alleged incident or behaviour and the circumstances, interviews and assessments by investigating officers, correspondence with relevant agencies, including (but not limited to) the police and local authorities. The legal bases for this processing are for performance of our contractual obligation to make sure that tenants are allowed quiet enjoyment of their homes. Also for our legitimate interest in making sure that the local community neither commits nor suffers any unnecessary disturbance.

Who we collect personal data about

mhs homes collects, stores and processes personal data for several purposes, mainly: personnel administration, financial accounting, managing tenancies and marketing. The detail of this is described in the table below.
In this section we have set out:

  1. the general categories of personal data that we may process
  2. the source and specific categories of that data, for personal data that we did not get directly from you
  3. the purposes for which we may process your personal data
  4. the legal bases of the processing. When we refer to a ‘legal basis’, we mean the provision of the General Data Protection Regulation under which we conduct the relevant processing.


Type of data Purpose Legal Basis Retention period
Recruitment (potential staff) Recruiting employees Consent 6 months
Staff (this includes current and former staff, as well as Board and Committee members, apprentices and volunteers) Administration Performance of a contract 6 years after employment ceases
Payroll Administration Performance of a contract 6 years
Suppliers Administration Performance of a contract 6 years
Customers (current, former, potential customers - this could include family & people associated with them) Administration Performance of a contract End of tenancy +6 years
Marketing email list Sending newsletters Consent For as long as consent is valid
Recorded telephone calls Quality and Training Performance of a contract 3 months
CCTV (where there is no incident) Promote Public safety Performance of a contract 30 days

Data sharing

Your personal information will be kept secure and confidential. Usually we will not disclose personal data without consent but we may share information between the mhs homes group of companies, with contractors or third parties and other agencies we work with, including local authorities, social services, the police, other social landlords and other agencies when mhs homes believes it is in yours or the public’s interest to do so, or as required by law.

In particular, please be aware:

      • Current or forwarding addresses may be shared with utility companies and Council Tax offices to ensure billing details are correct.
      • If you default upon any tenancy/licence conditions information about you may be provided to authorised debt recovery agencies, to enable them to recover the debt. This may affect future applications for tenancies, credit and insurance.
      • Welfare rights advisor, the housing benefit department or the local authorities housing advice and homeless prevention team to make sure that benefits are paid correctly.
      • mhs homes uses sub-contractors to carry out works on our behalf, your information will be shared in order for the works to be carried out efficiently.
      • mhs homes will not sell your data on to 3rd parties.

Online apps we use

We use a number of online apps to communicate with our customers and make sure our services are as great as they possibly can be.

Platform Used for Opt out
Facebook, Twitter and Instagram to communicate with our customers and stakeholders, and to serve adverts for our properties.
Sprout Social to monitor all our social media platforms, help customers and to quickly respond to questions
Linkedin to share business updates about mhs and stories of what it's like to work here
Livechat to talk to customers who are visiting our website and want to text chat with us
Hotjar to track (anonymised) customer behaviour on our website and find out whether our customers are struggling to find content Opt-out
Google Analytics to track the statistics of (anonymised) usage of our website and services Opt-out
Campaign Monitor to send emails to our customers and stakeholders Opt-out
Eventbrite to let customers and stakeholders sign up to our events and activities

Data matching

Data matching involves comparing computer records held by one body against other computer records held by the same or another body to see how far they match. This is usually personal information.

Computerised data matching allows fraudulent claims and payments to be identified. Where a match is found it may indicate that there is an inconsistency which requires further investigation.

No assumption can be made as to whether there is fraud, error or other explanation until an investigation is carried out.

We intend to participate in the National Fraud Initiative (NFI) data matching exercise carried out by the Audit Commission.

Our participation in NFI will assist in the prevention and detection of fraud against mhs homes and organisations within the public sector.

We will participate on a voluntary basis and provide the Audit Commission with particular sets of data for matching as set out in the Audit Commission’s guidance.

The use of data by the Audit Commission in a data matching exercise is carried out with statutory authority under its powers in Part 2A of the Audit Commission Act 1998.

It does not require the consent of the individuals concerned under the Data Protection Act 1998.

Data matching by the Audit Commission is subject to a Code of Practice.

Further information on the Audit Commission’s legal powers and the reasons why it matches particular information is available here. For further information on data matching at mhs homes, contact Andrew Pert on 01634 354081.

International Transfers

In this section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

Our website is hosted within the EEA. Our other systems are generally located on our premises or elsewhere within the EEA, but some services used for email distribution of newsletters and other mass communication are located within the United States of America.

Some of the other third parties to whom we may transfer your personal data, may be located outside the EEA or may transfer your personal data to their own service providers located outside the EEA.

Where data is transferred outside the EEA, then we will make all reasonable endeavours to ensure that transfers will only be made to countries in which the European Commission has made an ‘adequacy decision’. Otherwise they will only be made with appropriate safeguards, such as the use of standard data protection clauses adopted or approved by the European Commission. You may contact us to enquire about such safeguards. You can obtain a copy of them or we can direct you to them.

Your rights

You have the following rights concerning your personal data:


Right of access You have the right to obtain confirmation from mhs homes as to whether or not personal data concerning you are being processed, and, where that is the case, access to that personal data.
Right to rectification You have the right to oblige mhs homes to rectify inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed by providing a supplementary statement.
Right to erasure (right to be forgotten) You have the right (under certain circumstances, but not all) to oblige mhs homes to erase personal data concerning you.
Right to data portability You have the right (under certain circumstances, but not all) to oblige mhs homes to provide you with the personal data about you which you have provided to mhs homes in a structured, commonly used and machine-readable format. You also have the right to oblige mhs homes to transmit those data to another controller.
Right to withdraw consent If the lawful basis for processing is consent, you have the right to withdraw that consent.
Right to object to direct marketing Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for marketing, which includes profiling to the extent that it is related to such direct marketing.

About Cookies

Cookies are small text files that are placed on your computer by websites you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. You may delete and block all cookies from this site, but parts of the site may not work as they are intended.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit About Cookies.

For more information on how we use cookies and how you can manage your cookies, please view our Cookies Policy.

Third parties and security

The site contains links to third party websites and refers to third party service providers and other entities. If you follow a link to any third party website or deal with any third party entity referred to on the site, then you should note that these third parties may have their own privacy and cookie policies, and that we are not responsible for their use of any personal data which you may provide them. You should make sure that you have read and understood any relevant policies.

Although we do our best to ensure the security of personal data provided to us, and to use only reputable service providers, any transmission of data via the Internet is by its nature insecure and we cannot guarantee the security of any personal data you provide us

Your right to complain to the Information Commissioners Office

If you wish to exercise any of your rights concerning your personal data, you should contact mhs homes’s Data Protection Officer at the address shown above. If you are not satisfied with the response you receive you have the right to complain to the supervisory authority. In the United Kingdom this is:

Information Commissioner's Office
Wycliffe House
Water Lane
(t) 0303 123 1113


We may update this notice from time to time by publishing a new version on the site. You should check occasionally to make sure you are happy with any changes to this privacy notice, although we will notify you of material changes to this notice using the contact details you have given us.