Hull Churches Housing Association
Privacy and Cookie Policy
Effective date: October 2026
Policy owner: Hull Churches Housing Association (HCHA)
Review: This notice will be reviewed regularly and updated when necessary.
1. Introduction
Hull Churches Housing Association (HCHA) respects your privacy and is committed to protecting your personal information.
This Privacy and Cookie Policy explains how we collect, use, store and protect personal information when you visit our website, contact us, apply for housing, receive services from us or otherwise interact with HCHA through our website.
It also explains how we use cookies and similar technologies and the choices available to you.
HCHA processes personal information in accordance with applicable data protection and privacy legislation, including the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018 and, where relevant to our website, the Privacy and Electronic Communications Regulations (PECR). PECR contains specific requirements relating to cookies and similar technologies and operates alongside UK data protection legislation.
2. Who We Are
Hull Churches Housing Association is a registered housing provider delivering homes and housing-related services.
For data protection purposes, HCHA will normally be the data controller for the personal information covered by this notice. This means that we determine why and how your personal information is processed.
Hull Churches Housing Association (HCHA)
Studio 701
17 Princess Street
Hull
HU2 8BJ
Telephone: 01482 210842
Email: info@hcha.co.uk
Data Protection Contact: info@hcha.co.uk
3. Information We May Collect
The personal information we collect depends upon how you interact with HCHA.
Information you provide directly
This may include:
• your name, address and contact details;
• date of birth;
• information provided when applying for housing;
• information relating to your tenancy, lease or other relationship with HCHA;
• financial and payment information;
• employment information;
• information contained within enquiries or correspondence;
• complaints, compliments and other feedback;
• information provided when completing surveys or forms;
• information submitted as part of a recruitment process; and
• any other information you choose to provide to us.
Information collected when you use our website
Depending upon the technology and cookies used on our website, we may collect information such as:
• your IP address;
• browser and device information;
• pages visited;
• date and time of visits;
• how you navigate around our website; and
• cookie identifiers and preferences.
4. Special Category Information
In some circumstances HCHA may need to process information that is afforded additional protection under data protection legislation.
This can include information about an individual’s health, disability, racial or ethnic origin, religion or beliefs and other information classed as special category data under UK GDPR.
For example, information about a health condition or disability may be relevant where a resident requires an adaptation or needs HCHA to make reasonable adjustments when delivering a service.
Where we process special category information, we will ensure there is an appropriate lawful basis and additional legal condition for doing so.
5. How We Use Personal Information
IDepending upon your relationship with HCHA, we may use personal information to:
• respond to enquiries and requests;
• process housing applications;
• administer tenancies and leases;
• provide housing management and support services;
• arrange repairs and maintenance;
• manage rent and other payments;
• deal with complaints, reports and feedback;
• investigate incidents and concerns;
• manage antisocial behaviour, safeguarding and tenancy matters;
• meet legal, regulatory and health and safety obligations;
• prevent and detect fraud or crime;
• communicate with residents and service users;
• recruit employees and manage job applications;
• manage and improve our services;
• administer, secure and improve our website; and
• maintain appropriate records of our activities.
We will only use personal information where we have an appropriate lawful basis for doing so.
6. Our Lawful Bases
Depending on the circumstances, HCHA may rely upon one or more lawful bases under UK data protection legislation.
Contract
Where processing is necessary to enter into or perform a contract with you, such as a tenancy, lease or employment contract.
Legal obligation
Where processing is necessary for HCHA to comply with a legal obligation.
Legitimate interests
Where processing is necessary for HCHA’s legitimate interests or those of another organisation, provided your interests and fundamental rights do not override those interests.
Consent
Where we rely upon your freely given consent for a particular use of your information.
Vital interests
In limited circumstances, where processing is necessary to protect someone’s life.
Other lawful bases and additional conditions may apply where HCHA processes special category or criminal offence data.
7. Our Use of Cookies
Cookies are small files which websites can place on a computer, mobile phone, tablet or other device.
Cookies allow websites to recognise a device and can be used for functions such as remembering preferences and understanding how a website is being used.
ICO guidance describes a cookie as a small text file downloaded onto a user’s device when they access a website, allowing the website to recognise the device and store information about preferences or previous actions.
HCHA may use cookies and similar technologies to ensure our website operates effectively, remember choices made by visitors and, where applicable, understand how people use our website.
8. Types of Cookies We May Use
Strictly Necessary Cookies
These are required for the operation, security or essential functionality of the website.
They may, for example, be required to maintain security, enable essential website features or remember your cookie preferences.
Where the relevant legal exemption applies, consent is not required for cookies that are essential to provide a service requested by the user.
Analytics and Performance Cookies
These can help us understand how visitors use our website, such as which pages are visited and how visitors move around the site.
This information can help us identify areas where the website can be improved.
Where consent is required, these cookies will not be placed until you have given your permission.
Functionality Cookies
Functionality cookies allow a website to remember choices or settings and provide enhanced features.
Where these cookies are not essential, we will obtain consent where required before using them.
Third-Party Cookies
Some features or content on our website may be provided by third parties. Depending upon HCHA’s website configuration, this could include embedded maps, videos, analytics tools or other external services.
These services may place or access cookies on your device. Where consent is required, such technologies should not be activated until you have made the appropriate choice.
9. Cookie Consent
When you first visit the HCHA website, you may be presented with a cookie consent tool that allows you to manage your preferences.
Where consent is legally required, HCHA will obtain consent before the relevant cookies or similar technologies are used. ICO guidance states that users must be informed about such technologies, told what they do and, unless an exception applies, prior consent must be obtained to the UK GDPR standard.
Visitors should be able to reject optional cookies as well as accept them.
Strictly necessary cookies may operate without consent where the relevant legal exception applies.
10. Changing Your Cookie Preferences
You can change or withdraw your cookie choices at any time using our website’s Cookie Settings or equivalent facility, where provided.
You can also manage cookies through your browser. Please be aware that blocking certain cookies may affect how some parts of the website operate.
If HCHA materially changes the way cookies are used, we may need to ask visitors to make their choices again. ICO guidance notes that fresh consent may be needed if the use of cookies changes over time.
11. Cookies Used on the HCHA Website
| Cookie | Domain | Description | Type | Duration |
| sbjs_migrations | .hcha.co.uk | Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website. | Analytics | session |
| sbjs_current_add | .hcha.co.uk | Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website. | Analytics | session |
| sbjs_first_add | .hcha.co.uk | Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website. | Analytics | session |
| sbjs_current | .hcha.co.uk | Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website. | Analytics | session |
| sbjs_first | .hcha.co.uk | Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website. | Analytics | session |
| sbjs_udata | .hcha.co.uk | Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website. | Analytics | session |
| sbjs_session | .hcha.co.uk | Sourcebuster sets this cookie to identify the source of a visit and stores user action information in cookies. This analytical and behavioural cookie is used to enhance the visitor experience on the website. | Analytics | 1 hour |
12. Information Submitted Through Our Website
If you complete a contact form, report an issue, make an enquiry, apply for a service or otherwise provide information through our website, we will use the information for the purpose for which it was provided and, where appropriate, to communicate with you about your request.
Please only provide information that is relevant to your enquiry.
13. Sharing Personal Information
We may share information with other organisations where this is necessary and lawful.
Depending upon the circumstances, this may include:
• contractors and service providers;
• local authorities;
• government departments and agencies;
• regulators;
• utility companies;
• professional advisers;
• auditors;
• insurers;
• IT, hosting and website service providers;
• support organisations; and
• law enforcement or other statutory bodies.
Where organisations process personal information on our behalf, we will take appropriate steps to ensure that the information is appropriately protected.
HCHA does not sell your personal information.
14. International Transfers
Some suppliers or online services may process personal information outside the UK.
Where personal information is transferred internationally, HCHA will ensure that appropriate safeguards are in place where required by data protection legislation.
15. Keeping Your Information Secure
HCHA takes appropriate organisational and technical measures to protect personal information against accidental or unlawful loss, alteration, disclosure, destruction or unauthorised access.
Measures may include secure systems, access controls, staff training, information governance procedures and appropriate security arrangements with organisations processing information on our behalf.
Access to personal information is limited to those who have a legitimate need to use it.
16. How Long We Keep Information
HCHA will not keep personal information for longer than is necessary.
The period for which information is retained will depend upon matters including:
• why the information was collected;
• legal and regulatory requirements;
• contractual requirements;
• the nature of HCHA’s relationship with you; and
• whether the information may be required to establish, exercise or defend legal claims.
When information is no longer required, it will be securely deleted or destroyed in accordance with our retention arrangements.
17. Your Data Protection Rights
Depending upon the circumstances, data protection law provides individuals with rights including:
The right to be informed about how their information is used.
The right of access to personal information held about them.
The right to rectification of inaccurate or incomplete information.
The right to erasure in certain circumstances.
The right to restrict processing in certain circumstances.
The right to data portability in applicable circumstances.
The right to object to certain types of processing.
Rights relating to automated decision-making and profiling where applicable.
Not every right applies in every circumstance, and exemptions provided by law may apply.
18. Exercising Your Rights
If you would like to exercise a data protection right, ask a question about this policy or raise a concern about how HCHA has handled your personal information, please contact:
Hull Churches Housing Association
Studio 701
17 Princess Street
Hull
HU2 8BJ
Email: info@hcha.co.uk
Telephone: 01482 210842
We may need to confirm your identity before responding to certain requests.
19. Complaints
We would encourage you to contact HCHA if you have concerns about how your personal information has been handled so that we have an opportunity to investigate and respond.
You also have the right to raise a concern with the Information Commissioner’s Office (ICO), the UK’s data protection regulator.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
https://ico.org.uk/
20. Links to Other Websites
Our website may contain links to websites operated by other organisations.
HCHA is not responsible for the privacy practices of external websites. We encourage visitors to read the relevant privacy and cookie information when visiting another organisation’s website.
21. Other HCHA Privacy Notices
This website notice provides general information about HCHA’s handling of personal data.
We may provide additional privacy information for particular groups or activities, for example residents and tenants, housing applicants, employees, job applicants, contractors or people using particular HCHA services.
Where a more specific privacy notice applies, it should be read alongside this policy.
22. Changes to This Policy
HCHA may amend this Privacy and Cookie Policy where necessary to reflect changes to our services, website, use of technology, legislation or regulatory guidance.
The current version will be published on the HCHA website.
