Terms and Conditions, and Privacy Policies

2a. Privacy Notice (including details of the National Fraud Initiative)

2b. Data Protection Policy

2c. Cookie Notice

1.Terms and Conditions - website

Sovereign makes every effort to ensure that the material contained in this website is accurate and up-to-date. However, we cannot warrant the accuracy and completeness of such material.

We make every effort to ensure that links from this website to third party websites are relevant, current and appropriate. However, we do not accept liability in connection with any third party websites which may be linked or accessible through our websites and we do not endorse or approve the contents of any such site.

Any data submitted via our online forms is not secure and we cannot guarantee that information submitted will not be intercepted or modified, or that it will be received safely.

We make every effort to ensure that our systems and website are free from viruses and harmful files. However, the material accessed through the use of our web pages is obtained entirely at your own risk and you will be responsible for any resulting problems or damage to software or computer systems and/or any resulting loss of data.

In no event will Sovereign be liable for any direct, indirect, special, incidental, or consequential damages arising out of the use of the information held on the site.

Nothing on this website shall be construed as an offer or the basis for a contract between us and you or any other party.

Information on this website is provided for information purposes only, you should not rely on it to make any decision without either taking professional advice or verifying the accuracy of the information provided.

The materials on our website are owned by us and we reserve copyright and all other rights in them.  Our name and any image or logo we use to identify ourselves are our trade marks and may not be reproduced without our permission in writing.

You may download, print and store information from this website while acknowledging our copyright in it.

Our website and these terms and conditions shall be governed by English law and subject to the exclusive jurisdiction of the English Courts.

Sovereign  Housing Association Limited is a charitable Registered Society under the Co-operative and Community Benefit Societies Act 2014, registered with the Financial Conduct Authority no. 7448 and with the Homes and Communities Agency no. 4837. Registered office: Woodlands, 90 Bartholomew Street, Newbury, Berkshire RG14 5EE.

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2.Privacy Policies

2a.  Privacy Notice 

2b.  Data Protection Policy 

2c.  Cookie Notice

2a. Privacy Notice

Sovereign respects the privacy of its residents.  Your contact with us generates records including records of some personal information which is subject to the Data Protection Act 1998.

This privacy notice explains our approach to data protection.  In this privacy notice, “we”, “us”, “our” and “Sovereign” means any of the Sovereign group entities.  You can see a full list of the entities in our terms and conditions on the website.

How we collect personal information

We collect information in a variety of ways including via the websites, on various forms, and contracts, and through our ongoing contact and correspondence with you with other support agencies which relates to you, and from people associated with you such as family, friends and neighbours. We record calls to and from Connect (our Contact Centre).  At some schemes and offices we have CCTV cameras to record events in public areas.

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 consent.

It is important that you notify us of any changes to your personal information as soon as possible so that we can contact you easily.  You can let us know about changes via MySovereign or by contacting us.

What information we hold

When you apply to become a Sovereign customer, we obtain information to determine your housing needs.  In order to help us assess your application, we may take up 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. 

Once you become a Sovereign customer, we will also need your bank details, benefit and council tax information, feedback from our contractors about their appointments with you and other aspects of our routine contact with you. We will record information whenever you contact us or use our services and we will note any action taken, for example logging repairs, so that we have a record of what happened.

We may take photographs at events organised and hosted by Sovereign.  The images would be used on Sovereign’s websites, in brochures and other publicity material (such as newsletters) and may be provided to the media for publication in local or national newspapers.  You will always be given the option not to be included in a photograph.  Where group shots are to be taken there will be a sign warning that photographs are being taken and any individual photographs will only be taken with your consent in writing.

Who the personal information relates to

We collect and hold personal information about: 

Customers - This includes current, former and potential customers who live in our properties or access our support and other services and includes members of their family and people associated with them. 

Visitors - Visitors to our website and our offices.  Anyone who makes a complaint or enquiry to Sovereign.

How we use our records

We keep records to allow us to: 

  • Make allocations of accommodation
  • Manage tenancies including collecting rent and service charges 
  • Provide a repairs and maintenance service
  • Provide home ownership products
  • Offer help with debts and benefits
  • Provide support services which help customers achieve their goals
  • Provide care and support for elderly and vulnerable customers
  • Keep in touch with our customers, understand your needs and preferences and invite you to events
  • Prevent and detect crime and resolve disputes
  • Prevent and detect fraud and moneylaundering
  • Promote safety and the quiet enjoyment of our neighbourhoods and communities
  • Engage with customers and make improvements to our products and services
  • Promote equal opportunities and fair treatment for all our customers
  • Provide information (e.g. about products and services) you request from us
  • Develop new products and services to meet the future needs of our communities
  • Meet our legal obligations, including those owed to our funders or regulators

"Sensitive" personal information

Under the Data Protection Act 1998 certain personal information is classified as “sensitive”. Sensitive data is information relating to physical or mental health, sex life, religious or philosophical beliefs, political opinions, membership of a Trade Union, allegations of criminal offences and criminal convictions and offences.

We minimise our holding and use of sensitive categories of personal information but, given the services we provide, there are times when we use it to understand our customers and their needs better, for example when providing accommodation for disabled persons or those with problems around substance abuse, when resolving neighbourhood disputes involving alleged criminal activity or when helping someone to access care services. When we collect specific sensitive data we will notify you of how we will use it, including who it may be shared with, and seek your consent to this. 

Direct marketing

We would like to provide you with information about events, services and other information which we think you may find interesting. We may send you such information by post, email or contact you by telephone.  You can let us know at any time how you prefer to be contacted or if you do not want us to contact you with this information.

We never provide your personal information to other companies for their marketing purposes. 

Sharing your information

Your personal information will be kept secure and confidential. Our staff have restricted access to personal information on a “need to know” basis.  We may share information with contractors, or agencies we work with, such as Local Authorities, Social Services, Police, other social landlords, with a purchaser or potential purchaser of our business and others when Sovereign believes it is in your, or the public’s, interest to do so.  We will also disclose information 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 on 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.
  • We may discuss your financial situation, rent payments (including any arrears) and any claims made for welfare benefits with an external debt advice agency, 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.
  • We may pass data about your rent payment record to credit reference agencies. This will enable them to assist other organisations to assess your financial standing if you apply for products and services.
  • We may pass your contact information to a third party to conduct surveys and research on our behalf which allow us to gather feedback and improve the services we offer you. The third party will be bound to strict terms and conditions outlined by us and will not share your data with other organisations. Should you choose not to participate in the surveys the third party will securely destroy your data.
  • We may share your National Insurance number to verify your Universal Credit application and manage these payments.

    We may also share your National Insurance number in order to prevent and investigate tenancy and right to buy applications fraud.

National Fraud initiative

We occasionally participate in the National Fraud initiative (NFI) data matching exercise carried out by the Cabinet Office. Our participation in NFI assists in the prevention and detection of fraud against Sovereign and organisations within the public sector. We participate on a voluntary basis and provide the Minister for the Cabinet Office with particular sets of data for matching as detailed here.

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.

The use of data by the Cabinet Office in a data matching exercise is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the Data Protection Act 1998. Data matching by the Cabinet Office is subject to a Code of Practice.

Your rights

You have the right to ask us in writing not to process your personal information if it is causing or likely to cause substantial damage or distress, or for the purpose of direct marketing. There may also be other specific circumstances where you may wish for us to stop processing your data, such as if you agreed to take part in a survey or signed up to an optional service. However, we need to maintain certain records to enable us to provide you with the services you enjoy.

You have the right to access any personal information we hold about you.  If you would like copies of some specific information from your files, we will try to provide it as quickly as possible. Please contact your Housing Officer, our Connect Team or the Company Secretary.

If you require a substantial amount of your personal information, there is a formal process for this, under the Data Protection Act 1998, known as a Subject Access Request (SAR).

You also have the right to claim compensation if we fail to comply with the Data Protection Act 1998 and you suffer damage as a result.

What you need to know about making a SAR:

  • The right of subject access under the Data Protection Act 1998 is an individual one. This means that we cannot process joint requests – they have to be treated separately.
  • You can write to us to make your request and, if necessary, we will provide you with a SAR form for completion. Please write to the Company Secretary, Sovereign Housing Association Limited, Woodlands, 90 Bartholomew Street, Newbury, RG14 5EE.
  • We will require proof of your identity and address – we will let you know this when we receive your request.
  • We charge a nominal fee of £10 towards our administration costs for each SAR.
  • When we receive your request with payment and have confirmed your identity to our satisfaction, we shall respond and provide your information within 40 calendar days.  

Changes to our privacy notice

This privacy notice will be updated to reflect changes either to the way in which we operate or changes to data protection legislation. We will bring any significant changes to your attention but to make sure that you keep up to date, we suggest that you revisit this notice from time to time. 

Contacting us

We welcome any queries you may have regarding this privacy notice, or any information we hold about you. Please contact:

Company Secretary
Sovereign Housing Association Limited
90 Bartholomew Street
RG14 5EE

Other Resources

The Information Commissioners Office (ICO) is the UK’s independent body who upholds information rights in the public interest. Sovereign are registered as a Data Controller with the ICO. Their contact details are below:

Information Commissioner's Office
Wycliffe House Water Lane

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number
Fax: 01625 524 510
Website: https://ico.org.uk/

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2b. Data Protection Policy (the ‘Policy’)

Sovereign Housing Association Limited and its subsidiaries (‘Sovereign’) controls and processes personal information about its customers, staff and board members. The Data Protection Act 1998 (the ‘Act’) covers all personal information that relates to living individuals. These individuals are given rights by the Act. We will not share this information with other organisations without the consent of the individual concerned unless we are required by law to do so.

This Policy will set out what Sovereign will do to comply with the Act and the following eight principles:

  • Personal data shall be processed fairly and lawfully.
  • Personal data shall only be obtained and further processed for specified and lawful purposes.
  • Personal data shall be adequate, relevant and not excessive in relation to the purpose that they are processed.
  • Personal data shall be accurate and kept up to date.
  • Personal data shall not be kept longer than necessary.
  • Personal data shall be processed in line with the rights of the data subject.
  • Personal data must be kept secure.
  • Personal data must not be transferred to a country without adequate protection.

Being fair and understanding our customers’ needs

We recognise that communities are made up of people with different needs and values and that those differences are important. We will promote equality of access for everyone and value their diversity. We will work to eliminate discrimination and, in line with the law, we will treat everyone fairly, regardless of age, disability, gender, gender reassignment, marital status including civil partnerships, pregnancy and maternity, race, religion or belief or sexual orientation.

We will ensure that members of all these groups are treated in ways that meet their needs, and that they have equal access to services and/or activities wherever possible. We will promote their inclusion and challenge discrimination against them.


This Policy applies to all employees, board members and others who may be involved in the collection of and processing of personal information on behalf of Sovereign and extends to data whether it is held on paper or by electronic means.

Statement of commitment

Sovereign is committed to maintaining high standards of security and confidentiality for information in our custody and control. Safeguarding this information is critical to the successful operation of Sovereign. Sovereign will treat all information in its care and control with the same degree of security and confidentiality, and this Policy applies to all organisations within Sovereign and all its employees. Sovereign undertakes to inform residents, contractors, employees and board members on how it uses information and the purposes for which information is processed.


The objectives of this Data Protection Policy are:

  • To comply with the Data Protection Act 1998.
  • To outline, guide and monitor the coordination of the information security and data handling procedures in force within Sovereign.
  • To promote confidence in Sovereign’s information security and data handling procedures.
  • To provide assurances for third parties dealing with Sovereign.
  • To provide a benchmark for employees on information security, confidentiality and data protection issues.


In order to support these objectives, Sovereign will:

  • Delegate the responsibility for gathering and disseminating and dealing with issues relating to information security, the Data Protection Act and other legislation.
  • Ensure that all activities that relate to the processing of personal data have appropriate safeguards and controls in place to ensure information security and compliance with the Act.
  • Ensure that all contracts and service level agreements between any part of Sovereign and external third parties (including contract staff), where personal data is processed, make reference to the Act where appropriate.
  • Ensure that third parties acting on behalf of Sovereign are given access to personal information that is appropriate to the duties they are undertaking and no more.
  • Ensure that all staff (including contract staff) and board members understand their responsibilities regarding data protection and information security under the Act. 

Individuals’ rights of access to data

Individuals have a right of access to personal information held by Sovereign if they are the “data subject” of that information. Requests must be made in writing, signed by the data subject and addressed to the Company Secretariat. The person requesting the data must complete the Access Request Form providing details of the information required as well as their current address and some form of identification. The Act allows Sovereign to charge a £10 administration fee for searching for this information.

Someone may ask a third party to obtain the information on their behalf, but they must provide written consent in order to do this.


In some circumstances it may be appropriate to disclose information held by Sovereign to specific third parties for example to prevent a criminal offence from being committed, or to prevent the continuation of a criminal offence.

Data retention

Data should not be kept for longer than is necessary. Sovereign’s Document Retention Policy should be referred to for guidance on the retention of data.


Where personal and confidential information is no longer required, it will be destroyed.

Employees should refer to the appropriate data retention guidelines for their respective departments.

Policy promotion and training

This Policy will be made available within Sovereign as part of the induction process to all new and temporary employees and board members.

The Policy will be promoted to current employees by requiring acknowledgement and acceptance of its aims and objectives. There will be a continuing series of awareness raising initiatives relating to security and privacy issues by the Data Protection Champions nominated around Sovereign in order to ensure that all staff understand their responsibilities under the Act.

All employees will be provided with education and training where appropriate and will be expected to comply with data protection legislation and adhere to the policies and procedures used to meet the objectives of the Sovereign Data Protection Policy.


Any wilful disregard or intentional breach of the Data Protection Policy by employees shall be regarded as a disciplinary offence and handled within Sovereign’s Disciplinary Procedures. Any wilful disregard or intentional breach of the Data Protection Policy by data processors acting on Sovereign’s behalf under contract shall be regarded as a breach of contract and treated as such.

Equality impact assessment (‘EIA’)

After completing a Stage 1 EIA, it was found that this Policy will affect all employees and residents in the same way as all personal data should be processed in accordance with the Act. As long as any data requested is made available in a way that is suitable for the needs of the data subject, there will be no adverse impact on any particular group.

Monitoring and feedback

A programme of continuous review of this Policy’s implementation and effectiveness is to be conducted under the direction of the Company Secretary. An annual report with recommendations will be presented to the board of Sovereign Housing Association Limited.

This Policy can only be amended with the approval of the board of Sovereign Housing Association Limited.

Glossary of terms

  • Personal Information – any information that relates to a living individual who can be identified by this data. This includes opinions about the individual and an indication of the intention of Sovereign or any other person in respect of the individual.
  • Data Subject – the living individual that the personal data is about.
  • Data Controller – the company that decides the purpose for and the way in which any personal data is processed. Sovereign Housing Association and certain of its subsidiaries are data controllers.
  • Data Processor – any company that carries out activities with personal data on behalf of the data controller.

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2c. Cookie Notice

We use cookies on our website to improve the experience you have and to help us identify areas we could develop further. Our policy explains:

  • What a cookie is
  • Why we use them
  • How you can control them

What is a cookie?

Cookies are small text files that are stored in your computer (or mobile device) when you visit a website. They collect basic information that allows the website to remember who you are (during your visit if it is a 'session cookie' or between visits if it is a 'persistent cookie' – see jargon busting below for a full explanation).

The information collected allows the cookies to do lots of useful tasks - navigation between pages, remembering preferences, showing popular pages - that give you a better interaction with the website. 

Jargon busting

  • First party cookies are created by the website you're visiting.
  • Third party cookies are created by other websites which have content on the page of the website you're viewing.
  • Session cookies are temporary and are used only during a web browser session (examples of web browsers are Internet Explorer and Google Chrome). A browser session starts when you open a browser window (which is when the session cookie starts) and ends when you close a browser window (which is when the session cookie is deleted).
  • Persistent cookies stay on your computer (or mobile device) for a set amount of time (it varies depending on the cookie). They work every time you visit the website that created that cookie. 

If you’d like to know more, visit allaboutcookies.org – it really does tell you all about cookies.

Why do we use cookies?

We use cookies to carry out three types of task.

  • Essential - Some cookies are essential to making our site work properly. For example, we use them to make sure the information you enter in our contact form does not need to be re-entered if you enter it incorrectly. These are session cookies and are deleted at the end of the browser session. Deleting these cookies could seriously affect your use of the website.
  • Functionality - These cookies allow us to remember your choices and preferences. For instance, if you use access keys (shortcut keyboard commands) the cookie will be used to remember your personal access keys between visits. Because of the tasks they need to be able to do, functionality cookies are persistent cookies. If you prevent these cookies, you will have to repeatedly choose your preferences on a visit by visit basis and some services may not be available to you.
  • Performance - These cookies help us to continually improve our website. 

The cookies collect information on how you use our site, but they do not identify who you are. The information shows us the most popular pages, how many visitors come to our site, where visitors exit the site and other data that we use to improve how our website works in the future.

We use a Google service – Google Analytics – to measure our site’s performance (which makes these third party cookies).

Visit Google’s analytics privacy pages for more information.

Other third party cookies

Our website does not have any advertising from any other organisations. However, we do include links to social media websites like Facebook and YouTube, which may use their own cookies. We do not control these third party cookies, so please visit their websites to check their privacy or cookie policies.

How can I control cookies?

You can control cookies by changing the settings in your browser.

You will usually have a number of options to choose from including: accepting, rejecting or asking to be told when you receive cookies.

If you choose to reject all cookies, you will find that you can’t use all the features of some websites and other websites may not work very well.

You can find detailed instructions on how to change your browser settings on allaboutcookies.org.

Other places to control cookies

Adobe Flash Players (often used to watch videos and play games) serve their own type of cookie. You can’t control these cookies in your browser.

Visit Adobe’s website for more information.

To control third party advertising cookies, visit the consumer advice website of the Internet Advertising Bureau.

User agreement

By using our website, you agree to the use of cookies on our website. If you choose to reject cookies in your browser settings, your experience of using this website may be affected.

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3. Modern slavery statement 2017

Our Business and Organisational Structure

Sovereign is a social business and one of the largest housing associations in the country. We provide over 55,000 homes for around 130,000 people in housing need across the south and south west of England and the Isle of Wight. Sovereign Housing Association is a Registered Provider of Social Housing registered as a society under Cooperative and Community Benefit Societies Act 2014 with the FCA (7448) and with the social housing regulator, the HCA (4837).

Our values

  • Can Do; we are a "Can Do" team of people who deliver on our promises and maximize our impact.
  • Creative; we aim to be smart in the way we do things, to challenge "the norm" and to think and do in new and creative ways.
  • Collaborative; We work together with our residents, and with partner organizations to come up with solutions that are shared and inclusive.
  • Responsible; we are a robust, long term business, rooted in the communities in which we work.

Procurement and Supply Chains

Sovereign has an annual expenditure on goods, works and services of circa £150m. The way we manage our procurement and supply chain is increasingly important to our financial viability, reputation and corporate social responsibility objectives. We recognise that good procurement practice can directly enhance our business performance by securing best value goods and services against favourable commercial and contractual terms.

Sovereign is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our supply chains include sourcing of goods, services and works for the delivery and maintenance of quality homes.

To reflect recent changes in Government guidance on the pre-qualification of suppliers in a tender process, we have updated our tender questionnaires to the Standard Selection Questionnaire, aligned with the UK Public Contract Regulations 2015.

Parts 1 and Part 2 of the Standard Selection Questionnaire list the exclusion grounds that apply to public procurements above EU thresholds, and the statutory guidance states that the selection questions in Part 3 should be adopted across all procurement procedures and embedded as needed into procurement processes. As such Sovereign has adopted the standard Selection Questionnaire structure as a starting point to develop questions in the tender documents for lower value procurements. Part 3 (Selection Questions) includes a section specifically on the Modern Slavery Act 2015 and a declaration to be completed by potential suppliers.

The standardised pre-qualification questionnaire developed by the BSI for construction tendering (PAS91 PQQ) is used in works contracts above the relevant OJEU threshold. The BSI are updating PAS91 to reflect the 2015 Regulations so until the new version is published, as part of Sovereign's due diligence processes into slavery and human trafficking, specific questions will be included in all tenders to confirm bidders' commitments to ensuring that there is no modern slavery or human trafficking in Sovereign's supply chain. This will include a Bidder declaration and potentially the submittal of associated policy / statement depending on the suppliers' annual turnover

Policy Statement on Slavery and Human Trafficking

Sovereign is committed to social and environmental responsibility and has zero tolerance for slavery and human trafficking. We hold ourselves and our supply chain accountable and we fully comply with the provisions of the Modern Slavery Act 2015.

We recognise that modern slavery can exist in a complex supply chain issue, and we work in partnership with our Customers, Suppliers, with National Government Organisations and agencies as well as other organisations to help develop long-term solutions to this issue.

We have rigorous Human Resources procedures in place to ensure that all employees have a legal right to work in the UK, are paid a fair and legal wage, and are under no duress.

Our social purpose and commitment to preventing slavery and human trafficking are also reflected in our Safeguarding and Procurement Policies, to underscore the seriousness of slavery and human trafficking and ensure that staff are aware of and responsive to the issues. We have an open accountable culture and if slavery and safeguarding issues emerge, these are reported through standard management processes, the Safeguarding Reporting process or through our Whistleblowing process.

Sovereign Housing Association and its subsidiaries will not support or deal with any business knowingly involved in slavery or human trafficking. The Board of Directors and all senior management shall take responsibility for implementing this policy statement and its objectives and shall provide adequate resources (training, etc.) and investment to ensure that slavery and human trafficking is not taking place within the organisation and within its supply chains.

In terms of oversight, procurement and compliance are reviewed by the Audit and Risk Committee of the Board regularly. This policy statement will be reviewed by the Board annually and published.


Supplier Adherence to our Values

Sovereign has zero tolerance to slavery and human trafficking and we expect all those in our supply chain and contractors to comply with our values.

Training (L&D)

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our procurement and supply chains within our business, we will aim to provide training to relevant members of staff.

We also provide training to our frontline staff to help them identify potential cases of slavery and human trafficking and how to report them.


Future Action

During this financial year Sovereign Housing intends to further expand the steps it takes to combat modern slavery and human trafficking as follows:

  • Work is in progress to ensure that incumbent suppliers across the organisation, including subsidiaries, have an up to date declaration and Modern Slavery Policy in place dependent on turnover thresholds (Global annual turnover in excess £36m). Part of the Supplier On­Boarding and onward Contract Management process will ensure the assurances in place in respect of modern slavery and human trafficking issues are up to date, declared annually and maintained through the life of the contract.
  • An online training programme about how to identify and report slavery and human trafficking is being developed and will be available for all staff

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes our group's slavery and human trafficking statement for the current financial year ending 31 March 2017.

Date of Board Approval: 18 May 2017