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Sensitive categories of personal data

The following information clarifies in detail when and where we collect sensitive categories of personal data. If you would like to know more about our overall approach to collecting, storing and using personal data, please read our privacy notice.

Personal financial information

Applicable to those who have applied for housing and people housed by us

Dot Dot Dot collects personal financial information including actual or predicted earnings, outgoings, debts whether formal or informal, existence of County Court Judgements, source of funds for licence fees and refundable security payment requirements.

We use this information to conduct affordability assessments when an individual applies for housing. It is not in anyone’s interest to house an applicant who cannot afford to pay the necessary fees to be a guardian, or who cannot afford the refundable security payment that we require before someone becomes a property guardian with Dot Dot Dot.

We will usually require documentary evidence (for example, bank statements, savings account statements or other financial documents) to verify the situation of each individual applicant. This information is retained in accordance with our privacy notice and our data and information security arrangements.

The information provided in this category is only used by Dot Dot Dot to make informed decisions about an individual’s ability to pay fees for housing on an ongoing basis.

Proof of identity, nationality and/or immigration status

Applicable to those who have applied for housing and people housed by us

We need to see a copy of an individual’s passport or other suitable identification at the point of application for housing by us. This enables us to meet our legal obligations (Right to Rent and employment law, depending on our relationship with the individual).

We will also create an electronic or paper copy of the documents and retain them in accordance with our data retention policy in order to meet our legal obligations, and to comply with our internal and external audit requirements.

Self-declared information

Self-declared information indicating that an individual has convictions, cautions, custodial sentences that are not ‘protected’ in the meaning of the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 (as amended in 2013).

Applicants for housing are asked to answer a self-declaration question regarding previous criminal records, sentences and cautions. We ask this because a lot of our housing is shared with other occupants, and because of each property guardian’s responsibility for ensuring the building that they occupy is looked after and kept safe. These responsibilities are over and above what would be expected if someone was a tenant, so in our view it is proportionate to ask for relevant information in this category.

We ask applicants if they have any criminal convictions, either spent or unspent, in the same way that an employer would ask of prospective employees. We treat any information provided carefully and sensitively.

We encourage all applicants to answer this question honestly and openly. If an applicant for housing answers this question in the affirmative, more information will be sought by Dot Dot Dot at that point in the application process. This will normally be a telephone discussion.

Decisions are made on a case-by-case basis and an affirmative answer to the initial question will not necessarily preclude that individual from becoming housed. Our decision depends on the individual’s circumstances and our need to balance a number of business needs while also acting fairly and consistently towards the individual.

We do not seek DBS disclosures for guardians as standard because being a property guardian is not – without the presence of other factors (see the ‘Special projects’ section below) – an eligible role for a DBS (discover DBS eligibility guidance on the Gov.uk website). Therefore it would be unlawful for us to obtain a DBS in the majority of circumstances.

Demographic information and sensitive personal information

Collecting data enables us to make better decisions about how to be more inclusive, to identify opportunities to do different and better things, and to be able to analyse and review our progress.
The types of data we are interested in collecting, or may hold about you, include sensitive categories of data, sometimes referred to as “protected characteristics” (a term used in the Equality Act 2010):

  • Age
  • Disability
  • Ethnicity
  • Religion or belief
  • Sexual orientation
  • Gender reassignment

As well as demographic information including:

  • Nationality
  • Socio-economic background

With the exception of age and nationality, individuals being asked to provide personal data will always be presented with the possibility to opt out of doing so. Choosing to opt out will have no effect on the individual’s experience of Dot Dot Dot’s processes.

Information in this category about specific individuals will never be used to make individual decisions (for example, whether to offer housing).

Protecting data

There are a number of general protections, applicable to all categories of personal data. Individuals interacting with Dot Dot Dot benefit from a range of protections, safeguards and rights in terms of how their personal data is collected, stored and processed by Dot Dot Dot. More information can be found in our privacy notice. All of the protections and safeguards in the notice apply to the sensitive categories of personal data.

Special projects and DBS

From time to time, Dot Dot Dot will have housing projects in buildings and sites that share communal areas (corridors, lifts, lounges, kitchens) with other people who are not guardians and may be vulnerable. In these circumstances, we will require a basic DBS check for any potential guardian before they take up occupation in these spaces.

Dot Dot Dot will store a copy of the DBS in order to demonstrate to its clients that contractual and (where appropriate) legal requirements have been met in terms of assisting clients to meet the requirements of their safeguarding and vulnerable adult protection policies, and reduce the risk to their residents.

Statement on restricted lists

We are aware that some industry sectors maintain lists of individuals who engage in certain forms of behaviour or who hold certain characteristics. These lists, sometimes referred to as ‘blocklists’, can be shared or traded between organisations, with the intention of denying certain individuals access or service based solely on their appearance in such a list.

Dot Dot Dot believes such practices are unethical and may indeed be unlawful and does not participate in any such practices.

This information was last updated in January 2022.