Last updated: 16 May 2025
1. Introduction
At Lumina Pathways CIC (“we”, “us”, “our”), we are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and share your personal data when you engage with us as a tenant, service user, supporter, employee, contractor, volunteer, or website visitor. It outlines your rights and how we uphold them under UK data protection legislation, including:
- The UK General Data Protection Regulation (UK GDPR)
- The Data Protection Act 2018
- The Human Rights Act 1998
- Any applicable guidance from the Information Commissioner’s Office (ICO)
Lumina Pathways CIC is a Community Interest Company (registration number: 16411905) providing supported housing and tenancy support services to vulnerable adults, including those with learning disabilities, autism, and mental health needs.
2. Who We Are
Data Controller: Lumina Pathways CIC Registered Address: Hamill House 112A-116 Chorley New Road Bolton BL1 4DH
Email: hello@luminapathways.org.uk
ICO Registration Number: ZB905996
As a data controller, we are responsible for ensuring that your personal information is used fairly, lawfully, and securely.
3. The Information We Collect
We may collect and process the following types of personal data:
a. Personal Identifiers
- Full name
- Date of birth
- National Insurance number
- NHS number (where relevant)
- Photo ID and supporting documentation
b. Contact Information
- Home address
- Email address
- Phone numbers
- Emergency contacts
c. Health and Support Information
- Details of diagnoses, disabilities, or mental health needs
- Care and support plans
- Risk assessments
- Safeguarding concerns
- Medication requirements
d. Housing-Related Information
- Tenancy agreements
- Housing benefit information
- Rent and arrears history
- Property inspection records
e. Financial Information
- Bank details (for rent collection or deposit returns)
- Universal Credit or Housing Benefit correspondence
- Direct payment arrangements
f. Employment and Recruitment Data
- CVs and job applications
- DBS certificates and status
- Employment history
- Right to work checks
g. Website and Communication Data
- IP address
- Website usage (via cookies)
- Email correspondence
- Feedback forms and survey responses
We may also receive information about you from third parties such as local authorities, NHS services, previous housing providers, or legal representatives.
4. Lawful Basis for Processing
Under the UK GDPR, we must have a lawful basis for processing your personal data. We rely on one or more of the following:
| Lawful Basis | Explanation |
| Consent | When you have given us clear permission (e.g. signing a form or ticking a box |
| Contract | Where processing is necessary to manage your tenancy or support agreement |
| Legal Obligation | Where we must process information to comply with a law (e.g. health and safety, safeguarding, housing law) |
| Vital Interests | Where your safety or someone else’s is at serious risk |
| Public Task | Where processing is necessary to perform a function in the public interest |
| Legitimate Interests | Where we process data in a fair, necessary way to operate our services and it does not override your rights |
5. How We Use Your Information
We use your data to:
- Provide you with safe, secure, and supportive housing
- Deliver and tailor tenancy sustainment and support services
- Communicate with you about your tenancy, services, and wellbeing
- Administer repairs, complaints, or health and safety inspections
- Fulfil contractual and statutory responsibilities (e.g. safeguarding, rent collection, legal notices)
- Monitor service quality, risks, and outcomes
- Manage staff recruitment, supervision, and compliance
- Submit anonymised data to regulators or funders (e.g. the CIC Regulator, local authorities)
6. Sharing Your Data
We do not sell your data.
We may share your data, where necessary and lawful, with the following:
- Your named care or support provider
- Local authority housing or social care teams
- Health professionals (GP, mental health teams, district nurses)
- Safeguarding partners and emergency services
- External contractors carrying out property repairs or inspections
- The Housing Ombudsman Service or relevant regulatory bodies
- Professional advisers (e.g. solicitors, insurers)
- Our software providers for data storage (with strict agreements in place)
All data sharing is subject to strict contracts or information-sharing protocols to ensure confidentiality, proportionality, and lawful processing.
7. How We Store and Protect Your Information
We use appropriate technical and organisational measures to protect your data, including:
- Password-protected systems
- Encrypted cloud-based storage
- Role-based access controls
- Secure email and document transfer platforms
- Confidentiality clauses in all staff contracts
We retain your information only for as long as necessary, in accordance with our Data Retention Schedule, and destroy it securely when no longer required.
Example retention periods:
- Tenancy records: 6 years after the end of tenancy
- Safeguarding concerns: 7 years or more depending on the case
- Financial records: 6 years (HMRC compliance)
- Recruitment records: 6 months for unsuccessful candidates
8. Your Data Protection Rights
You have the following rights under UK GDPR:
- Right to be informed – this policy provides that information.
- Right of access – you can ask us for a copy of your personal data.
- Right to rectification – you can ask us to correct inaccurate or incomplete data.
- Right to erasure – you can ask us to delete your data, subject to certain conditions.
- Right to restrict processing – you can ask us to limit how we use your data.
- Right to data portability – you can request a copy of your data in a usable format.
- Right to object – you can object to processing in some circumstances.
To exercise your rights, please email: privacy@luminapathways.org.uk. We will respond within one calendar month unless the request is complex.
9. Cookies and Website Use
Our website uses cookies to improve user experience. Cookies are small files saved to your computer used to store preferences, monitor usage, or support site functionality.
You can accept or decline cookies via the website pop-up or browser settings.
We do not use cookies to collect personally identifiable information.
10. Children’s Privacy
Our services are intended for adults and young adults aged 16+ in supported living arrangements. We do not knowingly collect or store children’s personal data without appropriate parental or legal guardian consent.
11. Third Party Links
Our website or materials may contain links to other websites. We are not responsible for the privacy practices of those sites. We encourage users to read their policies.
12. Making a Complaint
If you are unhappy with how we use your data, please contact us first at: hello@luminapathways.org.uk
If unresolved, you can raise your concern with the Information Commissioner’s Office (ICO):
- Website: www.ico.org.uk
- Phone: 0303 123 1113
- Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
13. Policy Review and Contact
We review this Privacy Policy annually and whenever significant changes occur to our processing or to UK data protection law.
Policy Owner: Chief Compliance Officer
Approved by: Chief Executive Officer
Issue Date: 16 May 2025
Review Date: May 2026
Contact Address:
Lumina Pathways CIC
Hamill House 112A-116 Chorley New Road Bolton BL1 4DH
Email: hello@luminapathways.org.uk
Tel: 0161 388 3908
