Housing: privacy notice
Housing Management Service – Privacy Notice
The London Borough of Hounslow is committed to protecting and respecting your privacy. Through this Privacy Notice we have sought to be as transparent as possible and fully explain how your personal data is held and processed.
This privacy notice applies to services provided by the Housing Management Service and tells you what to expect us to do with your personal information.
If you have any questions about this privacy notice or any concerns about how we process your data, please contact Mr Chris Shoubridge, Head of Housing Management. email@example.com. The privacy notice will continue to be monitored and updated. You are advised to check this page from time to time.
What type of information we have
We collect and hold information about named tenants, license holders and leaseholders and their household members.
We collect and hold personal information such as email addresses, contact numbers, date of birth, household composition, ethnic origin, vulnerability and disability, next of kin and any relevant support workers.
How do we get your information?
We collect personal information through the Housing Register application form. Further information is collected at the sign-up stage as part of being offered accommodation. Information is also collected by Housing Officers through the following processes: Resettlement visits at the start of new tenancies, tenancy audits, property inspections and through meetings held at Housing Offices. Further information is collected when residents are asked to complete forms such as applications for Succession or the Right to Buy.
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- Managing your tenancy
- Managing transfer applications
- Managing applications for Succession or Assignment
- Supporting vulnerable residents
We also receive personal information indirectly, in the following scenarios:
- We may receive information from external organisations such as the DWP or support agencies where you have given consent for information to be shared and we have received your signed consent. This could relate to issues with Universal Credit or information supplied by support workers acting on your behalf.
If it is not disproportionate or prejudicial, we’ll contact you to let you know we are processing your personal information. Where we obtain personal information from a source other than from you we must inform you:
- within a reasonable of period of obtaining the personal data and no later than one month;
However, there are certain exemptions to this rule.
Our lawful basis for processing your information
Under the General Data Protection Regulation (GDPR) 2016, the Council as Data Controller is responsible for taking into account the nature, scope, and the purposes in which personal data is processed.
The Housing Management Service must process all personal data lawfully, fairly and in a transparent manner under GDPR Article 6.
We do not always need consent to process personal information. We can use personal information without consent if we have a valid reason, known in the law as ‘lawful basis’.
What counts as a valid reason or 'lawful basis'?
- Legal Obligation
- Vital Interests
- Public Task
- Legitimate interest
When we collect special categories of data (also known as sensitive data) we need to identify both a lawful basis for general processing (Article 6 GDPR) and an additional condition for processing this type of data (Article 9 GDPR).
If the information you provide us contains special category data, such as health, religious or ethnic information the legal basis we rely on to process this information is set out in Article 9 of GDPR. At least one of these must apply whenever we process this type of data:
(a) Explicit consent
(b) Purposes of carrying out the obligation and exercising specific right of the controller or data subject in the field of employment, social security and social protection law
(c) Vital interests
(d) Legitimate activities
(e) Personal data is manifestly made public by the data subject
(f) Establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity
(g) Substantial public interest
(h) Preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and
(i) Public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices
(j) Archiving purposes in the public interest, scientific or historical research or statistical purposes.
Where we are relying on consent you can remove your consent at any time by contacting firstname.lastname@example.org
Why we need your information (purposes of processing)
We collect and hold personal information to enable us to manage our residents homes, to assess applications against criteria set out in our procedures, to contact you and to provide support.
The London Borough of Hounslow is also under a duty to protect the public funds it administers so we may use the information you have provided for the prevention and detection of fraud. We may also share this information with law enforcement agencies and other bodies responsible for auditing or administering public funds.
Who your information may be shared with (internally and externally)
Internally personal data may be shared with other departments in the process of understanding vulnerability or cautionary data, arranging support, processing applications or identifying fraud. This may include Adult and Children’s Social Care, Mental Health Services, repairs, Voids and Lettings, Homelessness, Independence & Preventative Services, IT, Revenues and Benefits, tenancy and corporate fraud.
Externally personal information may be shared with agencies where you have provided consent. This could include the DWP or support agencies. Information may also be shared with the Police as required.
Personal Information may also be held by Housemark. This is an external Housing Organisation that provides the Housing Management Service with a solution for completing resident audits.
We will strive to ensure that any personal data in our care will be kept safe and that where your information is disclosed to a third party working on our behalf, we will seek to ensure that they have sufficient systems and procedures in place to prevent the loss or damage of personal data.
How long we keep your information
The Housing Management Service uses the following retention periods:
|Tenancy File||12 years from termination of tenancy|
|Housing Needs Assessment||12 years from termination of tenancy|
|Evictions||12 years from termination of tenancy|
|Housing Repairs||12 years from termination of tenancy|
|Garage Rental||12 years from termination of tenancy|
|Insurance||12 years from termination of tenancy|
|Tenancy List||12 years from termination of tenancy|
|Welfare Support||12 years from termination of tenancy|
|Rent Arrears||7 years after the case is closed|
|Right to Buy||12 years after sale of the property|
|Ordinary Tenancy||6 years after tenancy has expired|
|Tenancy Under Seal||12 years after tenancy has expired|
|Section 20 Consultations||6 years after work is complete|
We will then dispose your information in the most secure manner possible.
Data matching and auditing
We are required by law to protect the public funds we administer. We may use the information you provide to us for the prevention and detection of crime. We may also share this information with other bodies that are responsible for auditing or administering public funds including the Audit Commission, the Department for Work and Pensions, other local authorities, HM Revenue and Customers and the Police.
The council uses data matching as a way of processing large volumes of information. While this can be a useful way of detecting fraud, it also enables us to identify information that is inaccurate or out of date, helping us comply with Data Protection law, while improving service provision.
In addition to undertaking our own data matching to identify errors and potential frauds, we are required to take part in national data matching exercises undertaken by the Audit Commission. The use of data by the Audit Commission in a data matching exercise is carried out under its powers in Part 2A of the Audit Commission Act 1998. It does not require the consent of the individuals concerned.
Your data protection rights
The rights available to you depend on our reason for processing your information. For further information about your data protection rights and how to make a request, please see ‘Your rights’
Your right to make a complaint
The Council tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.
If you want to make a complaint you can contact us on:
London Borough of Hounslow
7 Bath Road
Data Protection Officer
The Council’s Data Protection Officer can be contacted on:
Information Governance Team
London Borough of Hounslow
7 Bath Road
Information Commissioner’s Office
The Information Commissioner is the UK's independent body set up to uphold information rights.
If you would like to know more about your rights under the Data Protection law, and what you should expect, visit the Information Commissioner’s website: https://ico.org.uk/
If you have any concerns regarding any privacy practices or about exercising your Data Protection rights, you may contact the Information Commissioner’s Office:
Information Commissioner's Office
Telephone: 0303 123 1113 or 01625 545 745
A full list of what information we control and process and for what purposes is set out in our notification with the Information Commissioner's Register of Data Controllers. Our registration number is Z5761176. You can view our registration on the Information Commissioner's website.