Housing - Asset Management and Investment, M&E and Compliance, Surveying, Leasehold Services Teams
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 Asset Management and Investment, M&E and Compliance, Surveying, Leasehold Services Teams 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 Martin Thomas Head of Asset Management and Leasehold Services. 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.
We use your personal information to:
Ensure that we meet all our legal and statutory duties including, but not limited, to those which apply under the following legislation (including any updates / changes affecting them) and/or contractual agreements:
- Housing Act 2004
- Equality Act 2010
- Localism Act 2010
- Leasehold Reform Act 2014
- Landlord and Tenant Act 1985
- Homelessness Reduction Act 2017
- Local Government Act 1972 (amended 2000)
- Health and Social Care Act 2012
- Commonhold and Leasehold Reform Act 2002
- Crime and Disorder Act 1998
- Traffic Management Act 2004
- Construction Regulations 2015
- Regulatory Reform (Fire Safety) Order 2005
- Gas Safety Regulations 1998
- Prevention of Social Housing Fraud Act 2013
- Tenancy agreement
- Lease agreement, freehold transfer document and shared ownership agreement
- Property and estates maintenance and repair
- Managing footways, footpaths, carriageways, car parks, streetlighting and other facilities on our estates
- Other contracts and agreements setting out the terms and conditions of services provided to you by the Housing Department
We may also use your data:
- to check and, if needed, update your customer record details
- for administrative purposes and customer service
- to contact you to take part in independent research or surveys and ask your opinion about our services to ensure we understand how we can deliver a better service to our residents
- to provide you with information about our activities and services relevant to the area in which you live.
We do not want to be intrusive and will only collect the necessary information needed to effectively and efficiently run our services.
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.
We use automated processes to calculate the rents, service charges and major works bills for the properties we manage, and to initiate contact with tenants and leaseholders who have fallen into arrears on their rent or service charge accounts. We also use information about our residents and properties to inform strategic decision making through the preparation of block, estate or neighbourhood profiles.
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 Asset Management and Investment, M&E and Compliance, Surveying and Leasehold Services Teams 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 services
(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.
Article 6(1)(e) gives the Council a lawful basis for processing where: “processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller”. As the landlord (Tenancy Agreement) and freeholder (Lease Agreement), the Council is responsible for providing you with a safe property – which entails both management and repairs to the structure, exterior of the property and installations in the block / property. Provision (processing) of your data is necessary to enable the Council and its appointed Contractors to undertake these works as required.
Where we have multiple projects with different lawful basis, we will endeavour to explain what our lawful basis is for each project (e.g. via letters sent to individuals affected by projects). This is particularly important where we are relying on consent, as GDPR gives more rights to individuals when relying on consent (e.g. the right to withdraw consent which is not applicable when our lawful basis is public task or legal obligation).
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)
We share limited personal information with our contractors and agencies who are carrying out services on our behalf. Our contractors are required to comply with the law and our own data protection contract clauses to ensure data is managed appropriately and for specified purposes; these include running our out-of-hours telephone service or to complete emergency, responsive or planned property repairs. From time to time we may need to provide or obtain personal information relating to you or members of your household from third parties. However, this will only happen so we can achieve the purposes detailed above and deliver the best possible services to you.
Externally, information may also be shared with the Police as required. 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 Housing Management Services, 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.
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
We take our responsibilities under the GDPR very seriously and will adopt and maintain high standards in respect of handling personal information. Your personal information will only be collected if it is necessary and proportionate to do so. We have a number of policies and procedures in place to ensure your data is kept secure and safe. Methods such as encryption, access controls and staff security training are all designed to ensure that your data are only made available to those who have a right to see them.
We will only hold your information for as long as is required by law to provide you with the necessary services. We follow the local government recommend guidelines around retention periods. See the Council’s Housing Management Services Data Privacy Notice for information on the retention periods for data collected from tenancy files, etc.
At the end of works contracts, our Contractors will delete or return to us all the personal data it has been processing for us; and
delete existing copies of the personal data unless EU or Member State law requires it to be stored. Deletion of personal data will be done in a secure manner. We will ensure the continued protection of personal data after contract end. We appreciate the practical reality that it may not be possible for data in backups or archives to be deleted immediately on termination of a contract. We will ensure that appropriate safeguards are in place, such as the data being put immediately beyond use and then not deleted immediately if the retention period is appropriate and the data is subsequently deleted as soon as possible, e.g. on the Contractor’s next deletion/destruction cycle.
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
Hounslow House, 7 Bath Road, Hounslow, TW3 3EB
Data Protection Officer
The Council’s Data Protection Officer can be contacted on:
Information Governance Team
London Borough of Hounslow
Hounslow House, 7 Bath Road, Hounslow, TW3 3EB
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
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
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.