Privacy notice

Services administered in the Corporate Services contract

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 Corporate Services Contract 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 the Client Team on 0208 583 4751 or email us at curevenues@hounslow.gov.uk

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 currently collect and process the following information:

• name
• address
• date of birth
• national insurance number
• contact information
• telephone number
• email address.
• Household composition
• Your income details and that of your household
• Savings i.e., details of your bank accounts. Building society accounts etc.

As well as Personal Information where applicable, we may collect and share additional information known as ‘Special Categories of Personal Data’ where appropriate including:

• health assessment
• mental capacity assessments

How do we get your information?

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• When you submit an application form for help with your rent or council tax.
• When you submit an application form for help with your financial affairs
• When you register for council tax
• When you register for business rates
• If you complete an application form for help with a Discretionary Local Crisis Payment or for help with Free School Meals or School Uniform grants.

We also receive personal information indirectly, in the following scenarios:

• We will obtain your personal data directly from the Department for Work and Pensions (DWP) or Her Majesty’s Revenue and Customs (HMRC). This enables us to process your housing benefit and council tax support applications without having to ask you for the documentary evidence we require.  This also applies to records held by HMRC.

If it is not disproportionate or prejudicial, we’ll contact you to let you know we are processing your personal information. ​

Our lawful basis for processing your information?

The lawful basis we rely on for processing this information is

• Legal obligation
  • We collect personal information when processing your applications for help with rent and/or council tax as we are administrating public money, ask you to sign a declaration when you submit an application form.
  • The statute that supports this is the Local Government Finance Act 1992, Housing Benefit Regulations 2006, and the Local Government Finance Act 1992 and associated Regulations.

 

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 is

• Employment, social security, and social protection as the Council works with our most vulnerable residents and details about their health, financial status and mental capacity is processed to assess their needs appropriately

Why we need your information (purposes of processing)?

Our purpose is to comply with employment law, social security and social protection law. We have an obligation to keep your data secure.  To process your benefit applications, we rely on information held by the Department for Works and Pensions.

We need the above information to make correct assessments of any applications you may submit for any of the services listed below (except Payroll and mail). Some assessments can be automated, some new claims received are processed manually by an officer using risk based and self-service assessments. Any data collected for payroll is for the purpose for paying an officer who works for the London Borough of Hounslow and for pension calculations.

We also use the data to do some profiling, analysis and outreach. This can be done for a number of reasons e.g. improve the service we aspire to provide, engage with more residents who may be entitled to support, but aren’t claiming. 

Engagement may commence with a letter, phone call, text or email.

Liberata on behalf of the Council administer the following services in the Corporate Services contract:

1. Revenues and Benefits – which includes council tax, business rates, housing benefit and council tax support/reduction
2. Payroll
3. HR Transactional
4. Accounts Payable
5. Accounts Receivable
6. Financial Assessments
7. Deputyship and Appointeeship
8. Discretionary Housing Payments
9. Discretionary Local Crisis Payments
10. Rent Accounts
11. Incoming and outgoing mail (digital mail)

Example: We need your information to process your application for housing benefit and we also need details of your household composition because depending on the size of your family and your children’s ages determines how much help you will receive. We also use the data for the prevention or detection of fraud/crime and statistics.

 

Consequences if information is not provided

If you fail to provide certain information when requested, we may not be able to process your requests – for example process applications for discounts or other reductions that you might be entitled to.  

Who your information may be shared with (internally and externally)?

To meet our obligations, as well as to provide you with a statutory service where appropriate, we may need to share the information you provide us with our internal departments and other service providers, contractors and/or partner bodies other professionals such as:

• Council’s Housing team
• Council’s Social Services team
• Council’s partner Liberata is our data processors
• Council’s Planning and enforcement team
• Council’s Elections Team
• Local Job Centre (DWP)
• Other internal departments such as Community Solutions on projects for the purpose of early support/intervention for the residents of Hounslow
• Other external organisations on projects for the purpose of maximising income for the residents of Hounslow
• Other external organisations on projects to help distribute supermarket and utility top-up vouchers
• Other external Government departments on projects to issue energy payments to those residents who receive energy from different sources not commonly used.      

Please note: phone calls to our Revenues & Benefits call centre may be recorded for training and quality improvement purposes.

The Council is permitted to share data under The Social Security Information sharing Regulations 2012, Part 3, S5 / S6/S7 where appropriate. 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, we will seek to ensure that the third party has sufficient systems and procedures in place to prevent the loss or damage of personal data.

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 keep information as per retention summary below. We will then dispose your information in the most secure manner possible. A copy of the council’s retention schedule is available on request.

Type of record	Duration
Council Tax	There is no statute of limitations on the collection of Council Tax debts therefore it is necessary to retain information about how liability was ascertained in case of disputes/appeals.
Business Rates	There is no statute of limitations on the collection of Council Tax debts therefore it is necessary to retain information about how liability was ascertained in case of disputes/appeals.
Housing Benefit	7 years from the date the claim is closed
Council Tax Support	7 years from the date the claim is closed
Customer Financial Affairs	7 years  from the date the claim is closed
Financial Assessment	7 years  from the date the claim is closed
Free School Meals (FSM)	7 years from the date the claim is closed
Clothing grants (SUG)	7 years from the date the claim is closed
Accounts Payable	6 years from the date of the last payment. Old, unpaid invoices remain valid for up to 6 years.
Rent Account	6 years
HR Transactional	6 years from termination of employment. For unsuccessful candidates the applications are kept for up to 12 months
Payroll	6 yeas plus current and lifetime for pension data
Supplier set-up	Minimum of 6 years + current financial year.
Accounts Receivable - Sundry debt - Leasehold Debt and True FTA debts	Sundry & FTA 6 years, Leasehold 12years +
Finance - Transactional & Processing	Financial Records 6 years plus current year, 12 years or life of contract for some contractual, banking or HMRC related agreements
Pension Fund	Retention schedule QAP 130
Service & Corporate Finance	Financial Records 6 years plus current year, 12 years or life of contract for some contractual, banking or HMRC related agreements

Transfers to third countries

All the information you provide us is held within UK & European Economic Area

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 Local Audit Framework, the Department for Work and Pensions, other local authorities, HM Revenue and Customers and the Police.

The Local Audit Framework covers:

• the new transitional body, Public Sector Audit Appointments Ltd, will take on the existing audit contracts until they expire, in 2017
• the National Audit Office will set the standards for public audit
• the Financial Reporting Council and professional accountancy bodies will monitor the quality of audit
• the Cabinet Office will assume responsibility for the National Fraud Initiative

 

DWP sometimes needs information about people other than the person who has applied for a benefit or service to work out what that person is entitled to. For example, where a person makes a claim for Universal Credit, we need information about other people who live in the same household to work out how much the person will be paid.

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 Cabinet Office. It does not require the consent of the individuals concerned.

National Fraud Initiative (NFI)

As part of the council's fraud prevention and detection activities, the council participates in the National Fraud Initiative (NFI). The data matching exercise is run by the Cabinet Office.

Data matching involves comparing sets of data, such as the payroll or benefits records of a body, against other records held by the same or another body to see how far they match. The data is usually personal information. The data matching allows potentially fraudulent claims and payments to be identified. Where a match is found it may indicate that there is an inconsistency that 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 processing of data in a data matching exercise is carried out Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under data protection legislation or the GDPR.

All bodies participating in the Cabinet Office’s data matching exercises receive a report of matches that they should investigate, so as to detect instances of fraud, overpayments or underpayments and other errors, to take remedial action and update their records accordingly.

Further information on the National Fraud Initiative and the data sets used.

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:

Complaints Team
London Borough of Hounslow
Hounslow House
7 Bath Road
TW3 3EB

 

Data Protection Officer

The Council’s Data Protection Officer can be contacted via:

Email - InformationGovernance@hounslow.gov.uk

Address

Information Governance Team
London Borough of Hounslow
Hounslow House
7 Bath Road
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

Email: casework@ico.org.uk

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.