Privacy notice

Housing Management

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.

It should be read alongside the Council’s Privacy Notice.

If you have any questions about this notice or any concerns about how we process your data, please contact our Data Protection Officer, their contact details have been provided at the end of this privacy notice. The privacy notice will continue to be monitored and updated. You are advised to check this page from time to time for any updates to this notice.

What type of information we have

Generally, the information we hold will have been provided by you so that we can provide you with a service, (on the application or enquiry forms or when we communicate with you), but we may also hold information provided by third parties where this is relevant to your housing circumstances (e.g. from social workers and health professionals, doctors and occupational therapists) as well as information based on our interactions with you.

  • we keep financial records about the amount of money you have paid us, any amounts outstanding and action taken to recover money you owe.
  • we hold names and dates of birth, photographic ID and information about your previous housing circumstances to assess housing applications and help prevent tenancy fraud and illegal subletting.
  • we hold contact details for you so we can communicate with you, and to keep you informed about other services we offer which may be useful to you.
  • we record information about your needs and requirements to ensure our services are accessible; that we take account of any support needs in our dealings with you; and to improve our communications with you.
  • we record information to assist us in delivering housing management services including reports of antisocial behaviour; complaints; change in circumstances.
  • we may hold recordings of your telephone calls to us, as some calls to our contact centre are recorded for training and monitoring purposes so we can ensure we’re delivering a good service. Any recordings will be held in accordance with our corporate retention policy before being erased.
  • we may capture your image on our CCTV systems if you visit an estate, office or community facility which is covered by this facility. Any recordings will be held in accordance with our corporate retention policy before being erased. This data may be shared with the Police in relation to the prevention or detection of crime or fraud.
  • we may carry out market research and customer satisfaction surveys to help us to monitor our performance and to improve our services to our customers.

We will only ask for personal information that is appropriate to enable us to deliver our services, in accordance with the Housing Act 1985, 1988, 1996, and 2004, the Homelessness Act 2002 and the Homelessness Reduction Act 2017. In some cases, you can refuse to provide your details if you deem a request to be inappropriate. However, you should note that this may impact our ability to provide some services to you.

How do we get your information?

The information we hold is only collected from the information you provide us with or is collected during interactions during the management of your tenancy or lease.

The information is collected from:

  • your housing application
  • details of sales when purchasing a property
  • when you sign your tenancy agreement
  • interactions with us during the management of your tenancy or lease.

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 Council has to have a lawful reason to process your information. As such the Council will process your personal data for these purposes as follows:

  • 6(1)(c) Processing is necessary for compliance with a legal obligation to which the controller is subject

Section 159 of the Housing Act 1996|Section 160ZA of the Housing Act 1996|Section 166 of the Housing Act 1996|Section 169 of the Housing Act 1996|Section 170 of the Housing Act 1996|Allocation of Housing (Qualification Criteria for Right 2016 to Move) (England) Regulations 2015/967

  • 6(1)(e) 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 for example, the provision of housing to those in need.

Lawful basis under Article 9 UK GDPR

If the information you provide us contains special category data, such as health, religious or ethnic information the legal bases we rely on to process is:

  • 9(2)(b) Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement.
  • 9(2)(g) Processing is necessary for reasons of substantial public interest on the basis of Union or Member State law which is proportionate to the aim pursued and which contains appropriate safeguards, as supplemented by DPA 2018 section 10(3) & Schedule 1, Part 2, paras 6(1) and (2)(a)  - processed for reasons of substantial public interest under the laws that apply to us.

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

Sharing information with third parties could help us to deal with your claim more quickly. When sharing information, we will comply with all aspects of the Data Protection Act 2018. Where necessary or required, we may share your personal information as follows:

  • with our contractors, in order to undertake repairs, maintenance, compliance or improvement works
  • with third party service providers, in connection with services performed on our behalf. For example, if we use a research company to carry out a resident satisfaction survey or if we use a mailing house to distribute our newsletters.
  • our relationships with such providers are governed by our contracts with them which include strict data sharing and confidentiality protocols.
  • with landlords, housing associations and trusts, in connection with tenancy references and other enquiries.
  • with community partners in connection with the delivery of co-ordinated local services.
  • with utility companies (and their representatives) and Council Tax Offices, to ensure billing details are correct and to collect payment.
  • with credit reference agencies and debt collection agencies, in connection with some housing applications and in relation to any outstanding charges.
  • with local authorities and government departments, as necessary for administering justice, or for exercising statutory, governmental, or other public functions.
  • with police and other relevant authorities (e.g. Probation Service, Department of Work & Pensions, HM Revenues & Customs) in relation to the prevention or detection of crime and fraud; the apprehension or prosecution of offenders and the assessment or collection of tax or duty.
  • with other statutory organisations, e.g. social services and health authorities, as necessary for exercising statutory functions.
  • disclosure under a court order
  • sharing with the Ministry of Justice for inspection purposes
  • where there is an overriding public interest to prevent abuse or serious harm to others
  • disclosure to a Regulator if we identify a situation of potential misconduct or if the information is requested.

This list is not exhaustive as there are other circumstances where we may also be required to share the information e.g. in order to meet our legal obligations. We will use all information held by us for the purposes of law enforcement, regulation and licensing, criminal prosecutions and court proceedings.

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.

Credit reference agencies

For more information about how the three main credit reference agencies TransUnion, Equifax and Experian, (also called “credit reference agencies” or “CRAs”) each use and share personal data (also called ‘bureau data’) they receive about you and/or your business that is part of or derived from or used in credit activity, please visit the TransUnion website.

National Fraud Initiative

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.

 

How long we keep your information

We will only hold your records during the period of our relationship with you and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us (for example if you live in one of our properties we will hold information about you for the duration of your tenancy). If you move and are no longer a resident, we will usually keep records about you for up to 6 years or where you are a leaseholder who sells, we will keep a record of this sale indefinitely. The Limitations Act 1980 {Section 2} provides timescales for the retention of records i.e. the current year + 6 years.

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 on:

InformationGovernance@hounslow.gov.uk

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.

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