The London Borough of Hounslow is committed to protecting and respecting your privacy. Through this Privacy Notice we explain how your personal data is used for the Thames Water social tariff auto enrolment project.
The Council will work with Thames Water to support customers who may be struggling to pay their water bill. If someone qualifies for support to pay their water bill. Thames Water will reduce the amount customers have to pay.
If you have any questions about this privacy notice or any concerns about how we process your information, please contact the Client Team at:
Controller: London Borough of Hounslow, Hounslow House, 7 Bath Road, TW3 3EB.
Email: curevenues@hounslow.gov.uk
This privacy notice will be kept under regular review. You are advised to check this page from time to time for the latest version.
How we handle your personal information
We take the handling of personal information very seriously. All data is processed in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This notice explains how your information is used to identify residents who may be eligible for Thames Water’s social tariff schemes.
Why we collect your personal information
The Council uses existing administrative data from Housing Benefit (HB), Council Tax Support (CTS) and Universal Credit (UC) files, along with analysis provided through the Low-Income Family Tracker (LIFT) system operated by Policy in Practice (PIP), to:
- identify households who may qualify for Thames Water’s reduced tariffs (WaterHelp / WaterSure)
- support residents who may be struggling with water bill costs
- carry out targeted, preventative support rather than waiting for residents to approach the Council
A limited eligibility file is then shared with Thames Water so they can apply the correct social tariff.
How we use your information
Your information is used to:
- analyse income and benefit information to assess potential eligibility
- group households into financial resilience categories (e.g. “at risk”, “in crisis”)
- allow a Council officer to review potential eligibility before any action is taken
- share a minimal data extract with Thames Water
- contact you to provide support or information where appropriate
What information we collect and use
We only use the minimum data necessary for this project.
Information used internally by the Council
- name
- address and postcode
- Housing Benefit / Council Tax Support entitlement indicators
- Universal Credit data supplied by DWP
- financial resilience indicators (e.g. “at risk”, “in crisis”)
- council tax or housing benefit reference numbers
Information shared with Thames Water (minimal extract)
- name
- address and postcode
- eligibility flag (e.g. WaterHelp / WaterSure)
- effective date
We do not share benefit amounts, medical information, vulnerability codes, bank details or any unnecessary data with Thames Water.
Profiling
As part of this project, the Council uses automated analysis (profiling) within the LIFT platform to group households based on financial indicators such as income, benefit entitlement and essential expenditure.
Profiling helps us identify residents who may be eligible for Thames Water’s social tariff.
We do not make decisions based only on automated processing.
A Council officer reviews all information before we take any action or share eligibility information with Thames Water.
Your right to object to profiling
You have the right to object to this profiling. We will consider your objection and will stop the processing unless we can demonstrate compelling lawful grounds to continue (for example, where processing is necessary for our public tasks). You may also request a human review of any outcome informed by this profiling.
Automated decision making
We do not make any decisions based solely on automated processing as part of this project. All decisions involve a Council officer.
How we get your information
We mainly use data the Council already holds for HB/CTS, and UC data supplied by DWP under legal information‑sharing provisions. You do not need to provide any new information for this project.
Our lawful basis for processing your information
We process your personal data under:
Article 6(1)(e) – Public Task
Processing is necessary for the Council to carry out its official functions relating to the administration of benefits, financial hardship support and income maximisation.
Special category data (where applicable)
Where the analysis may reveal information about health, disability or vulnerability, we rely on:
Article 9(2)(g) – substantial public interest
supported by Schedule 1, Paragraph 6 of the Data Protection Act 2018 (statutory and government purposes).
This processing is covered by the Council’s Appropriate Policy Document.
Statutory powers and legal gateways
This project relies on the following powers:
- Digital Economy Act 2017, sections 35–36 (public service delivery: water social tariffs)
- Social security information‑sharing provisions, which allow the Council to use HB/CTS/UC data for benefit take‑up and welfare support
Who your information may be shared with
We share the minimal eligibility information with:
- Thames Water – to apply the social tariff. Thames Water acts as a separate Data Controller for applying the social tariff. You can read Thames Water’s privacy information on their website at
We also work with:
- Policy in Practice (PIP) – who process Council data on our behalf under contract. They do not use your information for their own purposes.
- Liberata – who administer HB/CTS services on behalf of the Council.
- Department for Work and Pensions (DWP) – who supply UC data under legal gateways.
Where data is shared, we ensure contractual and technical safeguards are in place to keep your information secure.
How long we keep your information
For this project:
- LIFT datasets are retained for the duration of the contract plus one year
- SMS or campaign contact records (if used) are retained for 12 months
- Thames Water retains eligibility data only for the period needed to apply the tariff
- HB/CTS/UC data is retained in line with statutory requirements
International transfers
All data for this project is stored and processed within the United Kingdom.
Policy in Practice hosts data on UK based servers.
Your data protection rights
You have rights over your personal data, including the right to:
- access your information
- request correction
- object to profiling
- object to processing in certain circumstances
- request erasure (in limited circumstances)
For full details, see the Council’s “Your Rights” webpage.
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 all 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:
The Council’s Data Protection Officer
The Council’s Data Protection Officer can be contacted on:
Email: InformationGovernance@hounslow.gov.uk
If you remain dissatisfied, you may contact the Information Commissioner’s Office (ICO):
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.
If you have any concerns regarding any privacy practices or about exercising your Data Protection rights, you may contact the 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.
