Purpose for processing your information
This privacy notice explains the how the Council uses the information it collects to perform its duties as a landlord. The notice also explains the purpose for processing this information, categories of personal information and who we share it with. This is in addition to the general functions described in the service fair processing notice, which is being developed and will be published shortly.
From the 1 March 2018, the Royal Borough of Kensington and Chelsea assumed direct responsibility for the delivery of housing services. The services provided are wide ranging. The core service areas are:
- housing management including that for specialist groups (e.g. sheltered)
- repairs and major works
- tenancy management and enforcement
- leaseholder services
- communal services including estate management and community engagement
- associated support services including payments and contract management.
In order to provide a quality housing management service, the Council must collect, hold and process a considerable amount of information, including personal information relating to tenancies and general information relating to service delivery and use. It does this to provide services in the most effective and efficient way that it can.
We collect the following information
Personal data collected includes household member defined characteristics, working status and related personal financial circumstances, training requirements, service needs and preferences, evidence of identification (e.g. national insurance number and passport photo), rehousing needs and preferences, address information, payments made, support provided, and personal data relating to case complaints, antisocial behaviour enquiries and wider support provision.
We may also collect and process special categories of personal information that may include:
- racial or ethnic origin
- interest in community engagement activities specific to a particular group (e.g. ethnicity)
- religious or philosophical beliefs
- data concerning health or disability
- data concerning a person’s sex life or sexual orientation.
Your personal information is only used for a specified purpose(s) but if we intend to use it for any other new purposes we will normally ask you first. For instance, in some cases, the Council may wish to use your information for another purpose such as improving and developing services, or to prevent or detect fraud. In any event our processing will always have a demonstrable lawful basis. Where practicable and reasonable we will always seek to inform you of any significant proposed changes to how we process or intend to process your personal data, in order to ensure full transparency over how we handle your information.
How we collect your information
In order to fulfil our duties as a landlord, it is important that we have access to your personal data, as it helps us to deal with your queries and provide services. We collect information in a variety of ways, including:
- when residents are applying for a home or service
- when signing a tenancy or rental agreement
- routine and ad-hoc contact with residents living in or owning homes
- recording calls to and from us
- when a tenancy is terminated or ended
- when delivering routine services (e.g. complaints or repairs)
- when providing welfare benefits advice
- when engaging with residents through our community outreach team.
Legal basis for using and sharing your personal data
Although access to your data is restricted, there are occasions when we need to share it with others including other Council departments, services and elected members, partner organisations, third party contractors, Government bodies, the police, health and social care agencies. We will only share information in line with our public task and public duty official functions, and undertake to only share the minimum required to fulfil a statutory or legitimate interest. Below are some examples of why and when data can be legitimately shared:
- where we have a legitimate basis to do so, for example in general performance of a contract or service (for example, estate cleaning)
- with regard to service improvement
- when we are legally obliged to, for example debt collection or in connection with legal proceedings
- for the detection and prevention of fraud
- in the event of an emergency or risk of serious harm or threat to life, when the emergency services and other local authorities may need it to assist.
In these instances, we would share your information with the following parties:
- other Council departments and services (for example, Adult Social Care)
- elected Members
- third-party contractors
- Government bodies
- the police
- health and social care organisations.
How long do we keep your information?
We will only keep your information for as long as is required by law and to provide you with the necessary services in line with our stated retention policy.
We may also anonymise personal data, to allow the Council to effectively target and plan the provision of services. At this point the data would cease to be personal data.
Your rights and access to your information
You have the right to request a copy of the information that we hold about you.
The new GDPR and Data Protection Act 2018 also gives you additional rights that refer to how the Council holds and uses your information.
Consequently, under certain and specified circumstances you have the right to:
- withdraw your consent to the processing of your data, the right to object, remedy and restrict further processing of your data
- request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it
- request your data to be rectified if it is inaccurate or incomplete
- challenge any automated decision-making including profiling housing services undertake that significantly impact on the nature and quality of the service you receive.
We will consider any objections made, correct errors and inaccuracies and ensure that data is stored in line with the retention policy.
Information about how to submit a Subject Access Request
Please visit our data protection pages for further details on how the Council complies with the new GDPR and Data Protection Act 2018. Contact details for the Council’s Data Protection Officer can also be found here.
If you have any concerns
If you would like to know more about the information we hold about you and how we use it, please email firstname.lastname@example.org
You have a right to complain to us if you think we have not complied with our obligation for handling your personal information; please visit the Comments, complaints and feedback page.
If you are not satisfied with the Council’s response you have a right to complain to the Information Commissioner’s Office (ICO). You can report a concern via the ICO website.
Changes in your circumstances
You must notify us immediately if there are any changes in your circumstances and personal details so we can maintain an accurate and up to date record of your information.