Housing Needs: privacy notice

Purpose for processing your information

This privacy notice explains how the council uses the information it collects within the Housing Needs division of the Housing Department. The notice also explains the purpose for processing this information, categories of personal information and when and with whom it may be shared. This is in addition to the general functions described in the service fair processing notice. 

The core service areas are:

• homelessness: statutory assessment and street outreach
• assessing and provision of accommodation (temporary and permanent)
• providing support to those in accommodation, including employment and financial
• enabling provision of new build homes
• securing additional accommodation for those in housing need
• management of relationships with social housing providers 

Using your information

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 could use your information for another purpose such as related to 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.

Personal data collected includes :

• household member defined characteristics
• identification documentation, e.g. passport
• financial details, e.g. payslips and rent statements
• rehousing preferences
• address information
• payments made, support provided and complaints made

 We will also collect information relating to immigration status and recourse to public funding.

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 

Please see the council’s policy on processing special category data.

Collecting your information

In order to provide housing services to our residents, it is important that we have access to your personal data, as it the means by which we  provide services and support vulnerable residents and clients.  

We collect information in a variety of ways, including when: 

• conducting client suitability assessments 
• facilitating a client’s move on from supported housing 
• conducting outreach work with those who are rough sleeping
• supporting residents with welfare benefits, housing, debt and employment
• providing an adaptations service (grants service) 
• providing a transportation and storage service 
• undertaking case work for our traveller community 

Legal basis for using and sharing your personal data

Access to your data is restricted. However, there are occasions when we need to share it with others, including:

• where we have a lawful basis to do so, for example in general performance of a contract or service, under Homelessness Reduction Act 2017, and Nationality, Immigration & Asylum Act 2002
• as part of public task and public duty where appropriate to do so
• 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 (e.g. Adult Social Care) 
• elected members
• third-party contractors, for example Aids and Adaptations
• other local authorities, for example outreach teams
• government bodies, for example MHCLG, London Councils
• bodies involved in the detection and prevention of crime and fraud, for example. DWP, HMRC
• health and social care organisations 

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found at Cifas.

Where there is a need for coordinated support to be provided through the sharing of information an Information Sharing Protocol will be put in place. 

Organisations we may share your data with include:

Where there is a need for coordinated support to be provided through the sharing of information an Information Sharing Protocol will be put in place.

How long 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 subject to any exemptions that may apply. The GDPR and Data Protection Act 2018 also gives you additional rights that refer to how the Council holds and uses your information. 

Under certain circumstances, by law you have the right to:

• request that consent be withdrawn and the right to object, remedy and restrict further processing of your data, however, this may affect service delivery to you
• 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
• have your data transferred or copied should you move to another authority
• not be subject to automated decision-making including profiling

We will consider any objections made, correct errors and inaccuracies and ensure that data is stored in line with the retention policy.  

Further information

• how to submit a Subject Access Request.
• your rights under the GDPR and Data Protection Act 2018 and how the Council complies with the new GDPR and Data Protection Act 2018

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. 

If you have any concerns

Contact us if you would like to know more about the information we hold about you and how we use it:

• email: [email protected]

You have a right to complain to us if you think we have not complied with our obligation for handling your personal information. 

If you are not satisfied with the Council’s response you have a right to complain to the Information Commissioner’s Office (ICO).