Housing Management privacy notice

This privacy notice is to inform you how and why we collect, use and retain your personal data.

The Housing Management team, provide a wide range of services under our statutory duties under the Housing Act 1996 (as amended) and the Localism Act 2011. Our core service areas are:

• housing management including that for specialist groups (community supportive housing )
• repairs and maintenance to homes
• major works to homes
• tenancy management and enforcement
• leaseholder services
• communal services including estate management and community engagement
• housing performance and intelligence
• associated support services including payments and contract management.

The Council respects your privacy and is committed to protecting your personal data. This Privacy Notice will inform you about how we look after your personal data when we receive it and tell you about your privacy rights and how the law protects you.

Data Controller

The Council is registered as a Data Controller with the Information Commissioner's Office (ICO). Our registration number is Z5674504. You can view it on the ICO Website. This complies with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).

If you have any concerns or questions about how we look after your personal information, you can contact our Data Protection Officer as follows:

Data Protection Officer
Bi-Borough Legal Services
The Town Hall
Hornton Street
London 
W8 7NX

Email: [email protected]

Personal data we collect

We collect the following personal data:

• household member protected 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
• arrears and payments made
• support provided
• personal data relating to case complaints, antisocial behaviour enquiries and wider support provision
• images of people on our estates and properties that are covered by CCTV

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 (such as ethnicity)
• religious or philosophical beliefs
• marital status
• gender reassignment
• pregnancy and maternity
• data concerning  vulnerability, support needs health or disability
• data concerning sexual orientation

How we collect your personal data

We collect your personal data in a number of ways. We obtain your personal data from you through –

• any paper application(s) you complete
• by letter
• telephone or email conversations, or face-to-face interactions
• digital forms completed via an online portal

We may also gather personal information about you and your household from other sources. Examples include:

• By referrals from third parties including external agencies and advocates (see section on ‘who we may share your data with’ for a list of agencies)
• when engaging with residents through our community outreach activities
• when conducting satisfaction surveys or services provided, including through third parties
• CCTV - when recording images of people on our housing estates and properties that are covered by cameras

How we use your personal data

To provide an effective, efficient, and quality housing service, the Council must collect, hold, and process a considerable amount of information, including personal information relating to tenancies, leaseholders and general information relating to service delivery and use. This information may also be used for analysis purposes helping us to design and continuously improve our housing services.

For example, we may use and your personal information for the following purposes.

• To undertake statutory functions efficiently and effectively
• To undertake service planning by understanding your housing needs
• To record and flag information in relation to your vulnerability, support needs or health status and ensure that the Council and our contractors can tailor and deliver accessible services to you.
• To record and flag your information where a member of staff has a concern about your safety, health, wellbeing, or behaviour.
• To understand the diverse needs of tenants, including those arising from protected characteristics, language barriers, and additional support needs
• To promote equality and tackle any form of discrimination for anyone with protected characteristics
• To assess whether all tenants have fair access to, and equitable outcomes of, housing and landlord services.
• To understand what we can do for you and inform you of other relevant services and benefits
• To help us to build up a picture of how we are performing at delivering services to you and what housing services the residents of Westminster need
• To analyse costs and spend of housing services we provide so that we can ensure better and efficient use of public funds.
• To perform analysis for improving and developing services
• For the prevention and detection of crime

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. In any event our processing will always have a lawful basis that can be evidenced.

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.

Who we may share your data with

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 also receive data from these 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 (such as estate cleaning)
• as part of public task and public duty, where appropriate to do so
• with regard to service improvement, for example with a third-party research company collecting customer satisfaction information
• when we have or are legally obliged to, for example debt collection or in connection with legal proceedings
• for the detection and prevention of fraud and criminal activity
• 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 (such as adult social care)
• elected members
• third-party contractors, for example repair contractors
• government bodies
• the police and fire brigade
• health and social care organisations

Consent and complying with the law

We will always ask your consent to share your personal information unless we have a legal duty or power to provide it without your consent, for example as part of the National Fraud Initiative.

Sometimes third parties may request information on your behalf about your housing application and they must provide your consent and show they are compliant with the Data Protection Act 2018 for us to do this. We have to process your personal data to comply with our legal obligations under the law.

Transferring your data outside the UK or European Union

We will generally not transfer the personal data you have provided outside of the UK or European Union, unless this is required to investigate your tenancy or housing eligibility. When necessary this will be done in compliance with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).

How long we keep your personal data

We will only retain your personal information for as long as necessary by law and in line with the council’s document retention policy to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  For example, all information relating to management of a tenancy will be kept for the duration of the tenancy plus six years.

We may also anonymise some personal data you provide to us to ensure that you cannot be identified and use this data to allow the council to effectively target and plan the provision of services.

Automated decision making

We will not use the personal data you provide to make any automated decisions.

Your rights as a data subject

You have the right to request a copy of the information that we hold about you.

The new UK Data Protection Act 2018 also gives you additional rights that refer to how the council holds and uses your information.

Consequently, under certain circumstances, by law you have the right to:

• withdraw consent and the right to object and restrict further processing of your data; however, where legally enforceable 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

Making a subject access request (SAR)

If you wish to access personal information that Westminster may hold about you, either on paper or electronically, you can make a subject access request. You can also ask us to allow others to see your record.

Please note that we can't let you see any parts of your record which contain:

• confidential information about other people
• data we think will cause serious harm to you or someone else's physical or mental wellbeing
• information that may stop us preventing or detecting a crime.

Please use our subject access request form or write to:

Data Protection
Westminster City Council
64 Victoria Street
London
SW1E 6QP

Email: [email protected]
 

Will you use my personal data for a different purpose?

No. If we need to make any changes under the Data Protection Act, we will publish a notice on our website explaining what has changed and update our privacy notice.

Personal information collected via online forms

Our policy is to respect and protect the privacy of anyone who visits our website. Where we ask you for personal information via an online form, this information will only be used for the purpose indicated and will be held in a secure manner. It will not be used for any other purpose without your permission and will not be kept for longer than necessary. If you are concerned about providing your personal information online, please contact us and we will arrange alternative means for you to provide this information.

Use of IP addresses and cookies

For information about your privacy and the cookies we use please visit our website to view the council’s fair processing notice.

Changes in your personal 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.

Right to complain

If you have any worries or questions about how we manage your personal information, please email the Westminster City Council Data Protection Officer at [email protected]

If you are dissatisfied with how we process your personal data, you have the right to complain to the Information Commissioner. Their website is found here https://ico.org.uk. Their address is Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.

Changes to our Fair Processing Notice

As the Council creates new or improves existing services, this may generate need to amend the Notice. Any changes with regard to how the Council processes personal data will be posted on this page