Privacy notice and data protection

What type of information is collected about you?

• contact details; including name, address, email address, telephone number
• date of birth
• proof of identity
• family composition
• address/es of schools attended by children
• national identifiers such as; NHS number and NI numbers
• information about your family
• lifestyle, social and personal circumstances
• the services you receive
• financial details for purposes of making a decision on your housing application
• employment details
• housing information relating your Council tenancy
• visual images, personal appearance and behaviour
• business activities 

We may also collect sensitive personal data that may include:

• physical or mental health details
• racial or ethnic origin
• gender and sexual orientation
• offences (including alleged offences)
• religious or other beliefs of a similar nature
• incidents of domestic abuse
• criminal proceedings, outcomes and sentences 

We need your information for the following services and functions

Your information will be used to assess your housing needs under the Housing Act 1996 as amended.

The services we provide are:

• housing advice
• homelessness prevention
• homelessness assessment
• temporary accommodation
• housing register and housing allocation
• securing private sector accommodation
• referral to the housing support services 

We will also use your information for our wider functions which are:

• the prevention and detection of housing fraud and any other crime
• to provide accommodation in the private sector
• to access housing related support where it is requested by you 

Who your information may be shared with

We may share some of your information, for example your name and address, family composition internally with other departments in the council and outsourced services if this:

• helps you to access services more easily
• promotes the more efficient and cost effective delivery of services
• helps prevent homelessness or secure alternative suitable accommodation 

We may also share your data with individuals, Government departments, statutory and non-statutory services that may hold relevant information that will assist in the assessment of your housing needs. These bodies include, but are not limited to: 

• Ministry of Housing, Communities and Local Government (MHCLG) dataprotection@communities.gsi.gov.uk (Personal data shared with MHCLG will only be used for research purposes. Any information shared will not affect the services or benefits that you receive now or in future or used to identify fraud.)
• private landlords or letting agencies in order to assess your housing application, prevent homelessness or secure that alternative accommodation is available for you.
• credit reference agencies
• Department of Works and Pensions
• Inland Revenue
• police
• medical practitioners
• employers
• other council departments, including their agents 

Low-Income Family Tracker Dashboard (LIFT)

As part of its response to the current cost of living crisis the Council has engaged with an external organisation, Policy in Practice, to utilise what is known as the Low-Income Family Tracker Dashboard (LIFT).

The dashboard brings together indicators of poverty from data supplied by the Council to highlight those residents or households at risk of falling into crisis. It specifically identifies households affected by multiple welfare reforms and allows staff to identify residents and families who would benefit financially from targeted proactive engagement, rather than just reacting to people who contact the Council.

The dashboard uses information from the Council’s administrative datasets covering Housing Benefit and Council Tax Support recipients, Housing data in regard to Council tenants, Universal Credit data which the Council holds as data controller and Free School Meals data. These datasets are controlled by the Council. Policy in Practice acts as a data processor working directly with these datasets.

Given the volume of personal information involved a Data Protection Impact Assessment has been undertaken to assess the level of any risk to data subjects and to identify ways of mitigating any such risks. The work being undertaken by Policy in Practice is governed by a formal Data Processing Agreement put in place by the Council.

The lawful basis for the intended processing is set out in UK GDPR Article 6 (e) Public task: as it is necessary for the Council to process the data to enable it to carry out its statutory duties in respect of Housing Benefit and Council tax administration in support of the Council’s official functions and statutory obligations.

No data will be processed outside of the UK and there are no automated decisions or 'profiling'.

The legal basis for processing your information

We have legal authority to process your information; your right to be forgotten does not apply to our functions and services. 

We have legal authority to process your personal information for the provision of our service, your consent therefore is not required to process your information.

Where the service is optional, we will not process your information until you have consented to receive the service. Once we have your consent for the service, your information will be processed under our legal authority to provide the service. 

How long will we keep your information?

We will retain your information for the period in which your information is being used for service provision or in line with the timescales relate directly to the legislation related to housing and homelessness. 

We will need to retain certain documents for the purposes of our statutory duties, reporting, and in case of possible future legal claims by and against the Royal Borough of Kingston. Periods of retention need to satisfy the periods set down in the Limitation Act 1980 after which proceedings are time-barred – generally between three and twelve years, depending the on the type of claim, We have legal authority to process your information; your right to be forgotten does not apply to our functions and services.