Purposes of processing your personal data
We need to process personal information about council tenants in order to collect or recover rents.
Categories of personal data and lawful basis
In the course of this processing, we may hold some or all of the following information about tenants:
- contact details
- age and gender
- tenancy details
- behaviour notes
- financial details
- criminal convictions.
Under data protection legislation, processing of this information is allowed because it forms part of the performance of a contract.
Categories of sensitive personal data and lawful basis
In the course of this processing, we may hold some or all of the following sensitive information about tenants:
Under data protection legislation, processing of this information is allowed because it is necessary for the establishment, exercise or defence of legal claims.
Who we share your personal data with
The Council shares information with Credit Reference Agencies (CRA). They provide the Council with information about, for example, where people may have moved to.
Most of the information held by the CRA relates to how you have maintained your credit and service/utility accounts. It also includes details of your previous addresses and information from public sources such as the electoral roll, public records including county court judgments, and bankruptcy and insolvency data.
The information held by the CRA is also used to verify the identity, age and residency of individuals, to identify and track fraud, to combat money laundering and to help recover payment of debts. Government bodies may also access this credit data to check that individuals are entitled to certain benefits and to recover unpaid taxes and similar debts.
Credit reference agencies are licensed by the Financial Conduct Authority.
We will also share your data with Debt Collection Companies to assist in the collection of any outstanding debts that you may owe to the Council. All the Debt Collection companies that we share data with comply with all applicable law covering debt collection and Data Protection.
With consent, we will pass direct debit mandates to our bank to allow tenants to pay their rent by direct debit.
We will also pass tenant contact details to third parties to provide payment cards (for Paypoint terminals) and to send out billing letters. We have contracts in place with these service providers to ensure your data is kept secure. We will sometimes provide information about your tenancy to other housing organisations or landlords if a reference is requested.
In some cases, we may need to pass tenants information to a government department, for example the Department of Work and Pensions.
At times we might use or share your information without your permission with Citizens Advice. If we do, we’ll always make sure there’s a legal basis for it which will ensure you have access to free impartial advice relating to Housing Matters.
We will process information in a legitimate and lawful basis to facilitate and provide our services to tenants. In doing so we may use Adobe Sign, an electronic system, to validate and ensure agreements are legally binding through an e-signature solution.
This requires some information to be collected and stored with our third party cloud-hosted supplier in a safe and secure manner.