Housing Privacy Statement

Purposes of processing your personal data

We need to process personal information about council tenants in order to provide Home Contents Insurance.
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
• financial details, including value of home contents and bank details for Direct Debits
• criminal convictions
• history of previous claims for the last 5 years
  occupation
• third party details ( for residents that have carers)

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:

• health data for vulnerable adults

Under data protection legislation, processing of this information is allowed because it is necessary to provide a financial product ( Home Contents Insurance Policy).

Who we share your personal data with

The Council shares information with the:

• Insurance company, in order that they can provide a policy of home contents insurance
• The Loss Adjuster, in order that they can visit tenants in the event of a claim and assess that claim
• The Insurance Broker for the purpose of evaluating and providing competitive policies

The information is shared by the Council with these organisations ( stated above) for the sole purpose of providing and Insurance service. The data is shared through secure portals and contracts are in place to ensure that the information is not passed to third parties.

The Home Contents Insurance policy is a financial product and is regulated by Financial Conduct Authority. The product is also authorised and regulated by the Prudential Regulatory Authority.

We will discuss information you have provided ( such as any previous claims and convictions) directly with the Insurance company to assess if a Home Contents policy can be awarded. This information will be shared and stored securely and will not be shared with any other party.

We will discuss the details of any new claims with the Insurer / broker and Loss adjuster in order to process your claim.

We will provide statistical and detailed information on all policies held by the Council to the Data Controller ( Insurance company) periodically in order to maintain the Home Contents service. This can be the balance on insurance accounts, so the Loss Adjuster can verify that accounts balances are up to date. This must be verified before any claims are processed.

With consent, we will pass direct debit mandates to our bank to allow tenants to pay their insurance by direct debit and process instructions to cancel mandates from the bank.

We will also pass tenant contact details to third parties to provide payment cards (for Paypoint, Post Office and Payzone terminals). We have contracts in place with these service providers to ensure your data is kept secure.

We collect, hold and process personal information about our customers to allow us to process homeless applications and to discharge homeless duties.

This privacy notice tells you what to expect when the Homelessness Prevention Team processes your personal information, how it is used, shared and secured.

Your privacy is important to us and we are therefore committed to handling your personal data in accordance with the provisions of the Data Protection Act 2018, UK General Data Protection Regulation, and any subsequent changes to data protection legislation.

We collect and use your personal data for several reasons, this depends on how you interact with us.

Some of the reasons are things we must do by law/under our statutory obligations, such as:

• Allow to us to submit data as required to national central public bodies i.e Department for Levelling Up, Housing and Communities.
• Make sure we meet our statutory obligations under the Homelessness Legislation and other relevant legislation including those related to diversity and equalities.
• To safeguarding vulnerable children and adults.
• Where relevant Data Protection legislation allows us to process data (Data Protection Act 2018) (UK General Data Protection Regulation).
• Corporate administration and all activities we are required to carry out as a data controller and public authority.

To progress your homelessness claim we will need to collect your personal or special category data of a more sensitive nature, to deliver our service. No more information will be collected than is required to deliver that service.

Types of personal information we may collect about you may include:

• Personal details (name, date of birth)
• Identification numbers (e.g NHS number, National Insurance Number)
• Family details
• Lifestyle and social circumstances
• Economic / financial details
• Employment and education details
• Housing needs
• Case file information 

Special categories of data (also known as sensitive personal information), that we may hold about you include:

• Physical or mental health details
• Social care needs 
• Racial or ethnic origin 
• Offences (including alleged offences) 
• Religious or other beliefs of a similar nature 
• Criminal proceedings, outcomes and sentences
• Sex life or sexual orientation

Equalities information

We may use some information for statistical reasons about the population of the city and the take up of organisation services by various groups. This is to help comply with our legal obligations and to plan the provision of future services. This analysis will not identify individuals nor will it have impact an individual’s entitlement to organisation services and facilities. This could include:

• Ethnic background
• First language
• Gender
• Sexual orientation
• Age 

Your personal information may be shared with internal departments or with external partners and agencies, including charities involved in delivering services on our behalf which you have consented to using. They will only have access to your information on a need to know basis, and your privacy and the security of the information is assessed when a new sharing partner is identified. Examples are:

• Other local authorities
• Contractors and partner agencies
• Providers of goods and services
• Local and central government
• Ombudsman and regulatory authorities
• Health bodies

We may also provide personal information to third parties. We would usually do so where we have your consent, but there may be cases where it is necessary to do so, to comply with the law or where permitted under Data Protection legislation (Data Protection Act 2018) (UK General Data Protection Regulation).

Examples of third parties who we may share your information include (but are not limited to):

• Health bodies (NHS Trusts, GPs)
• The Police
• Regulatory bodies such as the Department of Work and Pensions
• Care Quality Commission
• Courts, prisons
• Other Local Authorities

Where we need to share sensitive or confidential information such as medical details, we will do so only with your permission or where we are legally required to. We may share information to prevent risk of harm to an individual, for example in the case of safeguarding.

We are required by law to protect our public funds; therefore, we may use any of the information you provide to us for the prevention and detection of fraud or to comply with the law and to help with other legal duties including the collection of taxes, charges and other enforcement duties. As well as conducting our own ‘Data Matching’ we may also share your information with other public bodies. These include (but are not limited to):

• Dudley Metropolitan Borough Council
• The Audit Commission
• Department for Work and Pensions
• Other local authorities
• Her Majesty’s Revenue & Customs (HMRC)
• National and Local fraud initiatives.
• The Police
• Health bodies (NHS Trusts, GPs)

We may also share information with utility companies, credit reference agencies, insurers, service providers or contractors and partner organisations, where the sharing of information is necessary, proportionate and lawful.

We may share your data with third countries or international organisations, only where there is a legal reason to share, you have provided consent for us to share, and where there are appropriate safeguards in place to ensure the level of protection of your data is guaranteed.

Data matching involves comparing computer records held by one body against other computer records held by the same or another body to see how far they match. This is usually personal information. Computerised data matching allows potentially fraudulent claims, transactions, applications, taxes and payments to be identified.

Where a match is found it indicates that there is an inconsistency which requires further investigation. No assumption can be made as to whether there is fraud, error or other explanation until an investigation is carried out. Regardless of the outcome data matching helps to ensure records are up to date and accurate.

We participate in the Cabinet Office's National Fraud Initiative: a data matching exercise to assist in the prevention and detection of fraud. We are required to provide particular sets of data to the Minister for the Cabinet Office for each exercise. The use of data by the Cabinet Office in a data matching exercise is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. Data matching by the Cabinet Office is subject to a Code of Practice.

View further information on the Cabinet Office's legal powers and the reasons why it matches particular information.

How we collect your data and from where

Face to face: 
We will keep a record of your contact in order to assist on the delivery and improvement of the services we provide to you and others. Any such records that include any personal information will be kept securely.

Telephone calls: 
Ordinarily we will inform you if we record or monitor any telephone calls you make to us. This is to increase your security, for our record keeping of the phone call and for training and quality purposes.

Emails:
If you email us we will keep a record of your contact and your email address for our record keeping. We will not include any confidential information about you in any email we send to you unless sent securely or you have agreed to us contacting you with this information. We would also suggest that you keep the amount of confidential information you send to us via email to a minimum.

On paper:
You may complete assessment forms or request forms on paper that you send to us. You may write us letters and send these in on paper.

On systems:
We will log any information you provide to us when making a homeless claim on a computer system to help us to progress your claim

We may add your information to systems where we are required to by laws.

From other sources:
We may receive information about you from other organisations or agencies such as but not limited to:

• Dudley Metropolitan Borough Council
• Providers of goods and services
• Local and central government (e.g. Department of Work and Pensions, HMRC)
• Health bodies (NHS Trusts, GPs)
• The Police
• Other Local Authorities

We will receive information about you either for a legal reason or because you have asked for your information to be shared with us. Information can be provided to us by any of the other formats described in this section. We may add this information to our systems to record and hold it as part of your record with us.

Information which you have provided to us will be stored securely. It will be used for the purposes stated when the information was collected, and not reused for different purposes or sold on to others.

Your data will be placed on an appropriate system, such as Information Management Systems that hold data about you and your homelessness application. These are used to provide or administrate our services. We may cross reference this data between systems to keep your information as accurate and up to date as possible in line with Data Protection best practice.

Everyone working for us has a legal duty to keep information about you confidential and secure, for specific purposes and only for as long as necessary.

Where we share information with other bodies or agencies, we will ensure the confidentiality and security of your data. This will normally be done by having a contract and confidentiality clauses in place. We also carry out data privacy impact assessment each time we start a new project, to help us build in security and privacy to protect your information.

We will keep your information in line with legislation and guidance on records retention periods. We will not keep your information longer than it is needed. We will dispose of paper records or delete any electronic personal information in a secure way.

We do not share your data with private companies, unless they have a contract with us to provide a service on behalf of us. For example, a landlord who has offered you accommodation.

Under the Data Protection Act 2018/ UK General Data Protection Regulation  you have rights of how your personal and special category (known as sensitive) information is used. Please see the Information Commissioners Office guidance.

• You have the right to be informed of how we are processing your data. This Privacy Notice explains this in detail.
• You have the right to ask for incorrect data to be rectified.
• You have right to request the deletion or removal of personal data where there is no reason for its continued processing.
• Where you have signed up to an organisation’s service which relies on your consent alone (i.e the services is not covered by a statutory duty) you have the right to withdraw your consent.
• The right of access to your data. Access to non-personal organisation data

If you have a complaint in relation to a request to see a copy of your records or a freedom of information request, please contact us in the first instance to request an internal review of our response.

If after contacting us you are still not happy, you may wish to contact The Information Commissioner's Office:

Post:
The Information Commissioner's Office
Wycliffe House
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

The Department for Levelling Up, Housing Communities and Communities (formerly known as MHCLG) are conducting a study to try to understand the causes of homelessness

As a consequence of your approach for housing advice and assistance to Dudley Council we are required to provide your information to DHLUC. Any information you provide will not be used to make any decisions about what benefits you get, services you use, now or in future, or used to identify fraud.

Whose data is being collected

DLUHC want to collect data on all people asking for help with homelessness. 

What is involved 

At your assessment you will be asked questions about:

• Your experiences of homelessness
• Your support needs
• Whether you have spent time in local authority care, and your current employment status.

What will happen to the information provided

Your information will only be used for research and will be anonymised so the researchers will not know whose data they have.

Dudley Council will send your information to DLUHC using a secure IT system.

Your personal information (name, date of birth, gender, last known address) will be used to identify data collected as part of your assessment and linked to information held by other government departments:

• Department for Work and Pensions (DWP) – to see what benefits you have received and whether you have been employed
• Ministry of Justice (MOJ) – to see what contact you may have had with the criminal justice system
• Department for Education (DfE) – to see when your child has been in school, how well they are doing at each Key Stage and whether they are a Child in Need. 

Your information will be kept strictly confidential. Your name, date of birth, gender, address and National Insurance number will be kept separately from all the other information in a secure, password-protected document on a computer system. You will be assigned a unique reference number, so that even though a researcher will see all your information, they will not be able to know it is you.

How long will my information be kept for

DWP, DfE and MOJ will only keep your personal information for a month and will not keep records showing you were part of this research. DLUHC will keep your personal information for five years. They will only use your data within the terms of data protection laws, will delete your data securely and only keep it for as long as necessary. They will review dates for keeping personal data in the future and if necessary update these privacy notices. 

To legally share data for this research, Dudley Council and DLUHC will rely on the Digital Economy Act 2017. The collection of personal information by DLUHC for this project is compliant with data protection legislation.

Dudley Council will collect your personal data under the public task basis (in this case to provide housing services) and agree to share this data with DLUHC under the public task basis (in this case to reduce homelessness).

DLUHC will rely on the following reasons for processing personal data and additional special category data below: 

A. Lawful basis for processing personal data under Article 6 UK GDPR

The processing is necessary for this reason:

• Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.

B. Additional condition for processing special category data under Article 9(2) UK GDPR

Special category personal data may be processed if:

(g) processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

C. The DPA 2018 will provide a lawful basis to process criminal offence data (as required by Article 10 UK GDPR). 

What are my rights

You can talk to Dudley Council about whether your data is being used for this project without it affecting your legal rights. You can also see copies of all the data MHCLG hold about you and ask for it to be corrected or deleted.

What if I want more information

If you want more information you can ask a member of staff. You can also contact DLUHC’s Knowledge and Information Team about seeing your data or withdrawing from the research by emailing MHCLG’s Data Protection Officer at dataprotection@communities.gsi.gov.uk

If you are unhappy with the way your personal information is being handled you can contact the independent Information Commissioner

What will happen to the results of this research

The final results of this research will be published on the main government website. You will not be identified in any research report.

Purposes of processing your personal data

The personal data you provide is used to enable the council to process your house condition and public health complaints and undertake informal and formal enforcement, including using videos and photographic evidence provided by the owner/tenant. This includes sharing some of your personal data with other agencies and recording your data on the council secure system. The data is used for investigating breaches of legislation across all tenures of property.

Categories of personal data and lawful basis

We may hold some, or all, of the following information about private renters, household members and landlords and/or other individuals connected with private rented tenancies or properties:

•  your name
•  address
•  nationality
•  date of birth
•  unique identifiers (such as National Insurance Number)
•  signature(s)
•  change of circumstance details
•  medical and welfare details
•  housing needs’ assessment(s)
•  GP/support worker details
•  carer details
•  licences
•  satisfaction surveys
•  other occupants in your home (including children)
•  call recording
•  property ownership
•  tenancies
•  video

Under data protection legislation, processing of this information is allowed because we have a statutory duty to provide a housing enforcement service, and so the management of that service is in the public interest. This duty is created by various pieces of legislation:-

•  our legal obligation(s) under the Caravan Sites and Control of Development Act 1960
•  our legal obligation(s) under the Protection from Eviction Act 1977
•  our legal obligation(s) under the Home Energy Conservation Act 1995
•  our legal obligation(s) under the Housing Grants, Construction and Regeneration Act 1996
•  our legal obligation(s) under the Regulatory Reform (Housing Assistance) (England and Wales) Order 2002
•  our legal obligation(s) under the Licensing and Management of Houses In Multiple Occupation and Other Houses (Miscellaneous Provisions) (England) Regulations 2006
•  our legal obligation(s) under section 85 Local Government Act 2003
•  our legal obligations(s) under the Housing Act 2004
•  our legal obligation(s) under the Housing and Planning Act 2016
•  our legal obligation(s) under the Climate Change Act 2008
•  our legal obligation(s) under the Energy Performance of Buildings (England and Wales) Regulations 2012
•  our legal obligation(s) under the Mobile Homes Act 2013
•  our legal obligations under the Smoke And Carbon Monoxide Alarm (England) Regulations 2015
•  our legal obligation(s) under the Digital Economy Act 2017
•  necessary to protect your or another person’s vital interests
•  necessary for the performance of a task in the public interest or in the exercise of official authority vested in us in accordance with the legislation referred to above and the General Power of Competence (Localism Act 2011 s1) combined with section 111 Local Government Act 1972

We do not sell your personal information to anyone else.

Categories of sensitive personal data and lawful basis

 We may hold some, or all, of the following information about private renters, household members and landlords and/or other individuals connected with private rented tenancies or properties:

•  special category personal data (including physical or disability)
•  criminal convictions and offences (including alleged offences)

This is processed for reasons of substantial public interest under the laws that apply to us (see above) where this helps to meet our broader social obligations such as where it is necessary for us to fulfil our legal obligations and regulatory requirements.

Who we share your personal data with

We are required to share information with the following parties:

•  the police and other services i.e. Fire
•  the Home Office can require us to provide information about immigration status of our private renters.
•  We are required to share data with the Cabinet Office as part of a national data matching exercise to prevent and detect fraud.
•  Benefits and Council Tax
•  private sector landlords
•  lettings agents
•  Ombudsmen
•  courts/tribunals
•  housing associations
•  external service providers
•  National Rogue Landlords Database
•  local authorities
•  Border Force
•  NHS
•  Mortgage providers
•  DFG Agents (disability facilities grants)
•  Utilities
•  Energy Suppliers and service providers (fuel poverty schemes)
•  providers of contracted services for the collective switching scheme referrals
•  elected Councillors and/or Member of Parliament
•  friends and relatives you and your household may have been living with
•  voluntary sector organisations

We will protect your details and store the information in compliance with the Data Protection Law and we will only share your contact details where there is a lawful basis to do so.

We may need to use some information about you to:

• enable you to partake in customer surveys (necessary for our legitimate interests to study how you use our products/services, to develop and improve them)
• help investigate any worries or complaints you have about your services
• check the quality of services
• to help with research and planning of service reviews

Purposes of processing your personal data

If we use your personal information for research and analysis, we will always keep you anonymous, unless you have agreed that your personal information can be used for that research.

We do not sell your personal information to anyone else.

Categories of personal data and lawful basis

We may hold some or all of the following information about tenants, residents, family members, household members, leaseholders, people outside household connected with anti-social behaviour and tenancy breaches, people associated with applications for housing:

• contact details

The information that you provide within our surveys is subject to the provision of the Data Protection Law.  

The information will be held confidentially and will be retained for the purpose of updating our records, monitoring take up of services and/or improving the service that we provide by using the feedback that you have provided.    

Who we share your personal data with

Information supplied provided within the surveys may be subject to us contacting the you for further clarification, and/or sharing comments within Dudley MBC and/or our service providers/contractors for information.

Permission to share customer details against survey answers/comments is asked within Housing customer satisfaction surveys and is adhered to accordingly.

We will protect your details and store the information in compliance with the Data Protection Law and we will only share your contact details where there is a lawful basis to do so, for example; for crime or fraud prevention.

Purposes of processing your personal data

We need to process personal information about council tenants and their property in order to carry out Quality Assurance Auditing across DMBC housing stock.

We need to process information about gas connections in council properties in order to carry out gas safety supply checks across DMBC housing stock.

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:

• Tenant Address details
• Tenant Names
• Contact details
• History of building safety checks carried out
• History of building safety certification

• Meter Asset Status
• Property UPRN
• Address
• Postcode

Under data protection legislation, processing of this information is allowed because we have a statutory duty to meet all legislative and regulatory requirements in relation to Building Safety and Compliance.

Who we share your personal data with

The Council shares information with the:

• Morgan & Lambert (Appointed Auditors), to enable them to carry out independent reviews of building safety works and certification.
• Xoserve the Central Data Service Provider for Britain’s gas suppliers.

The information is shared by the Council with these organisations (stated above) for the sole purpose of independent auditing / gas supply auditing. The data is shared through secure portals and contracts are in place to ensure that the information is not passed to third parties.

This information will be shared and stored securely and will not be shared with any other party.

We use a cloud-based gas certification recording system called Tysoft EasyGas to record and manage gas safety certification records. This may include basic personal information, such as your name and property address, for the purpose of registering and maintaining gas safety certifications in compliance with regulatory requirements. All information recorded is held within the United Kingdom.

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:

• ethnicity
• health data.

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.

Please view the Adobe Sign Privacy Policy

Purposes of processing your personal data

We need to process some personal information from a council tenant in order to complete the Right to Buy process. Data may also be used for the prevention and detection of fraud.

Categories of personal data and lawful basis

In order to process Right to Buy requests, we may need to process the following categories of personal information:

• contact details
• tenancy details
• financial details
• solicitors details
• marital status.

Under data protection legislation, processing of this information is allowed because we have a statutory duty to provide a right to buy service for council tenants.

Categories of sensitive personal data and lawful basis

In order to process Right to Buy requests, we may need to process the following categories of sensitive personal information:

• health information.

Under data protection legislation, processing of this data is allowed because it is for reasons of substantial public interest.

Who we share your personal data with

A Right to Buy valuation is partly based on the amount of time a tenant has spent in social housing, so we may need to contact other housing associations or local authorities to confirm this information.

We will send the final offer to the tenant’s nominated solicitor to further the sale.

We are also required to share this data with the Cabinet Office as part of a national data matching exercise to prevent and detect fraud. Please see our National Fraud Initiative privacy notice, and the Cabinet Office privacy notice, for more details.

Purposes of processing your personal data

Dudley Council is installing a number of smart and connected thermostats that will allow us to better maintain our properties and support the residents who live in them. The council is working with a private company called Switchee Limited to collect and monitor the data from these thermostats and their privacy statement can be found at this link: Switchee Privacy Policy

Categories of personal data and lawful basis

We may need to process some or all of the information listed below:

• Humidity data
• Temperature data
• Whether movement has been detected
• Presence of a mobile phone signal
• When and how the thermostat is adjusted
• Data regarding the construction and estimated energy efficiency of the property

Under data protection legislation, processing of this information is allowed because we have a legitimate interest.

Who we share your personal data with

In order to effectively analyse the performance of our building, relevant data will be shared with Switchee.

Where anomalies are highlighted in either the operation of the thermostat or the performance of the building, we may share data with other council departments; public sector agencies or appointed contractors. This might for example include companies tasked with maintaining gas boilers or the council’s winter warmth team who can provide help and advice about energy efficiency and keeping warm over winter.

Purposes of processing your personal data

We need to collect and process your personal information in order to:

• manage and administer council residential tenancies, properties (or garages)
• enforce breaches of the tenancy agreement (eg. antisocial behaviour, untidy gardens, condition of homes, or non-payment of rent)
• provide housing asset maintenance and repairs services
• provide a statutory and regulatory service ensuring Dudley MBC is compliant across areas of Fire, Legionella, Electricity, Gas, Asbestos, Lifts which can be referred to as FLEGAL
• provide estate management
• facilitate tenant participation
• provide tenancy advice (about rents, transfers, mutual exchanges or general tenancy matters)
• provide services related to tenancies – for example facilitating contents insurance or TV licence renewal
• take action, including legal action, against people engaging in conduct capable of causing housing-related anti-social behaviour or sharing information with services involved in responding to allegations of crime and anti-social behaviour.
• Prevention and detection of fraud

Categories of personal data and lawful basis

We may hold some or all of the following information about tenants, family members, household members, other individuals connected with anti-social behaviour and tenancy breaches, people associated with applications for housing:

• contact details
• age and gender
• tax or benefit details
• information about your housing and social circumstances prior to moving into your council property
• tenancy details (which may include information about your current social circumstances)
• criminal convictions and some alleged offences.

Under data protection legislation, processing of this information is allowed because we have a statutory duty to provide a housing service, and so the management of that service is in the public interest. This duty is created by various pieces of legislation, including the Housing Act 1996. Some processing is also allowed because it is in the performance of a contract, or the individual has asked us to do something before entering into a contract. Processing may also occur because it is in the legitimate interest of the council.

Categories of sensitive personal data and lawful basis

We may hold some or all of the following information about tenants, family members, household members, other individuals connected with anti-social behaviour and tenancy breaches, and people associated with applications for housing:

• health information - for example if a tenant has required accessibility modifications to a property
• immigration status

Under data protection legislation, processing of this information is allowed because it is for reasons of substantial public interest.

Who we share your personal data with

We are required to share information with the following parties:

• the police and other services involved in the prevention, detection and prosecution of crime and disorder and tenancy fraud; this could include information about anti-social behaviour
• the Home Office can require us to provide information about immigration status of our tenants.
• We are required to share data with the Cabinet Office as part of a national data matching exercise to prevent and detect fraud.

As part of the tenancy management service, we may also share information with insurers (if you ask us to arrange contents insurance for you) and third parties like utilities companies and TV licensing. When you move into a new property, we will pass your contact details and date of birth to the utility companies that provide services to your new home.

We also have a legitimate interest to ensure that utility charges (e.g. electricity, gas, water) are directed to those responsible for paying them. As such we will provide forwarding addresses to utility providers, debt collection agencies and debt tracing agents.

The council does work with Energy Angels as a partner in providing utility services (gas/electric) for incoming tenants – this company manage the closedown of any outstanding debt, arrange for gas/electric for us to work during the void period. We may share information with them at times including your name, contact details and address.

Please view the Energy Angels’ Privacy Notice 

Dudley MBC and specific private service delivery organisations carry out statutory and regulatory maintenance or repairs as part of delivering services and maintaining compliance. Systems used by third party organisations are scrutinised and checked so their processing and handling of data meets strict UK General Data Protection Regulation standards, including having robust, secure safety measures that guard against data loss or mis-handling.

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.

Please view the Adobe Sign Privacy Policy

The information provided will be kept in accordance with our retention policy. Details of this are available by contacting information.governance@dudley.gov.uk.

If we are processing your personal information using your consent, you can withdraw your consent at any time. If you want to remove your consent, please contact information.governance@dudley.gov.uk

Your Information Rights are set out in the law. Subject to some legal exceptions, you have the right to:

• Have any inaccuracies corrected;
• Have your personal data erased;
• Place a restriction on our processing of your data;
• Object to processing; and
• To request your data to be ported (data portability)

You also have the right to request a copy of the personal information the council holds about you.

For more information, or If you wish to exercise your information rights, please contact our Data Protection Officer at information.governance@dudley.gov.uk