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This privacy notice explains how and why we process personal information about our residential tenants. Safeguards are in place to ensure that this data is kept secure and the privacy of individuals is protected.

This notice covers the information that is processed as part of the management of an existing tenancy. These notices should be read in conjunction with the council’s main privacy notice.

Tenancy management

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 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.

Tenancy support

Purposes of processing your personal data

We process personal information is order to provide or organise support for tenants and household members to enable tenancies to be sustained and/or in order to improve health and wellbeing. This is a service that is offered to vulnerable tenants or those at a higher risk of tenancy failure. We may process information about tenants, household members, and associates that are related to the tenants health or welfare needs.

We will not collect or use information in this way without consent. Consent for this this service can be withdrawn at any time using the contact details below.

Categories of personal data and lawful basis

In order to provide this service, we may need to process some or all of the following categories of personal information:

  • contact details
  • tenancy details
  • financial details
  • education history
  • criminal convictions.

Under data protection legislation, processing of this information is allowed because we have the consent of the individual.

Categories of sensitive personal data and lawful basis

In order to provide this service, 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 we have the explicit consent of the individual.

Who we share your personal data with

We may share information with other services and organisations involved in support or safeguarding for tenants and household members. This data sharing will only be done with the consent of the individual, unless there is judged to be a serious risk or safeguarding issue to a child.

Rent collection

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.

Right to Buy

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.

Smart Thermostats

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: https://switchee.co/privacy/

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.

What are your information rights?

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