Housing Solutions

The London Borough of Hounslow is committed to protecting and respecting your privacy. Through this privacy notice we have sought to be as transparent as possible and fully explain how your personal data is held and processed.

This privacy notice applies to services provided by Hounslow Housing Solutions team (also known as Housing Advice, Homelessness, Independence and Preventative Services team) and tells you what to expect us to do with your personal information.

If you have any questions about this privacy notice or any concerns about how we process your data, please contact the Hounslow Housing Solutions team:

phone: 020 8583 3942
email: housingadvice@hounslow.gov.uk

The privacy notice will continue to be monitored and updated. You are advised to check this page from time to time.

What type of information we have

When you begin this process, information will be collected by the Hounslow Housing Solutions service in order to assess your housing needs. This is collected via an online request portal, where you can complete your details and submit your request. As part of this online process, there is a Data Sharing Consent requests page, where you will be asked for your consent for us to share your data with agencies and third parties.

Please note that at this online request stage, while we do ask for your data, and your consent to share it, in practice, we will not share any of your data until the full application is submitted by yourself, following an interview with a Housing Officer.

The only exception to this process is if we have a legal obligation to share the information, for example, we are contacted by the police or legal enforcement agencies, as part of legal our obligations. The information we ask for might include personal and sensitive data.

Any data obtained during the online and face to face interview(s) will be held in strictest confidence in accordance with the Data Protection Act 1998 and the General Data Protection Regulation (GDPR), for the purposes of dealing with your housing enquiry, delivering services and for managing quality within the service.

In order to provide assistance or investigate your housing situation it may be necessary to:

contact relevant people or other organisations and share personal and sensitive data with them
refer you to other agencies
cross check the information you have given with other council sections as well as other council and benefit agencies
use the information you have provided for verification by data matching companies. This will include credit reference agencies that will provide us with information for the purpose of verifying your identity, housing circumstances, and address history disclosed, if appropriate, for the purpose of preventing or detecting fraud

All contacts will be made in the strictest confidence and only relevant data will be shared.

In order to assist you with your situation, Hounslow council will have to contact you, by phone or email, or both, using the contact details you have provided.

Information held about you will be accessed and processed by Hounslow Council and would only be passed on to other parties if there is a risk of serious harm, threat of life or a legal duty to do so. This can include the prevention and detection of crime. We may also share information with other public bodies that are responsible for auditing or administering public funds including but not limited to other local authorities, HM Revenue and Customs and the Police. We do not process your information with countries outside of the UK or EU zone.

Your information is also collected to protect against fraud and to ensure the safety of Hounslow Council Staff members (required by the Council’s duties under Housing Act 1996).

In order to administer our services, we collect the following information from you:

names, dates of birth, photographic ID, telephone numbers, email addresses
your and your family’s legal status
proof of identity and national identifiers
who else lives with you along with their details (e.g. partner, children and other adults)
details about your lifestyle, social and personal circumstances (including your household details)
characteristics such as ethnicity and sexuality
information about your previous housing circumstances to assess housing applications
details about your employment status
your financial records (e.g. allowances and benefits, savings and investments, income and capital)
your contact details so we can communicate with you, and keep you informed about other services we offer which may be useful to you
tenancy or contract information (if you are a leaseholder)
details of your landlord and the amount of rent paid and any other information required to process an application under our service
health information to take into account any reasonable requirements to ensure our services are accessible and appropriately targeted
any reports of anti-social behaviour; complaints; change in circumstances
safeguarding information such as Court Orders and professional involvement
equalities information
health data
family and support network information

We will only ask for personal information that is appropriate to enable us to deliver our services. In some cases, you can refuse to provide your details if you deem a request to be inappropriate. However, you should note that this may impact on our ability to provide some services to you.

How do we get your information?

Most of the personal information we process is provided to us directly by you for one of the following reasons:

You may give us your personal data by filling in forms or by corresponding with us by post, phone, email, social media (including WhatsApp)
You may provide personal data when you sign up to enquire about council provided service, request information, complete a survey, give us feedback or make a compliant
We collect personal information to meet and provide our statutory homelessness duties

We also receive personal information indirectly, in the following scenarios:

Revenues and benefits team
Landlords
Solicitors
Social Services
Banks and other financial organisations
Police and probation services
Other local authorities
Support agencies
HM Courts & Tribunal services
Government agencies
London Office of Technology and Innovation

If it is not disproportionate or prejudicial, we’ll contact you to let you know we are processing your personal information.

Our lawful basis for processing your information

We process your information to comply with our obligations, primarily under the Housing Act 1996, and 2004, the Homelessness Act 2002, the Localism Act 2011 and the Homelessness Reduction Act 2017 to which we are subject.

The lawful basis we rely on for processing this information under the General Data Protection Regulation is

Necessary to perform public tasks – Article 6-1(e)

Consent – Article 6-1(a)

You can remove your consent at any time by contacting the Housing Solutions team: housingadvice@hounslow.gov.uk

If you choose not to provide us with your personal data, we will not be able to process or assess your homelessness circumstances or provide you with advice and assistance in relation to your housing options.

If the information you provide us contains special category data, such as health, religious or ethnic information the legal basis we rely on to process is

Explicit consent – Article 9-2(a)

In some circumstances we will need your consent to obtain further information about you, or to share your information with partner agencies. This will enable us to provide you with the most appropriate advice and assistance, or to refer you to another organisation to provide you with further support.

You can remove your consent at any time by contacting the Housing Solutions team: housingadvice@hounslow.gov.uk

If you choose not to provide us with your personal data, we will not be able to process or assess your homelessness circumstances or provide you with advice and assistance in relation to your housing options.

Legal action - processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity – Article 9-2(f)
Carrying out obligations in the field of social protection law and exercising specific rights of the controller or of the data subject in the field of social security and social protection law – Article 9-2(b)
Substantial public interest condition – Article 9-2(g) - the processing is necessary for reasons of substantial public interest, as supplemented by DPA 2018, Section 10(3) and Schedule 1, Part 2, Paragraphs 6(1) and 6(2)(a) and 18.
Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with the UK GDPR Article 89(1) (as supplemented by section 19 of the Data Protection 2018 Act) - Article 9(2)(j)
UKGDPR Article 10 for criminal offence data where applicable and requested for purposes of safeguarding

You can remove your consent at any time by contacting the Housing Solutions team: housingadvice@hounslow.gov.uk

Why we need your information (purposes of processing)

We need your information to determine and fulfil our statutory housing duties. We are statutorily required to assess housing applications. The personal data we collect will be used for the following purposes:

Providing Housing and Homelessness Services to the residents, landlords and tenants of the Borough
Identifying housing needs and managing the Housing Register
Determining whether the Council has a Homelessness Duty and providing emergency accommodation
Sharing Information across local authorities to optimise and improve the delivery and commissioning of rough sleeping and single homelessness service providers
Detecting and preventing fraud and crime
Inform targeted support and homelessness services to adults, young people and families who are most in need and at risk of harm or abuse
Monitor, evaluate and review the quality of our services
Provide advice suitable for the household
Prepare a personal housing plan and keep the housing plan updated
Carry out activities to prevent homelessness and relieve homeless
Ensure accommodation is available for homeless persons and their households

Who your information may be shared with (internally and externally)

We share your information with:

Other services at our Partner Authorities, such as Housing Benefit, for the express purpose of processing your application
Other organisations in accordance with prevailing Data Protection Legislation
Across local authorities to improve the delivery and commissioning of rough sleeping and single homelessness service providers
Government departments
Registered social landlords
Private sector landlords
Support agencies
Other local authorities
Other council services
Police, probation and fraud prevention agencies
Staff in each area will only access the personal information that is essential to carry out their work and statutory function but may share data between the respective teams where this is necessary to provide you with services
Revenues and benefits team
Housing associations
Solicitors
Social Services
Banks and other financial organisations
Support agencies
National Health Service
HMRC
Credit reference agencies
HM Courts & Tribunal services
Government agencies (including Department of Levelling Up, Housing and Communities)
London Office of Technology and Innovation
MRI Jigsaw (our data processors, the Housing Assistance software provider that enables us to deliver this service)

Working with partners to reduce rough sleeping across London

We are taking part in a project with the London Office of Technology and Innovation (LOTI) to better understand the causes for homelessness and rough sleeping, and how local authorities and housing charities can work to reduce homelessness. London borough councils, and housing charities and providers are sharing some client data. This data will be matched to data held by any of the other organisations. Once matched, the data will be anonymised and aggregated to show trends, to identify potential areas for improvement. You will not be identifiable in this aggregate data. Data will shared on a monthly basis so we can look at homelessness journeys. The objective of this project is to make rough sleeping rare, brief and non-recurrent. See: Privacy notice - Strategic insights tool for rough sleeping

There will be times when we are under a legal duty to share information. This includes, but is not limited to:

disclosure under a court order
sharing with the Ministry of Justice for inspection purposes
sharing with the police for the prevention or detection of crime
where there is an overriding public interest or safeguarding duty to prevent abuse or serious harm to others
disclosure to a Regulator if we identify a situation of potential misconduct or if the information is requested

We will strive to ensure that any personal data in our care will be kept safe and that where your information is disclosed to a third party working on our behalf, we will seek to ensure that they have sufficient systems and procedures in place to prevent the loss or damage of personal data.

How long we keep your information

We keep your personal and special category information for six years from the date of last activity on the case.

We will then dispose your information in the most secure manner possible.

Transfers to third countries

All the information you provide us is held within the UK & European Economic Area.

Business intelligence, profiling and analysis

We may analyse your personal information to improve the council’s services for the following purposes:

undertake statutory functions efficiently and effectively
service planning by understanding your needs and your community's needs and to provide the services that you or your community request
understanding what we can do for you and your community and inform you of other relevant services and benefits
help us to build up a picture of how we are performing at delivering services to you and what services the people of Hounslow need
analysis of costs and spend of services we provide so that we can ensure better and efficient use of public funds

The council is committed to using pseudonymised or anonymised information where practical, and in many cases this will be the default position.

Pseudonymisation is a procedure by which the most identifying fields within a data record are replaced by one or more artificial identifiers, or pseudonyms. There can be a single pseudonym for a collection of replaced fields or a pseudonym per replaced field. An example of this is your National Insurance number or Council Tax Reference number.

Anonymisation is the process of removing identifying particulars or details. This means that the data cannot be linked back to identify you.

Data matching and auditing

We are required by law to protect the public funds we administer. We may use the information you provide to us for the prevention and detection of crime. We may also share this information with other bodies that are responsible for auditing or administering public funds including the Department for Work and Pensions, other local authorities, HM Revenue and Customers and the Police.

The council uses data matching as a way of processing large volumes of information. While this can be a useful way of detecting fraud, it also enables us to identify information that is inaccurate or out of date, helping us comply with Data Protection law, while improving service provision.

As part of the council’s fraud prevention and detection activities, the council participates in the National Fraud Initiative (NFI). The data matching exercise is run by the Cabinet Office. More information: Data protection - National Fraud Initiative

Your data protection rights

The rights available to you depend on our reason for processing your information.

More information and how to make a request: Data protection - Your rights

Your right to make a complaint

The council tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.

If you want to make a complaint you can contact us on:

Complaints team
London Borough of Hounslow
Hounslow House
7 Bath Road
TW3 3EB

Data Protection Officer

The Council’s Data Protection Officer can be contacted by email at InformationGovernance@hounslow.gov.uk or at:

Information Governance Team
London Borough of Hounslow
Hounslow House
7 Bath Road
TW3 3EB

Information Commissioner’s Office

The Information Commissioner is the UK's independent body set up to uphold information rights.

If you would like to know more about your rights under the Data Protection law, and what you should expect, visit the Information Commissioner’s website.

If you have any concerns regarding any privacy practices or about exercising your Data Protection rights, you may contact the Information Commissioner’s Office:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Phone: 0303 123 1113 or 01625 545 745

Email: casework@ico.org.uk

A full list of what information we control and process and for what purposes is set out in our notification with the Information Commissioner's Register of Data Controllers. Our registration number is Z5761176. You can view our registration on the Information Commissioner's website.