Healthy Homes pilot

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 the Regeneration and Housing (Healthy Homes), Asset Management and Investment Teams and tells you what to expect us to do with data collected from your address.

Hounslow Council is proactively looking at how we manage condensation, damp and mould across homes in the borough. We are investigating this as part of a pilot.

We have teamed up with an award-winning technology company called Information of Things Solutions Group (IOTSG) which provides monitoring sensors and devices that will help us to get a better understanding of these issues.

We want to use these sensors as part of a pilot project by installing them in properties that are experiencing issues with damp and mould.

The information we gain from this pilot will help to make a difference to our residents’ lives, by ensuring they live in safe and healthy homes. We are committed to finding solutions to condensation, damp, and mould. These sensors will help us to achieve this.

Installing a sensor in your home, as part of this 12-month pilot scheme will give us useful insights into your home’s current performance, alongside any measures we can put in place to make improvements.

It will help us to target and tackle damp and mould problems and assist us in developing future investment programmes (building improvements), by making sure that funds are allocated accordingly, to properties and estates identified from the scheme.

If you have any questions about this privacy notice or any concerns about how we process your data, please contact our Information Governance team at InformationGovernance@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

We will only gather humidity and temperature readings from your property. The humidity and temperature sensor does not record or submit any other information.

No personal information about you or your family will be collected or stored as part of this pilot.

Further information on the pilot and the information we collect will be provided during your appointment, to set up the sensor in your home. We will also provide you with a frequently asked questions sheet, to answer any queries you may have.

We currently collect and process the following information:

Humidity and temperature data, which is linked directly to your address and postcode only
Your name if you are the named tenant
Your address and contact details

How do we get your information?

Most of the property data we process is provided to us directly from your property for one of the following reasons:

you are a participant in the pilot for which a humidity and temperature sensor is installed in your home.
data from your property will be collected when the sensor sniffs the air to monitor temperature and humidity information. Data will be gathered which will alert us to any concerns around humidity and temperature levels in your home.

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

The Regeneration and Housing (Healthy Homes), Asset Management and Investment Teams must process all personal data lawfully, fairly and in a transparent manner under UK GDPR Article 6.

We do not always need consent to process personal information. We can use personal information without consent if we have a valid reason, known in the UK GDPR as ‘lawful basis’.

The lawful basis we rely on for processing this information is.

Public Task - 6(1)(e) Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller for example, the provision of housing to those in need.

Article 6(1)(e) gives the Council a lawful basis for processing where: “processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller”.

As the landlord (Tenancy Agreement) and freeholder (Lease Agreement), the Council is responsible for providing you with a safe property and healthy living conditions within your home – which entails both management and repairs to the structure, exterior of the property and installations in the block / property. Provision (processing) of your data is necessary to enable the Council and its appointed Contractors to undertake these works as required.

Where we have multiple projects with different lawful bases, we will endeavour to explain what our lawful basis is for each project (e.g. via letters sent to individuals affected by projects).

Why we need your information (purposes of processing)

We collect and hold personal information to enable us to manage our residents’ homes, to proactively look at how we manage condensation, damp and mould across homes in the borough. We are investigating this as part of a pilot.

We want to use humidity and temperature sensors as part of a pilot project by installing them in resident properties that are experiencing issues with damp and mould.

Participation in this pilot, will enable us to target and tackle damp and mould problems and assist us in developing future investment programmes (building improvements), by making sure that funds are allocated accordingly, to properties and estates identified from the scheme.

We may also use your personal data to ensure that we meet all our legal and statutory duties including, but not limited to, those which apply under the following legislation (including any updates / changes affecting them) and/or contractual agreements:

Housing Act 2004
Equality Act 2010
Localism Act 2010
Landlord and Tenant Act 1985
Environmental Protection Act (EPA) (1990)
Defective Premises Act (DPA) (1972)
Housing Health and Safety Rating System (HHSRS) for rented homes within the Housing Act 2004
The Social Housing (Regulation) Act 2023
Awaabs Law
Homelessness Reduction Act 2017
Local Government Act 1972 (amended 2000)
Health and Social Care Act 2012
Construction Regulations 2015
Tenancy agreement
Property and estates maintenance and repair
Other contracts and agreements setting out the terms and conditions of services provided to you by the Housing Department.

Personal data may also be used for the purposes of:

Checking and, if needed, update your address record details
Administration and customer service
Providing you with information, advice, signposting and support for the management of condensation, damp and mould
Proactively tackling damp and mould problems
Assisting us in developing future investment programmes (building improvements)

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

We share limited personal information with our contractors and agencies who are carrying out services on our behalf. Our contractors are required to comply with the law and our own data protection contract clauses to ensure data is managed appropriately and for specified purposes; these include running our out-of-hours telephone service or to complete emergency, responsive or planned property repairs.

Externally, data collected from your property relating to humidity and temperature readings, will be shared with a company called Internet of Things Solution Group (IOTSG). We are working with the London Office of Technology and Innovation and a supplier, Internet of Things Solution Group (IOTSG), to participate in a pan-London pilot project using monitoring sensor devices that will help us to get a better understanding of issues around damp and mould.

Internally, personal data may be shared with other departments in the process of understanding vulnerability or cautionary data and arranging support. This may include Housing Management Services, Adult and Children’s Social Care, Mental Health Services, Repairs, Voids and Lettings, Homelessness, Independence & Preventative Services, IT, Revenues and Benefits, Tenancy and Corporate Fraud.

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.

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
disclosure to a Regulator if we identify a situation of potential misconduct or if the information is requested.

How long we keep your information

We take our responsibilities under the UK GDPR very seriously and will adopt and maintain high standards in respect of handling personal information. Your personal information will only be collected if it is necessary and proportionate to do so. We have a number of policies and procedures in place to ensure your data is kept secure and safe. Methods such as encryption, access controls and staff security training are all designed to ensure that your data are only made available to those who have a right to see them.

We will only hold your information for as long as is required by law to provide you with the necessary services. We follow the local government recommend guidelines around retention periods. See the Council’s Housing Management Data Privacy Notice for information on the retention periods for data collected from tenancy files, etc.

We keep humidity and temperature readings from your property for 7 years. We will then dispose your information in the most secure manner possible.

At the end of works contracts, our Contractors will delete or return to us all the personal data it has been processing for us; and delete existing copies of the personal data unless any applicable law requires it to be stored. Deletion of personal data will be in the most secure manner possible. We will ensure the continued protection of personal data after contract end. We appreciate the practical reality that it may not be possible for data in backups or archives to be deleted immediately on termination of a contract with our contractors. We will ensure that appropriate safeguards are in place, such as the data being put immediately beyond use and then not deleted immediately, if the retention period is appropriate and the data is subsequently deleted as soon as possible, e.g. on the Contractor’s next deletion/destruction cycle.

Transfers to third countries

All the information you provide us is held within the UK & European Economic Area. The sensors are also designed and manufactured in the UK.

Your data protection rights

The rights available to you depend on our reason for processing your information. For further information about your data protection rights and how to make a request, please see ‘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 3E

Data Protection Officer

The Council’s Data Protection Officer can be contacted on:

InformationGovernance@hounslow.gov.uk

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: https://ico.org.uk/

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

Telephone: 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.

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