Housing services for vulnerable people privacy notice
Privacy notice in relation to homelessness and the allocation of housing within the City of Westminster.
Published: 15 January 2021
Last updated: 28 January 2021
Westminster City Council (WCC) has a statutory duty in relation to homelessness and the allocation of housing within the City of Westminster. This statutory duty is set out in the:
- Housing Act 1996 Parts 6 & 7 (as amended)
- Homelessness Act 2002 and
- Homelessness Reduction Act 2017.
This Privacy Notice was prepared to be as comprehensive as possible, but it does not include an exhaustive list of every aspect of our collection and use of personal information. However, we would be happy to provide any further information or explanation about our practices.
The Housing Solutions Service offers advice and assistance to households who contact us about their housing options, homelessness, threatened homelessness or any household wishing to apply to go on Westminster City Council’s housing register. It is also responsible for the allocation of temporary accommodation, private rented accommodation and social housing.
Westminster respects your privacy and is committed to protecting your personal data. This Privacy Notice will inform you about how we look after your personal data when we receive it and tell you about your privacy rights and how the law protects you.
Data Controller – Westminster City Council
In relation to the services offered by the Housing Solutions Service; Westminster City Council is the Data Controller. This means that the council has the overall duty and responsibility under the Data Protection Act 2018 and the General Data Protection Regulation (GDPR) when it comes to your personal data.
The Council is registered as a Data Controller with the Information Commissioner's Office (ICO). Their registration number is Z5674504. You can view it on the ICO Website. This complies with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).
Any concerns or issues you may have about how we look after your personal information can be raised with Westminster City Council. The council has a Data Protection Officer who makes sure we respect your rights and follow the law relating to your personal information. If you have any concerns or questions about how we look after your personal information, please email the Data Protection Officer at [email protected].
The address for Westminster City Council is 64 Victoria Street, London, SW1E 6QP and their phone number is 020 7641 2000.
Your personal information is only used for a specified purpose(s) but if we intend to use it for any other new purposes we will normally ask you first. For instance in some cases, the Council may wish to use your information for another purpose such as related to improving and developing services, or to prevent or detect fraud. In any event our processing will always have a demonstrable lawful basis.
Where practicable and reasonable we will always seek to inform you of any significant proposed changes to how we process or intend to process your personal data, in order to ensure full transparency over how we handle your information.
Personal data we collect
We collect the following personal data:
- Information from the Home Office regarding immigration status
- Information from other council departments e.g. Council Tax and Housing Benefit
- Information from other local authorities
- Information from landlords, private and social
- Information from employers
- Information from financial institutions and third party credit agencies
- Information from Department of Works and Pensions and welfare benefits agencies
- Information from medical and healthcare professionals and agencies
- Information from services delivered or contracted by local authorities to promote the well-being of children (such as children’s, mental health and education services)
- Information from services delivered or contracted by local authorities to promote the well-being of adults (such as adult social care and mental health services.
- Information from the Police, probation and criminal justice services
- Information from partner agencies
Why we collect your personal data
We collect your personal data for a number of reasons –
- to provide you with advice or support or a housing service that you have requested or been referred to us for
- to administer services Westminster City Council or the Housing Solutions Service is providing to you
- to address and resolve complaints about our services
- to carry out research to find out more information about the users of our service
- to comply with applicable laws and requests from statutory agencies
- to comply with any contractual obligations we have
How we collect your personal data
We collect your personal data in a number of ways –
- by any paper application(s) you complete
- by letter
- by telephone or email conversations, or face-to-face interactions
- by digital forms completed via an online portal
What we use your personal data for
If you contact us about your housing options, being homeless or threatened homelessness or the Housing Register, we will use your personal data to:
- assess your situation
- contact you about your situation and the information you have provided
- ask you to provide documents to prove your homelessness, threatened homelessness or housing circumstances
- contact third parties with your personal information to request further personal information about you
- refer you to third parties and/or other agencies that may be able to help you.
Who we may share your data with
Which third parties and/or other agencies we may refer you to will depend on your personal situation, but may include:
- Social services and related agencies
- NHS medical professionals
- Your doctor or associated doctor's surgery staff
- Housing associations
- Other departments within Westminster City Council
- The Home Office This list is not exhaustive, and we may need to use your data to refer you to other third parties and/or other agencies.
Consent and complying with the law
We will always ask your consent to share your personal information unless we have a legal duty or power to provide it without your consent, for example as part of the National Fraud Initiative.
Sometimes third parties may request information on your behalf about your housing application and they must provide your consent and show they are compliant with the Data Protection Act 2018 for us to do this. We have to process your personal data to comply with our legal obligations under the law on housing and homelessness.
Where you have criminal convictions or offences, we can process relevant personal information for the purposes of complying with the law on housing and homelessness. This is because:
- the processing is necessary to meet Westminster City Council’s obligations under housing and homelessness law, and
- our Privacy Notice sets out how we will comply with the data protection principles.
Where we get your personal data from
Information you supply
For the purposes of homelessness applications and approaches for advice on homelessness, housing options and the Housing Register, you are the applicant and are the source of the personal data about you and the members of your household.
Information from other sources
We may also gather personal information about you and your household from other sources. Examples include:
- private sector landlords, housing associations, lettings agents
- mortgage lenders
- health services
- children, family and adult services
- education services
- Department of Work and Pensions
- Westminster City Council departments such as Housing Benefit and Council Tax
- the Police, prisons, probation and youth offending services
- Citizens Advice and voluntary sector organisations.
Who processes your data and who we share it with
Housing Solutions staff involved in the administration and management of the Housing Register, homelessness and housing advice and options will receive and process your data.
We may share information about you relating to your housing options, homelessness, threatened homelessness and your housing application third parties, including:
- The Home Office
- Other council Departments e.g. Council Tax and Housing Benefit
- Other local authorities
- Landlords, private and social
- Financial institutions and third party credit agencies
- The Department of Works and Pensions and welfare benefits agencies
- Medical and healthcare professionals and agencies
- Services delivered or contracted by local authorities to promote the wellbeing of children (such as Children’s Services, mental health services and education services)
- Services delivered or contracted by local authorities to promote the wellbeing of adults (such as Adult Social Care and mental health services.
- Police, probation and criminal justice services
- Partner agencies
- This list is not exhaustive and other third party agencies not included here may need be contacted by us from time to time
Homelessness data for research
We will share data with the Ministry of Housing, Communities & Local Government to evaluate and research homelessness on a national scale.
Transferring your data outside the UK or European Union
We will generally not transfer the personal data you have provided outside of the UK or European Union, unless this is required to investigate your housing application. When necessary this will be done in compliance with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).
How long we keep your personal data
We will keep the personal data you have supplied for six years after your housing situation has been resolved and you have not contacted us again in relation to housing or homelessness.
If you apply to join the housing register and you do not renew your application or contact us about it again, we will keep your personal data for six years after the renewal date was due.
If you are a Westminster City Council tenant, we will keep your personal information while you are a tenant and destroy it six years after your tenancy ends.
Automated decision making
We will not use the personal data you provide to make any automated decisions.
Your rights as a data subject
You have the right to:
- see the personal data Westminster City Council holds about you at any time. This is subject to certain caveats, for example, where third parties are identified.
- ask Westminster City Council to correct any errors in the personal data we hold about you.
- ask Westminster City Council to erase your personal data. This right will not apply where we are processing your personal data because it is necessary to comply with a legal obligation.
- request that Westminster City Council restrict the processing of your personal data. This will only apply in certain situations, for example where:
- its accuracy is contested
- the processing is unlawful and you oppose its proposed erasure by us
- we no longer need to process the personal data, but it is required by you in connection with legal claims.
- object to the processing by Westminster where the processing is necessary for a task carried out in the public interest or in the exercise of official authority vested in the data controller. We will still be able to continue with the processing in certain circumstances, such as if there are compelling grounds for the processing which override your interests.
- Making a subject access request (SAR)
If you wish to access personal information that Westminster may hold about you, either on paper or electronically, you can make a subject access request. You can also ask us to allow others to see your record.
Please note that we can't let you see any parts of your record which contain:
• confidential information about other people
• data we think will cause serious harm to you or someone else's physical or mental wellbeing
• information that may stop us preventing or detecting a crime.
Please write to:
Westminster City Council
64 Victoria Street
Email: [email protected]
Will you use my personal data for a different purpose?
No. If we need to make any changes under the Data Protection Act, we will publish a notice on our website explaining what has changed and update our privacy notice.
Right to complain
If you have any worries or questions about how we manage your personal information, please email the Westminster City Council Data Protection Officer at [email protected]. This is because they are the Controller of your personal information for these services.
If you are dissatisfied with how we process your personal data, you have the right to complain to the Information Commissioner. Their website is found here - https://ico.org.uk. Their address is Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.
The Housing Solutions Service is delivered on behalf of Westminster Council by RMG Ltd in partnership with The Passage Day Centre and Shelter. Residential Management Group RMG House Essex Road Hoddesdon Hertfordshire EN11 0DR