Housing Services - Privacy notice
Croydon’s Housing Services are committed to protecting and respecting your privacy.
We are responsible for helping our residents to apply for housing assistance including Right to Buy applications and accessing ownership schemes, maintain tenancies, support for private tenants and landlords, help for homeowners including leaseholders, and our work to tackle homelessness and empty homes. We carry out day-to-day repairs and maintenance programmes. We also collect and recover income for the Council’s housing stock, some private sector tenancies and for households in temporary accommodation.
This Privacy Notice explains what personal information we collect about you, how and why we use it, who we disclose it to, and how we protect it in compliance with our legal obligations under the General Data Protection Regulation (GDPR) 2018 and the Data Protection Act 2018.
What information we collect
We collect a range of information including some or all of the following:
- names, dates of birth, photographic ID, telephone numbers, email addresses
- you 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
- 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
- recordings of your telephone calls to us, as calls to our contact centre are recorded for training and monitoring purposes so we can ensure we are delivering a good service. These are held in line with our corporate retention policy before being erased.
- your image on our CCTV systems if you visit an estate, office or community facility which is covered by this facility. Any footage is held in line with our corporate retention policy before being erased. This data may be shared with the Police in relation to the prevention or detection of crime or fraud.
- we also collect information when you voluntarily complete customer surveys and provide feedback, including complaints
Generally, the information we hold about you will have been provided by you via our application or enquiry forms or when we communicate with you. We may also hold information provided by third parties where this is relevant to your housing circumstances (e.g. from social workers and health professionals, doctors and occupational therapists).
Why we collect your information
We use your data to:
- make housing decisions and provide housing services to the residents, landlords and tenants of the borough
- carry out specific functions for which we are responsible for, e,g, administration of Right to Buy applications and provision of adaptations
- enable us to comply with our statutory duties e.g.
- preventing tenancy fraud and illegal subletting
- protecting public funds,
- recovering debt
- preventing or detecting crime/fraud
- law enforcement, criminal prosecutions and court proceedings
- regulation and licensing
- produce statistics and reports to research and plan new services. Statistics are used in such a way that individuals or families cannot be identified from them.
- monitor, evaluate and review the quality of our services
- comply with government department research and statistical returns
- deliver national government programmes and initiatives
- account for our decisions and investigate complaints
- assess performance and targets
- inform targeted support and homelessness services to adults, young people and families who are most in need and at risk of harm or abuse
- help you to access the correct services
- some of the services we provide are optional: in that case, we will only process your information and provide the service if you have asked us to do so
Who we share information with
We may share information about you to third parties where permitted or required by law to do so for all lawful purposes as specified in this notice:
- other Croydon Council teams so they can carry out their statutory roles and support our service (e.g. Social Services, Complaints, Business Intelligence, Corporate Finance, Legal Services, IT Services, Quality Assurance)
- third party / service delivery partners who deliver these services on our behalf
- Croydon’s Multi-Agency Safeguarding Hub (MASH)
- Croydon’s multi-agency risk assessment conference (MARAC) that carries out safety planning for high-risk victims of domestic abuse. It brings together the police, independent domestic violence advisers, children’s social services, health, social landlords and other relevant agencies.
- emergency services (e.g treatment centres, hospitals in their function of providing in patient care)
- government departments e.g. Department for Work and Pensions, HM Revenue and Customs, Home Office
- other local housing authorities
- banks or organisations that lend money
- social housing providers
- private rental landlords and/or housing companies
- estate agents and/or property management companies
- credit reference agencies
- police and fraud prevention agencies
- HM Courts and Tribunals System
- solicitors and other advocates
- your lawyer or representative (if you have instructed one)
Staff in each area will only access the personal information that is essential to carry out their work and statutory functions but may share data between the respective teams where this is necessary to provide you with services
All organisations we pass your information to will have an information-sharing agreement with us to ensure they meet the standards of the GDPR and the Data Protection Act 2018, and will be covered by a legal basis allowing them to collect, use and share your personal information.
The lawful basis on which we use this information
The legal bases for processing your personal information are:
- Compliance with our legal obligations
- Tasks carried out in the public interest or in the exercise of official authority
- Contract for the supply of services
Collecting this information
Whilst the majority of information provided to us is mandatory due to compliance with a legal obligation, some of it is provided to us on a voluntary basis. To comply with the GDPR, we will inform you whether you are required by law to provide certain information to us; if you do have a choice to provide information that is not mandatory, your explicit consent will be requested. You do have the right to withdraw your consent if this is applicable to processing your data. If this is the case, we will let you know.
We will only ask for personal information that is necessary to enable us to deliver our services in compliance with our legal duties under, including but not limited to, relevant health and safety regulations, Housing Acts 1985, 1988, 1996, and 2004, the Homelessness Act 2002, Landlord and Tenant Act 1985, Commonhold and Leasehold Reform Act 2002, Housing and Planning Act 2016, Homelessness Reduction Act 2017, Children Acts 1989 and 2004, Equality Act 2010, Human Rights Act 1998 and any associated regulations, statutory guidance and codes of guidance.
Storing this information
Personal data will not be retained for longer than necessary in relation to the purposes for which they were collected. There is usually a legal reason for keeping your personal information for a set period of time – this ranges from months for some records to decades for more sensitive records.
For example, if you live in one of our properties, or have become a leaseholder or freeholder, we will hold information about you for the duration of your tenancy. If you move and are no longer a resident within the borough, we will usually keep records about you for up to 6 years. Digital records will remain on digital files as property history for the duration that we maintain an interest in a property.
If you would like to know more about how we store your data, please contact us on 020 8726 6000.
Providing us with accurate information
It is very important that you provide us with accurate information to enable us to process your application more quickly. If any of your details have changed, or change in the future, please inform us as soon as possible so that we can update your records.
If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information.
Requesting access to your personal data
Under GDPR and the Data Protection Act 2018, you have the right to request access to information that we hold about you. To make a request for your personal information, contact the Council’s Information Management Team at SAR@croydon.gov.uk.
The GDPR and Data Protection Act 2018 give you a number of rights to control what personal information is used by us and how it is used by us. Information about your individual data rights is listed in the Council’s Privacy Notice.
If you have any questions or concerns about the way we collect, store or use your personal information, please contact in the first instance on 020 8726 6000.
For advice about data protection issues, you can contact the Information Commissioner’s Office (ICO) at www.ico.org.uk .
We reserve the right to amend this Privacy Notice at any time and will keep it under review. If we do make any changes, we will post the current version to our website at this address.
Last updated: May 2018