Housing Services Privacy Notice

Our core data protection obligations and commitments are set out in Bradford Council's primary privacy notice.

This notice provides additional privacy information for those accessing the Council’s Housing Services and describes how we collect, use and share personal information about you and the types of personal information we need to process, including information the law describes as ‘special’ because of its sensitivity.

Personal information we collect and use

Information collected by us

The information we collect will be the minimum we need to deliver our service.

The type of information we collect will depend on why you have got in touch with us. The information will include some or all of the following:

• name, address and contact details
• reason why you have contacted us
• contacts that we have had with you
• details of your current accommodation
• housing needs and any risk factors that need to be taken into account
• financial information
• medical information
• offending history
• characteristics (such as age, ethnicity and language)
• details of your GP and other people providing professional support
• information about people who hold a licence to operate a House in Multiple Occupation (HMO)

This information is used by officers within the three Housing Services;

• Housing Operations
• Housing Development
• Housing Access

How we use your personal information

We collect your personal information for the following purposes:

Housing Operations

• Improve and enforce standards in the rented housing sector
• Identify where landlords or lettings agents may not be complying with their legal requirements and collect evidence of this
• License Houses in Multiple Occupation (HMOs) and meet the statutory requirement to make the HMO register available to anyone requesting this
• Provide adaptations to assist disabled people and their carers
• Bring empty properties back in to use
• Assist owner occupiers with essential repairs and improvements
• Arrange payments to contractors (including some sole traders) for works carried out

Housing Development

• Develop and provide affordable housing schemes
• Manage the properties that the Council owns, we do not manage these directly but have a contract for their management with Incommunities. Incommunities also manages the information about these tenancies on our behalf

Housing Access

• Help local residents find and maintain secure accommodation
• Process applications for the housing register and award banding
• Assess whether the Council has a duty to rehouse people who are homeless or threatened with homelessness
• Help people access appropriate housing related support
• Meet general housing needs through the rented housing sector

We also use this information to monitor our own performance, meet our duties under equality legislation and to inform our future service planning.

How long your personal data will be kept

We will hold your personal information in line with Bradford Council’s retention schedule. At its expiry date the information will be reviewed, and only retained where there is an ongoing requirement to retain for a statutory or legal purpose. Following this your personal information will be securely destroyed.

Reasons we can collect and use your personal information

Housing Services process personal data under the following categories of lawfulness in the UK General Data Protection Regulation:

6(1)(c) Processing is necessary for compliance with a legal obligation to which the controller is subject

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

6(1)(f) Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

9(2)(b) Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement

9(2)(g) Processing is necessary for reasons of substantial public interest on the basis of Union or Member State law which is proportionate to the aim pursued and which contains appropriate safeguards

The tasks that we carry out in exercise of official authority are mainly required under the following laws (although other legislation applies)

• Local Government Act 1985
• Housing Acts 1985, 1988, 1996, 2002, 2004
• Environmental Protection Act 1990
• Housing Grants, Construction and Regeneration Act 1996
• Local Government Act 2000
• Localism Act 2011
• Energy Act 2011 and 2013
• Housing and Planning Act 2016
• Homelessness Reduction Act 2017

Who we share your personal information with

We may sometimes share the information that we have collected about you where it is necessary, lawful and fair to do so. We may share information with the following for these purposes:

• Other Council services - to help us carry out the functions that we need this information for, or to protect public funds – for instance, to prevent fraud.  We also share an information system with some other Council services – Environmental Protection, Neighbourhood Wardens and Licensing
• Other agencies with statutory enforcement powers relating to the rented housing sector and other linked areas, to support the exercise of these powers (e.g. Health and Safety Executive)
• Registered Providers (RPs) – to secure accommodation for people who have applied for social housing or who are homeless
• Supported accommodation/ floating support providers – to secure housing related support and/or to secure accommodation on the housing register and award banding. This also includes information to help with resettling refuges
• Support agencies that you are working with (such as refuges and domestic abuse workers, Social Services, mental/physical health support providers) - to secure accommodation on the housing register and award banding.
• Hospital homeless discharge team – to co-ordinate discharge dates and secure accommodation for people who are homeless on discharge from hospital
• Private landlords – where the Council's duty to provide accommodation is being discharged by the provision of bed and breakfast accommodation. We may also share your information, with agreement, with landlords participating in the Private Sector Lettings Scheme
• West Yorkshire Fire Service – to access fire safety assistance for vulnerable service users
• Incommunities – to support the housing management of the affordable homes that the council owns
• Government Departments, especially the Home Office – to show how we are performing our statutory functions and provide data for the Government to measure progress at a national level.
• Ministry of Housing, Communities and Local Government (MHCLG) with the Office for National Statistics (ONS) additionally processing information on behalf of the MHCLG – to show how we are performing our statutory functions and provide data for the Government to measure progress at a national level.
• General public – to meet the statutory requirement to make the Houses in Multiple Occupation (HMO) Register available to anyone requesting this

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security incidents and we will notify you and the appropriate regulator of any incident where we are legally required to do so.

When computers make any decisions about you

If you apply for housing through Bradford Homes, automated decision making will be used to calculate your band on the housing register. This decision is taken solely on the basis of automated processing of your personal data and does not involve profiling. In some instances, there may be human intervention following the automated decision making. Please refer to the 'What are your rights' section of this Privacy Notice.

When your data is sent to other countries

We do not send any information we collect about you outside the United Kingdom.

Rights for individuals under UK GDPR

• Find out about the rights for individuals under UK GDPR

What are your rights?

Please contact the Corporate Information Governance Team at dpo@bradford.gov.uk to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.

You can contact our Data Protection Officer at dpo@bradford.gov.uk or write to: Data Protection Officer, City Hall, Centenary Square, Bradford, BD1 1HY.

The UK GDPR also gives you the right to lodge a complaint with the Information Commissioner's Office who are the supervisory authority responsible to regulate and monitor the legislative obligations within the UK and can be contacted on 03031 231113.