Revenues, Benefits and Customer Services Privacy Notice
What information do we collect
We may collect some or all of the following information about you depending on which of our services you use:
Common to all services
- Name, address, contact details
- Correspondence (emails, letters, supporting documents)
- Conversations (recorded and typed notes of telephone conversations)
- Case notes
- Bank account details if applicable
Blue Badge
- National Insurance Number
- NHS Number
- Medical information to support your application
Council Tax and Business Rates
- Dates of occupancy
- Tenancy agreement and landlord details
- Agent details if applicable
- Business accounts and trading information (Business Rates only)
- Medical information only when required to support specific Council Tax Exemptions and Reductions
Sundry Debts
- Services provided
- Payments made and outstanding
Housing Benefit, Discretionary Housing Payment and Council Tax disregards, discounts and reductions
- Date of birth, gender
- National Insurance Number
- Financial information (income, savings, assets and where necessary, expenditure)
- Benefits you are in receipt of
- Details of others living in your household
- Landlord name, address and contact
- Medical information only when required to support your claim in specific circumstances
Free School Meals
- Child's name, address, date of birth and school
Discretionary Assistance Schemes (Assisted Purchase)
- Date of birth, gender
- National Insurance Number
- Benefits you are in receipt of
- Income
Test & Trace Self-Isolation Payments
- Proxy applicant details (as above where you may nominate someone else to complete this application on your behalf);
- Employer name and address;
- NHS notification number (the unique reference you will be given by NHS Test and Trace Service to self-isolate);
- Your National Insurance Number;
- Proof of self-employment for example recent business bank statement (within the last two months), most recent set of accounts or evidence of self-assessment.
- Name of your child/young person
- Date of birth for the applicant and where relevant child/young person
- Child’s main address
- Details of the child’s education or childcare setting, including contact information.
Equalities data
In some cases we may also ask you to provide ethnic, gender, sexual, age and other characteristic information to comply with equality legislation. Where we do so, it will always be made clear that this is optional and that you do not have to provide it. If you decide to provide such information, it may be used to provide better services and to help us to meet our equality obligations.
Why do we use this information?
We use this information about you to process
- the administration, billing and collection of Council Tax
- the administration, billing and collection of Business Rates including levies for Business Improvement Districts and other schemes as appropriate
- the collection of Sundry Debts owed to the council
- applications and payments for Housing Benefit and Discretionary Housing Payments
- applications for Council Tax Reduction
- entitlement to Free School Meals for your children
- applications for Blue Badge (disabled parking) permits
- applications for statutory and discretionary assistance and grant schemes
Collecting and using your information for these functions is vital to ensuring that the council collects the right amount of money to fund a variety of services such as social care, housing, highways, sports and health, museums, libraries and culture. We also use this information to assist individuals and families by helping them to obtain housing, school meals and mobility assistance where they may otherwise have difficulty.
What authority does Bradford Council have to collect and use this information?
We collect and use this information under powers given to local authorities (councils). Under the UK General Data Protection Regulations, the following categories of lawfulness apply:
Personal data
6(1)(b) Contract: processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract
- Sundry Debts, Discretionary Assistance Schemes
6(1)(c) Legal Obligation: processing is necessary for compliance with a legal obligation
- Payroll (statutory deductions)
- Sharing with government departments and the police
6(1)(e) Public Task: 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
- Council Tax, Council Tax Reduction, Business Rates, Business Improvement Districts, Housing Benefits, Discretionary Housing Benefits, Free School Meals, Blue Badge, Discretionary Assistance Schemes, Covid-19 Business Support Grants, Test & Trace Self-Isolation Payments
Special Category data
9(2)(a) Consent: the data subject has given explicit consent to the processing of those personal data for one or more specified purposes
- Blue Badge
9(2)(b) Social Security: processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement.
- Housing Benefits, Blue Badge
9(2)(i) Public Health: processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare.
- Test & Trace Self-Isolation Payments
Official Vested Authority
The main basis of our official vested authority is as follows, however this list is not exhaustive:
- Local Government Act 1972 and 2000
- Local Government Finance Act 1988, 1992 and 2012
- Social Security Administration Act 1992
- Welfare Reform Act 2007 and 2012
Separately, we have special permission from the Secretary of State for Health and Social Care to use confidential patient information without people’s consent for the purposes of diagnosing, recognising trends, controlling and preventing, and monitoring and managing communicable diseases and other risks to public health.
This is known as a ‘section 251’ approval and includes, for example, using your test results if you test positive for COVID-19 to start the contact-tracing process.
The part of the law that applies here is section 251 of the National Health Service Act 2006 and Regulation 3 of the associated Health Service (Control of Patient Information) Regulations 2002. You can find more information on this via the NHS Test and Trace overarching Privacy Notice.
In the rare circumstance that we do not have a legal or official vested authority to use your information, we will obtain your consent first.
Who are we likely to share this information with?
We may sometimes share the information we have collected about you where it is necessary, lawful and fair to do so. In each case we will only share the minimum amount of information, only when required, for the following reasons:
With other Bradford Council departments to:
- help safeguard vulnerable adults and children
- ensure your children receive Free School Meals where you are entitled
- provide advice and assistance to you
- process applications for statutory and discretionary assistance and grant schemes
- make it easier for you to register to vote in elections
- help carry out their legal duties, including the enforcement of regulations
- protect public money
- produce research and statistics
With other government departments and the police to:
- help process Housing Benefit, Blue Badge and other benefits
- help determine the correct Council Tax Band or Rateable Value of a property
- assist with appeals and disputes
- prevent, detect and prosecute crime
- protect public money
- to share data with the National Fraud Initiative) so that it can be cross referenced to detect and prevent fraud
- to share details of fraudulent and scam activity and attempts with the National Anti-Fraud Network
- produce research and statistics
With other organisations, including other councils (with your consent, or where the law allows us) to:
- provide services to you on the council's behalf
- provide services to the council
- for example, payment processing, document processing and undertaking reviews
- administer Business Improvement Districts
- provide advice and assistance to you including Personal Budgeting Support for Universal Credit
- protect public money
- to collect money owed to the council by engaging Enforcement Agents or sharing information with other councils
- to provide banks with details to recover overpayments made due to fraudulent activity
Landlords
If your Housing Benefit is paid directly to your landlord, we may discuss payment details (amounts and dates) with them as we have to provide this information.
Covid-19 Business Support Grants
Information submitted as part of your application for Covid-19 related Business Support Grants will be shared with the Department of Business, Energy & Industrial Strategy, the Ministry of Housing, Communities and Local Government and the National Anti-Fraud Initiative. It may also be shared with HMRC. Your information may be shared whether your application is successful or not.
We are required to submit various returns to government so that they can monitor the effectiveness of support grants, ensure the right amount of money is paid to the Council for the grants it administers and to prevent, detect and recover grants obtained through misrepresentation and fraud.
The specific grants this relates to are the Small Business Grant Fund, Retail Hospitality & Leisure Grant Fund, Local Authority Discretionary Grant Fund, Local Restriction Support Grant for Closed Businesses, Local Restriction Support Grant for Open Businesses, Christmas Support Wet-Led Pubs, Closed Business Lockdown Payments, Additional Restriction Support Grants and Restart Grants.
Test & Trace Self Isolation Payments
If you apply, we will need to process your personal data to assess whether you are eligible to receive financial support, and if so, to provide a payment to you. As part of this assessment we will check your information against that held by other government departments and may also share your information with them. More specifically:
We will obtain data from the NHS Test and Trace Service to confirm that you have either tested positive for COVID-19 or you have been in close contact with someone who has tested positive for COVID-19. As this data is related to your health it is referred to as ‘special category data’.
We will carry out checks with the NHS Test and Trace Service and the Department for Work and Pensions (DWP) for verification purposes, Her Majesty’s Revenue and Customs (HMRC) for tax and National Insurance purposes, and potentially with your employer in validating your application.
We will carry out checks with the education or child care setting of the child who is isolating for verification purposes.
Information relating to your application will also be sent to the DHSC to help understand public health implications, allow us to carry out anti-fraud checks and determine how well the scheme is performing.
We will not share this data with other organisations or individuals outside of City of Bradford Metropolitan District Council for any other purpose.
We will provide information to HMRC in relation to any payments we make because Self-Isolation Payments are subject to tax and National Insurance contributions. If you are self-employed, you will need to declare the payment on your self-assessment tax return.
To validate your bank account details, we need to share relevant information you've given us with TransUnion. This will be used to ensure your Test and Trace Support Payment is paid to the correct bank account and to help prevent fraudulent use of the Test and Trace Support Payment scheme. This is not a credit check and won't impact your credit rating.
For more information on how TransUnion may use your data, visit the TransUnion website.
City of Bradford Metropolitan District Council are the data controller for the purposes of assessing eligibility, administering and making payments under the Test and Trace Support scheme.
The Department of Health and Social Care (DHSC) has commissioned NHS Test and Trace on behalf of the government and is the data controller for the purposes of providing Test and Trace data to City of Bradford Metropolitan District Council.
Research and Statistics
Sometimes we may use the information you have provided us for research and statistics to help us better deliver services and share this with our partners. This may also involve sharing information we hold about you with government departments who lawfully request it. In most cases we remove any personal information that may identify you as an individual or household and only use and share anonymous statistics.
There are occasions however when government departments require your personal information and we will ensure only a minimal amount is shared for a specific purpose, for example The Office for National Statistics (ONS).
How do we keep this information secure?
Your information is stored securely on database and document management systems with stringent access and use policies. We also undertake quality checks and monitoring to ensure the information we hold is accurate at the time and being used appropriately.
When computers make decisions about you
Council Tax billing
When you submit an online form to update your Council Tax information, our system may process this automatically and determine a new bill. If you disagree with the outcome, you can appeal to have the outcome reviewed by a person in the normal way by following these instructions.
Income collection
If you have not kept up with payments or have not made an acceptable arrangement to pay, our system will automatically escalate your account and you will be issued with a reminder notice.
If payment or an acceptable arrangement has still not been made for Council Tax and Business Rates, the system will automatically escalate to court proceedings. The enforcement process is described in more detail on these pages for Council Tax and Business Rates.
If you disagree with the outcome, you can appeal to have it reviewed by a person in the normal way by following these instructions for Council Tax, Business Rates and Sundry Debt or by responding to the notices. If the case has progressed to court proceedings you may only be able to address this in court.
When your data gets sent to other countries
We do not send any information we collect about you outside the United Kingdom.
How long do we keep this information?
We have a record retention schedule which details how long we keep different types of records and what we do with them when we no longer need them.
This can be sent to you if you request it. Please email dpo@bradford.gov.uk.
What are your rights?
You have the right to request Bradford Council to stop processing your personal data in relation to any council service. See our main Privacy Notice for details.