Housing management privacy notice

Learn how we collect and use your personal data for housing management services.

Portsmouth City Council ("the Council", "we", "us") is the data controller for the personal information described in this notice. We are registered with the Information Commissioner's Office (ICO) (Registration Number Z5578313).

This privacy notice explains how Portsmouth City Council collects, uses, shares, stores and protects personal information relating to housing management services.

Who we are and how to contact us

Data Controller: Portsmouth City Council (Registration Number Z5578313)
Address: Civic Offices, Portsmouth, PO1 2AL
Data Protection Officer Email: DataProtection@portsmouthcc.gov.uk
Telephone: 023 9282 2251

If you have questions about this notice or want to exercise your data protection rights, contact the Data Protection Officer using the details above.

Who this notice applies to

This notice applies to:

  • People applying to rent a council home
  • Current council tenants
  • Former council tenants where information still needs to be retained
  • Members of a tenant's household
  • People receiving housing management and tenancy support services

The personal information we collect

When you apply to rent a home from us

We may collect:

  • Full name and proof of identity
  • Date of birth
  • Email address and telephone number
  • National Insurance number
  • Address details
  • Salary and employment information
  • Criminal offence information where relevant
  • Financial information, including bills, debts, loans and savings
  • Details of authorised representatives acting on your behalf
  • Names and dates of birth of household members
  • Bank account details
  • Information about previous tenancies, rent arrears and anti-social behaviour issues
  • Language and communication requirements
  • Tax and benefits information
  • Disability, health and support needs

When you are a tenant

We may collect:

  • Contact details, including email addresses and telephone numbers
  • Names and dates of birth of other people living in your home
  • Rent and service charge payment information, including arrears
  • Records of contact and correspondence with us
  • Health information and disability details where relevant
  • Criminal offence information where relevant
  • Ethnicity
  • Nationality
  • Gender
  • Photographs, video recordings, news stories and case studies where appropriate and where we have informed you

Additional information we may collect

We may also process information relating to:

  • You and your family
  • Your physical and mental health
  • Your financial circumstances
  • Housing needs and social care requirements
  • Information provided by professionals involved in supporting you, such as doctors, social workers and support agencies

Special Category and Criminal Offence Data

Some housing management services process special category personal data, including health, disability, ethnicity and support needs, and criminal offence information. We only process this information where the law allows and with appropriate safeguards.

Where we get your information from

We obtain information:

  • Directly from you through applications, forms, telephone calls, emails and meetings
  • From other Council services
  • From partner organisations, including support services, health professionals and social care services where appropriate
  • From previous landlords and housing providers where relevant
  • From government departments and public bodies where lawful

How we use your information and our lawful bases

We use personal information to:

  • Assess eligibility for housing and decide whether to offer a tenancy
  • Contact you regarding viewings, applications and tenancy matters
  • Communicate with you in an appropriate and accessible way
  • Set up and manage housing accounts
  • Collect rent, service charges and other payments
  • Maintain accurate and up-to-date records
  • Understand vulnerabilities and support needs
  • Tailor services to meet individual needs
  • Provide housing advice, tenancy support, budgeting support and independent living assistance
  • Deliver repairs and maintenance services and meet landlord health and safety responsibilities
  • Investigate and resolve complaints
  • Investigate anti-social behaviour and neighbour nuisance
  • Prevent and detect crime and fraud
  • Consult with tenants regarding service changes
  • Carry out customer feedback surveys and service improvement activities
  • Meet regulatory reporting requirements, including CORE (Continuous Recording of Social Housing Lettings and Sales)
  • Support research, planning and statistical analysis
  • Promote housing services through photographs, videos, news stories and case studies where appropriate

Lawful bases under UK GDPR

Most housing management activities are carried out under the lawful bases of:

  • Public task
  • Legal obligation
  • Contract

Consent is only relied upon in limited circumstances and will be made clear when information is collected.

Special Category Data (Article 9 UK GDPR)

Where special category information is processed, the Council relies on conditions including:

  • Substantial public interest
  • Health or social care purposes
  • Safeguarding of children and adults at risk
  • Social protection and housing functions

Who we share your information with

We may share information where necessary and lawful with:

  • Other Council services
  • Contractors carrying out repairs and services on our behalf
  • Legal services and solicitors
  • Survey and consultation providers acting on our behalf
  • Specialist tenancy support services
  • CORE (Continuous Recording of Social Housing Lettings and Sales)
  • Professional advisers, including insurers and legal advisers
  • Regulators
  • IT system suppliers and service providers
  • Credit reference agencies where you have consented to this as part of money advice services
  • Mailing and messaging providers acting on our behalf
  • Social care and health organisations where safeguarding concerns exist
  • Police and other law enforcement agencies where required to prevent or detect crime
  • Family members, carers or representatives where you have authorised this or where the law otherwise permits

We will only share information necessary for the relevant organisation to deliver services, provide support or carry out its legal responsibilities.

We do not share personal information for third-party marketing purposes.

CCTV and Body Worn Cameras

Some Council housing properties, estates and offices operate CCTV systems and body worn cameras.

These systems are used to help ensure the safety and security of residents, visitors and employees, investigate complaints, address anti-social behaviour, prevent and detect crime, and support insurance claims and legal proceedings.

CCTV and body worn camera footage may be shared with the police, courts, insurers and other authorised organisations where lawful and necessary.

CCTV and body worn camera recordings that are stored and catalogued may be accessed through a Subject Access Request. Access may be restricted where footage contains other identifiable individuals or where another legal exemption applies.

Portsmouth City Council may not record CCTV at all locations displaying CCTV signage and not all cameras will be operational at all times.

How long we keep your information

Personal information is only kept for as long as necessary for the purposes for which it was collected and in accordance with the Council's corporate retention schedule.

We regularly review records to ensure information remains accurate and up to date. Information may continue to be retained after a tenancy ends where this remains necessary for housing management, legal, regulatory, safeguarding or financial purposes.

Further information can be found in the Council's corporate retention schedule.

How we keep your information secure

Technical and organisational measures are used to protect personal information, including:

  • Access controls and permissions
  • Staff training and awareness
  • Secure storage and IT systems
  • Regular monitoring and validation processes
  • Information security and data protection policies
  • Contractual controls with contractors, suppliers and service providers

Anyone processing personal information on behalf of Portsmouth City Council is required to do so securely and only for authorised purposes.

Your data protection rights

Under data protection law, you may have the right to:

  • Access your personal information (Subject Access Request)
  • Request correction of inaccurate information
  • Request erasure in limited circumstances
  • Request restriction of processing
  • Object to processing in certain circumstances
  • Request data portability in limited circumstances
  • Exercise rights relating to automated decision-making and profiling

Right to object

You have the right to object to processing carried out under public task or legitimate interests in certain circumstances. Requests can be made by contacting the Data Protection Officer.

How to exercise your rights

You have the right to know whether Portsmouth City Council holds personal information about you.

Requests can be made by contacting the Data Protection Officer or by visiting the Council's subject access request and Freedom of Information pages.

You will usually be entitled to access your personal information, although access may be restricted where information relates to other individuals or where a legal exemption applies.

Complaints

If you are unhappy with how your personal information has been used, please contact the Data Protection Officer in the first instance.

If you remain dissatisfied, you may complain to:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Links to other websites

The Council's website may contain links to other websites. This privacy notice does not cover those websites. Please read the privacy notices published on any external sites you visit.

Changes to this privacy notice

This privacy notice was last reviewed on 1 July 2024.

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