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 supported housing 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 living in supported housing accommodation
- People receiving housing-related support services
- Applicants and residents assessed for supported housing services
- Family members, carers and representatives involved in supporting residents where appropriate
The personal information we collect
We may collect:
- Name, address and date of birth
- Contact details
- Next of kin and emergency contact details
- Information about your household, family circumstances and relationships
- Referral and assessment information
- Relevant case records and support information
- Risk information to help keep you and others safe
- Financial information, including bank account details where payments are made by Direct Debit
- Photographs where necessary or where you have agreed to their use
- Records of correspondence, emails, letters and telephone calls
- Information received from people or organisations involved in supporting you
We may also collect special category personal data where relevant to your support or tenancy management, including:
- Ethnicity
- NHS number
- Physical and mental health information
- Mental capacity information
- Disabilities, vulnerabilities and support needs
We only collect and use information necessary to deliver supported housing services and fulfil our legal responsibilities.
Where we get your information from
We obtain information:
- Directly from you through applications, referrals, assessments and support arrangements
- From family members, carers or representatives where appropriate
- From health and social care professionals involved in your support
- From partner organisations involved in housing or support services
- From other Council services where relevant and lawful
How we use your information and our lawful bases
We use personal information to:
- Deliver supported housing services
- Manage your tenancy and accommodation
- Arrange planned and responsive repairs
- Assess support needs and risks
- Help you access other services and support
- Coordinate support with relevant organisations
- Manage tenancy-related payments and charges
- Support safeguarding and risk management arrangements
- Improve and develop housing support services
- Produce communications, case studies, photographs or publicity materials where you have agreed
Lawful Bases under UK GDPR
Most supported housing activities are carried out under the lawful bases of:
- Article 6(1)(e) Public Task – processing is necessary for a task carried out in the public interest or in the exercise of official authority, including the provision of housing-related support services
- Article 6(1)(b) Contract – processing is necessary for the performance of your tenancy agreement and related services
Where consent is relied upon, such as for optional publicity, photography or communications activities, this will be obtained separately and may be withdrawn at any time.
Special Category Data (Article 9 UK GDPR)
Where special category information is processed, the Council relies on conditions including:
- Article 9(2)(h) – health or social care purposes
- Article 9(2)(g) – substantial public interest, including safeguarding and protecting individuals where applicable
Do you have to provide this information?
Some information is necessary for us to provide supported housing services safely and effectively.
Without relevant information we may not be able to:
- Assess your support needs
- Deliver appropriate housing support
- Manage your tenancy effectively
- Coordinate with services involved in safeguarding or risk management
- Respond appropriately to issues affecting your accommodation or wellbeing
Who we share your information with
We only share personal information where the law allows or requires us to, and only where necessary.
We may share information with:
- Health services and healthcare professionals
- Adult and children's social care services
- Department for Work and Pensions (DWP)
- Police and law enforcement agencies
- Care agencies and support providers
- Housing providers and landlords
- City, district and borough councils
- Direct payment support services
- Internal Portsmouth City Council departments
- Contractors carrying out repairs and maintenance on our behalf
- Family members, carers or representatives where appropriate and lawful
Information may also be shared:
- In safeguarding or life-threatening situations
- To prevent or detect crime or fraud
- To carry out a statutory duty
- To support tenancy management and housing support services
We may share or withhold information where sharing would place an individual at risk or where disclosure is restricted by law.
Data Processors
Where organisations process personal data on our behalf, we ensure appropriate contracts are in place requiring them to:
- Process data only on our instructions
- Keep information secure
- Comply with data protection law
- Return or securely destroy information when no longer required
CCTV and Body Worn Cameras
Some supported housing services and locations may use CCTV systems and body worn cameras.
Where recordings are stored and catalogued, individuals may request access through a Subject Access Request.
Access may be restricted where recordings contain other identifiable individuals or where disclosure would prejudice the prevention or detection of crime 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.
International Transfers
We do not routinely transfer personal information outside the UK.
If it becomes necessary to do so, appropriate safeguards will be put in place in accordance with UK GDPR.
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.
Retention periods vary depending on the type of information and purpose for which it was collected.
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 suppliers, contractors 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
- Withdraw consent where consent is relied upon
- 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 in certain circumstances. Requests can be made by contacting the Data Protection Officer.
How to exercise your rights
You can ask whether Portsmouth City Council holds personal information about you and request a copy through a Subject Access Request.
You will usually be entitled to access your personal information, although access may be restricted where a legal exemption applies.
Automated Decision-Making
The Supported Housing Service does not make decisions about you that have a legal or similarly significant effect solely through automated processing.
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 8 August 2025.