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Crawley Homes privacy notices

Crawley Homes privacy notice

This privacy notice applies to Crawley Homes, which is the council’s landlord service. It applies for all tenants, leaseholders, and shared owners of the council. It covers anyone who is housed in the council’s temporary accommodation (hostels), which are managed by Crawley Homes. It also covers anyone who rents a garage from the council.

This notice explains how personal information is going to be used, what it is used for, who it might be shared with and why and for how long it is to be kept. 

What information is collected?

The information we collect and may hold about you depends on our relationship with you through your Tenancy agreement, Lease or licence and may include:

  • Personal information including name (and proof of your identity / photo ID), age, date of birth, sex, gender identity, relationship status, household relationships religion, ethnicity, nationality, national insurance number, income and benefits details, employment details and status, contact details (phone, email, correspondence address), banking information (if you pay your rent by direct debit or card though we do not retain card detail information) and details of unspent criminal convictions.
  • Details of any change of circumstances.
  • Information you provide relating to your housing eligibility, including income assessments and any interest or equity in other property.
  • Information relating to your home including photographic evidence of repair and maintenance issues or tenancy breaches.
  • Basic details of all members of your household (name and date of birth).
  • Details of your next of kin and anyone authorised to act on your behalf if applicable
  • Information relating to any pregnancy, disability, vulnerability, medical issues, support needs or caring responsibilities if applicable.
  • Records of any of our contacts with you, your contact with us and any contact from third parties representing you or about you.
  • Any feedback you provide on our services.
  • Other personal information that will vary on a case by case basis to help us manage your tenancy or lease, resolve breach of tenancy, alleged anti-social behaviour or fraud this may include details of any behaviour carried out by yourself or members of your household.
  • CCTV images of you if you visit or live in a Hostel.
  • In some circumstances we use and retain images and / or sound recordings captured on CCTV, camera or recording devices to help in the detection and prevention of crime, anti-social behaviour and/or tenancy breaches.
  • From time to time we may also take photographs at our events, at our properties or in our neighbourhoods to use for general marketing and publicity (we will not publish these without your consent).
  • Information about you and your tenancy for Core (COntinuous REcording of Lettings and Sales in Social Housing in England) for research and statistical purposes only.

Generally the information we hold will have been provided by you (on application or enquiry forms when we communicate with you) but we may also hold information provided by third parties where this is relevant to your housing circumstances e.g. from social workers, health professionals or the police.

We will only ask for personal information that is appropriate to enable us to deliver our services. If you do not provide the information we need then we may not be able to provide all our services to you, and ultimately you may not be able to hold a tenancy or lease with us.

When you provide information about household members we assume that you do so with their full knowledge and consent and we may then store and use this information in the same way as we use your data.  

Why do we collect your personal information?

We collect, process and store personal information about you and other household members in order to manage, operate and deliver services to you. This includes:

  • Managing your account charges and payments including any arrears
  • Managing the repairs, maintenance and any adaptations to your property
  • Ensuring your contractual obligations are complied with
  • Complying with relevant legislation and regulation
  • Deliver services and support to you
  • Train and manage the employment of our workers who deliver those services;
  • Help investigate any worries or complaints you have about your services;
  • Keep track of spending on services
  • Check the quality of services

Data Controller

Crawley Borough Council is registered as a Data Controller with The Information Commissioner’s Office (Registration Number Z5327706).

The Council (CBC) complies with The Data Protection Act 2018 and the GDPR. 

We ensure that your personal data is processed fairly, kept safe and secure and retained for no longer than is necessary.  
The Data Protection Officer for CBC is Head of Legal and Democratic Services.

If you have any concerns or questions about how we look after your personal information please contact the Data Protection Officer.

The legal basis for processing personal data

  • Consent of the data subject
  • Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract.
  • Processing is necessary for compliance with a legal obligation.
  • Processing is necessary to protect the vital interests of a data subject or another person.
  • 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

The legal basis for processing special category data

  • Processing is necessary for the purpose of carrying out obligations and exercising specific rights of the Controller
  • Processing is necessary to protect the vital interests of the data subject
  • Processing is necessary for reasons of substantial public interest

Who we share data with

Normally, only Crawley Homes staff will be able to see and process your personal information. However, there may be times when we will share relevant information with third parties for the purposes outlined above. When sharing personal information, we will comply with all aspects of the Data Protection Act.

Sensitive information about health, sexual life, race, religion and criminal activity for example is subject to particularly stringent security and confidentiality measures.

Where necessary or required, we may share your personal information as follows: 

  • Internal departments
  • Our repairs contractors
  • Other third-party service providers for example Chichester Careline (if you have a ‘Life Line’) and FCS Laser Mail
  • Other statutory organisations with whom we have a duty to co-operate including: social services and health services as necessary for exercising statutory functions (for example safeguarding)
  • Other local authorities and government departments, as necessary for administering justice, or for exercising statutory, governmental, or other public functions.
  • The police and other relevant authorities (e.g. Probation) in relation to the prevention and detection of crime and fraud.
  • Registered Social Landlords Housing (for example in relation to mutual exchange applications)
  • Benefits Agency.
  • Utility companies and other organisations to confirm occupancy
  • Third party creditors (in relation to provision of debt advice)
  • HM Court Services.
  • CORE data collected will be shared with Ministry of Housing Communities and Local Government (MHCLG).

This list is not exhaustive as there are other circumstances where we may also be required to share information, for example:  

  • To meet our legal obligations
  • In connection with legal proceedings (or where we are instructed to do so by a Court order)
  • To protect the vital interests of an individual (in a life or death situation)

We will not share data with third-parties for marketing purposes.  

Retention schedule

This schedule refers to Housing Provision, the management of social housing by the local authority.

Why we process information
How long we keep records for
Examples of records we keep
Management of tenancies: processing information for the awarding of tenancies in social  housing, management of tenancies, provision of support and legal obligations e.g. safeguarding
Retain from end of tenancy for six years  
Correspondence regarding the tenancy. Tenancy files, case notes and records. Council housing application forms and supporting material.  Application for transfer of tenancy and supporting papers.  Application for emergency housing or referral from another agency.  All records relating to support given to housing tenants. Tenancy renewal application forms and supporting material including income assessments.  Signed tenancy agreements.
Management of rent accounts 
Retain from end of tenancy for six years. Where a tenancy ends with rent arrears we will retain records for six years after the debt is cleared. 
Documentation relating to the notification and enforcement of breaches of council tenancy agreements.  Correspondence concerning rent payments.  Requests for payment.  Bank details.  Financial information, employment information, benefits information and debt information.
Housing repairs 
Retain from end of tenancy for six years 
Contact information
Garage lettings 
Retain from end of tenancy for six years
All records relating to the management of garage lettings
Feedback surveys
For one off surveys personal data is deleted after the final report is written. For continuing surveys personal data is deleted after three years.
Periodic feedback surveys. Satisfaction surveys e.g. after repairs work.
Leasehold services 
Retain from end of contractual relationship i.e. the onward sale of the property for six years 
Leaseholder contact information
Right to Buy 
All records relating to the management of Right to Buy schemes will be retained from date property purchased for 12 years and 12 months. The casefile relating to the Right to Buy retained from close of case for six years.
Sale documents. Agreement concerning sale.  

Rights

  1. Be informed of data processing (which is covered by this Privacy Notice)
  2. Access information (also known as a Subject Access Request)
  3. Have inaccuracies corrected
  4. Have information erased
  5. Restrict processing
  6. Data portability
  7. Intervention in respect of automated decision making
  8. Withdraw Consent (see below)
  9. Complain to the Information Commissioner’s Office (See below)

To exercise any of these rights please contact the Data Protection Officer

Withdrawal of consent

The lawful basis upon which CBC process personal data is set out in this Notice However, where personal data is solely processed on the basis of consent, you will have the right to withdraw that consent.  

Where can I get advice?

If you have any worries or questions about how your personal information is handled please contact our Data Protection Officer.

For independent advice about data protection, privacy and data rights, you can contact the Information Commissioner’s Office (ICO):

  • Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire DK9 5AF
  • Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.  
  • Visit ico.org.uk
  • Email casework@ico.org.uk.