Lewisham Council tenant and leaseholder privacy notice

Information about how and when we process personal information about council tenants and leaseholders.

Purpose of this Privacy Notice

Lewisham Council Housing Services / ‘our’ / ‘us’ / ‘we’ are committed to protecting the personally identifiable information (PII) we collect about you and obtaining, using, and disclosing this information in accordance with data protection legislation. Privacy is important to us, and we are committed to protecting and ensuring your PII always remains safe. Privacy laws govern the way in which we process your information as well as the rights you have to the information we hold about you.

This privacy notice explains how we will use any PII you provide to us for yourself and your household. Please read this notice carefully and make sure you understand your rights and responsibilities. As our services develop we will continue to update and review this statement to comply with the law. The contents of this notice apply to our residents, both tenants and leaseholders, some parts of the document do refer specifically to tenants or leaseholders, as appropriate.

Who we are and our contact details

Lewisham Council has formally taken over responsibility for managing and maintaining more than 19,000 homes across the borough, following the transfer of staff and services from Lewisham Homes.

Lewisham Council Housing Services is a directorate within Lewisham Council covering housing management, maintenance, and strategy in the borough.

Lewisham Council is a registered data controller under the Information Commissioners Office (ICO). Our registration number is Z4977444. In accordance with the Data Protection Act 2018 we collect and process PII about our residents. We do this to provide social housing and services related to housing or as permitted by law.

For further information or queries contact our Data Protection Officer at DPO@lewisham.gov.uk based at:
Lewisham Council
Laurence House
London
SE6 4RU

Summary

Full details are set out in the relevant sections of this notice below, but in summary:

We receive PII relating to you from you directly, but it may occasionally be provided to us by third parties with whom you have a separate relationship (such as a local authority).

We use your data to provide housing and other services to you, correspond with you, meet our legal obligations and improve our products and services.

We provide your PII to third parties as part of our role to provide housing and services or as permitted by law.

We don’t share your data with third-party advertisers.

We store data for specified periods for our limited business purposes.

You have certain rights prescribed by law in relation to the processing of your data, such as rights to request access, restriction, portability, rectification, to be informed, or deletion of your PII, in certain circumstances.

We have CCTV in operation at some of our sites.

What is Personally Identifiable Information?

PII is data related to a living individual who can be identified from that data, either directly or indirectly. This can also include special categories of personal data (SPD) (revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, and genetic data, biometric data, health data and data concerning a person’s sex life or sexual orientation) as well as information relating to criminal convictions and offences.

How we use your PII?

PII will be processed in accordance with the Data Protection Act 2018.

This notice sets out how we use your information in the following circumstances:

Your Tenancy or Lease
CCTV
Resident Involvement
Marketing Communications

Who do we share your information with and why?

Where required we will disclose your PII with others, in these instances we will ensure we have appropriate information sharing protocols in place.

All Lewisham Council staff, contractors and suppliers who provide services to you, or who provide services on our behalf, e.g. contractors who undertake repairs/improvements or research companies who conduct surveys for us
Anyone who you have provided permission to speak with us on your behalf
Banks, to carry out payments through a secure system
Local authorities, other housing and support organisations and statutory agencies
Mediation partner organisations
Our solicitors and other advocacy partner organisations
Lewisham Council insurers in the event of public liability claims
Credit reference agencies
External assistance where you have agreed to the referral
Utility companies
Tracing/debt collection agencies for unresolved debts after termination of tenancy by either party or unpaid service charges / major works owed by a leaseholder

In some cases we will have a duty to disclose your information by law to:

Other housing associations
Local authorities, regulators and government departments
Police, fire services, health authorities or medical staff
Others who may need information from us for their own purposes, for example detecting and preventing crime, prosecuting offenders and for the prevention and detection of fraud

We do not provide organisations with access to your information in return for payment for their marketing or commercial purposes. However, on an annual basis we are obliged to disclose your information by law to the government, as required of all housing associations. There may also be instances when we are required regulator with appropriate powers or via court order.

From time to time we may need to provide third parties with PII relating to you or members of your household or obtain PII relating to you or members of your household from third parties. However, this will only be so we can accomplish our responsibilities as a housing provider.

What Information we collect from you

We will collect the following PII about our tenants:

Name
Address
Phone number
Marital status
Whether you have any dependants
National Insurance Number
Benefits
Date of birth
Family details
Reference information
Relationship status
Home Finder application number (if applicable)
Documentation includes:

For a tenant: one photographic document e.g. passport, national identity card, provisional/full driving license – or a UK birth certificate where none of these are available. Home office ID card for nationals outside EEA and freedom pass. 2 passport photos, legal documents if name changed and home office documents
For an adult occupant: one photographic document e.g. passport, national identity card, provisional/full driving license – or a UK birth certificate where none of these are available. Freedom pass. 2 passport photos and legal documents if name changed
For a child occupant: full birth certificate, and documentation to confirm tenant is in receipt of child benefit for the child

If you do not provide us with the information required we will not be able to process your application for a tenancy or provide you with a property that meets your needs.

We will collect the following PII about our leaseholders:

Name
Address
For absentee leaseholders: your contact address, telephone number and e-mail address

Note that if you have purchased your property under Right to Buy we will hold data for you and your household as per the tenant list above. This previous information will form part of your former tenancy record and held in line with our document retention policy.

During the life of your tenancy or lease we will collect and process information about you and members of your household for the following purposes:

There may be some not applicable to leaseholders or alternatives available, these are noted.

managing your tenancy or lease
providing safe and sustainable properties
monitoring compliance with the terms of your tenancy or lease agreement
delivering support to you or members of your household (note that leaseholders can find detail about relevant support via our web site).
conducting surveys in order to monitor and improve our services
providing associated welfare services, advice and support
maintaining our accounts and records
recruiting, supporting and managing our board and employees
recruiting, supporting and managing our agents and contractors that we use to help maintain properties and services
promoting the services we provide
carrying out surveys and conducting research
Local Fraud Initiatives, including the Lewisham Council Anti-Fraud & Corruption Team to tackle tenancy fraud. We may share the PII you have provided with fraud prevention agencies who will use it to prevent and detect fraud and money laundering and to verify your identity. If fraud is detected you could be refused certain services, finance or employment. For more information about this read the anti-fraud and corruption notice.
corporate administration and all activities we are required to carry out as a data controller
ensuring we meet our legal obligations as a housing provider
insurers and/or professional advisers in relation to maintaining insurance coverage
where you are identified as an alleged victim, witness or perpetrator of anti-social behaviour or are the reporting party in relation to queries, complaints or reports.
to allow the statistical analysis of data so we can plan the provision of services
to prevent and detect fraud or crime

Unless we specifically advise you otherwise, we will only collect and process PII that we need to carry out these functions.

Collection of PII for Residents

The collection and processing of PII allows us to provide a service that meets your needs, and the information will be processed for social care purposes and as part of emergency response situations.

For tenants, the collection of criminal conviction information allows us to monitor housing benefit and to assess the tenancy, such as whether bail conditions exclude the tenant from the property or area. Criminal conviction data would also be collected if a tenant applied to us for a friend or relative to be a caretaker of the property while the tenant is in prison. This information is processed because of our statutory function to provide social housing and handle housing benefit.

This PII will be stored on our computer systems and/or a paper tenancy file. It is held securely and we have security measures in place to prevent it from being accessed by any unauthorised person. We do not transfer your data outside of the European Union.

CCTV

CCTV is installed on some of our estates to monitor building security, crime prevention and detection. We also operate some mobile CCTV.

We operate our CCTV in accordance with the guidance issued by the ICO. The Data Protection Act 2018 covers images of people and information about people derived from CCTV, for example a vehicle registration plate.

We collect this data as part of our public function as a housing provider to ensure the health and safety of residents and staff.

We will not hold images for longer than necessary and will dispose of them securely.

Information on Children (Tenants only)

We collect information from you regarding members of your household, including information on children.

We collect this data for the purposes of processing your application for a tenancy and providing you with a property that meets your needs.

We do not communicate with children directly and we would not normally share data with agencies or contractors on children.

We may share information on children with the necessary agencies if they were identified as an alleged victim, witness or perpetrator of anti-social behaviour.

Resident Involvement

We encourage residents to become involved in helping us to improve the services that we provide. Should you decide to be kept informed about community projects and ways to get involved you will be added to the resident involvement database.

To be added to this database, the following PII will be collected from you:

Name
Address
Phone Number
Email Address

Information on that database will be kept separate from the main database and your PII will be used specifically for this purpose.

We may use this information to contact you and for consultation exercises. This information is processed as part of our role as a public authority as resident involvement helps us to improve our services as a housing provider.

How we store your information

We store PII and SPD both electronically and in paper format. We use a range of controls to keep your PII is secure from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. These include delivering data protection training to all our employees and implementation of security policies, processes, and technical physical security solutions.

Information kept in a paper format is placed in secure storage, e.g. lockable filing cabinets if onsite in the Lewisham Council office and in a secure data storage sites if held externally. Security checks are conducted if you call our front-line teams to ensure the call handler can identify you before disclosing any account-related information. We do this to protect you, your data and ensure that other people are not privy to your PII.

If you would like another person to speak to us on your behalf, e.g. relative, carer, partner, friend, etc. you will need to provide them with your permission and make us aware of this. We cannot discuss your personal situation or disclose information about you without your permission, permission can be granted verbally every time you call us alternatively you can confirm in writing and a note will be retained on our system and we can then speak with your chosen contact.

Do we send data overseas?

We do not send data overseas. We may sometimes make use of cloud-based systems to support the management of our business. Where this happens we will ensure that there are appropriate safeguards in place to protect your rights.

Email and text communications

We send our residents a monthly email newsletter. This includes important information regarding health and safety and our services alongside opportunities in the borough which may be of interest. Our community relations team may also send text messages regarding opportunities in your area.

To provide you with the updates we process the following types of information:

Name
Address
Phone Number
Email address

We process your information in this circumstance because you have entered into a contract with us and it is necessary to perform our statutory duties.

You can opt out (unsubscribe) from these emails and texts, but we will continue to process your information for other purposes as set out above, to continue to provide you with housing services. This may include contacting you with important information regarding health and safety and your contract (tenancy agreement/leasehold) with us.

You can view your contact preferences and update your settings at any time on the Resident Portal. You can call us on 0800 028 2028 to opt in or opt out of any method of communication.

Alternatively you can write to us at customer.relations@lewisham.gov.uk or Customer Relations, Lewisham Council Housing Services, Laurence House, SE6 4RU.

How long do you keep my PII for?

All PII is retained in line with our Retention and Disposal Policy. The following applies:

Current tenants’ Tenancy Files, including rent payment records, and details of any complaints and harassment cases, are retained for the length of the tenancy plus 6 years thereafter
Former tenants’ Tenancy Agreements, and details of their leaving are retained for 6 years
If you go on to purchase your property, documentation relating to your statutory right to purchase council housing is retained for 12 years after the sale of the property
For leaseholders, we hold the information for the duration of the lease or if you assign the lease to someone else for 12 years after the date of the assignment

The data we collect and retain for the necessary period of time is sourced through all types of communication, this includes telephone calls, e-mail and paper-based correspondence.

How can I apply to see the PII you hold about me?

If you wish to see a copy of the PII we hold about you then you can ask us at any time and we must respond within one calendar month of the request. This is a data subject access request under the Data Protection Act 2018.

You will not have to pay a fee to access your PII. However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

You have a legal right to access information we hold about you, including the right to:

Be informed about how we process your PII – this is why we have developed this privacy notice
Have access to a copy of the PII we collect and keep on you – known as a data subject access request
Have incomplete or inaccurate information rectified
Restrict the processing of your PII in certain circumstances, for example, if you have challenged the accuracy or you have objected to the processing of your PII
Have PII erased in certain circumstances
Obtain and have your data ported across different service providers, from one ICT environment to another
Object to the processing of your PII in certain circumstances including to stop your details from being used for direct marketing purposes
Request human intervention when decisions are made solely by automated means, you have the right to ask for details of the logic leading to the decision

You may exercise any of your rights in relation to your PII by written notice to us.

You can exercise any of the above rights by emailing the Customer Relations Team at customer.relations@lewisham.gov.uk or writing to Customer Relations, Lewisham Council Housing Services, Laurence House, London SE6 4RU.

If you wish to make a complaint about how we are processing your PII please contact the Data Protection Officer at DPO@lewisham.gov.uk. You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO). Find out how to contact the ICO on their website.

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Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will notify you when we make any fundamental changes. We may also notify you in other ways from time to time about the processing of your PII.