Housing Management Services Privacy Notice

This privacy notice explains how we use personal information when delivering our Housing Management Services. These services include managing Council tenancies, processing housing applications, carrying out repairs and property maintenance, addressing reports of anti‑social behaviour, supporting tenants to sustain their tenancies, and fulfilling the Council’s statutory duties under housing and homelessness legislation. We work closely with tenants, applicants, contractors, housing providers, and partner agencies to ensure safe, well‑managed homes and effective housing services. This notice sets out what information we collect, how we use it, who we may share it with, how long we keep it, and how we protect your privacy.

What information we collect, use, and why

Whenever you contact us, whether in person, by phone, online, or through our housing systems, we collect certain information so we can provide Housing Management Services. This helps us identify you, understand your circumstances, manage your tenancy or application, arrange repairs, and fulfil our legal and contractual responsibilities as a local housing authority.

We collect the following types of information:

Personal Data

Name, address, and contact details: To identify you, manage your tenancy or housing application, arrange repairs or inspections, and keep you updated about your home or case.

Date of birth: To confirm your identity, match records, determine eligibility for certain services, and prevent tenancy fraud.

National identifiers (e.g., National Insurance number): To verify identity, prevent fraud, and meet statutory requirements where needed.

Family composition and household relationships: To ensure the property is suitable for your household, support tenancy management, understand any care or support needs, and meet legal requirements around occupancy and safeguarding.

Housing history and case file information: To manage your housing application, tenancy, repairs, anti‑social behaviour cases, tenancy sustainment work, or other housing‑related interactions. This may include visit notes, correspondence, reports, decisions, and records of actions taken.

Financial information: To assess affordability, manage rent accounts, prevent and manage arrears, and determine eligibility for certain financial support.

Employment and education details: Where relevant, to assess eligibility for certain housing services, support tenancy sustainment, or coordinate with partner agencies.

Property‑related information: Including details of repairs, inspections, adaptations, property condition, reports from contractors, and information you give us about issues in or around your home.

CCTV, body‑worn video, and audio recordings: Where applicable, to prevent and detect crime, protect staff and residents, and investigate incidents.

IP address and online identifiers: To keep your online interactions secure (for example, when using online repair reporting or tenant portals).

Special Category Data

We only collect special category data where it is necessary, proportionate, and relevant to deliver housing services or fulfil legal duties.

Physical or mental health information: To assess housing needs, prioritise applications, support tenancy sustainment, arrange adaptations, or identify safeguarding concerns.

Information from health or support professionals: Where needed to inform decisions about your housing needs, tenancy support, safeguarding, or property suitability.

Racial or ethnic origin: To monitor equality, ensure fair access to services, and meet statutory equality duties.

Religious or other beliefs: Only where necessary, for example to meet cultural housing needs or support safeguarding.

Criminal Data

We may collect and use information relating to criminal offences or allegations where this is necessary and lawful. This can help us to:

assess and manage risks related to tenancy management or community safety
investigate and resolve reports of anti‑social behaviour
protect staff, residents, and property
comply with statutory obligations

This may include information from the Police, probation services, courts, or other authorised agencies.

Sources of Information

We primarily collect information directly from you when you apply for housing, manage your tenancy, report a repair, contact us about anti‑social behaviour, or engage with us in any other way. However, to deliver Housing Management Services effectively and lawfully, we may also receive information from the following sources:

Other local authorities: For example, when you move into or out of the area, apply for housing with a history elsewhere, or where another authority has relevant information about your housing needs or circumstances.

Central government agencies: Such as the Department for Work and Pensions, where information is required to support rent accounts, benefits‑related matters, or fraud prevention.

Police, probation and courts: To support community safety work, manage anti‑social behaviour cases, protect staff and residents, and meet legal obligations.

Health and social care services: Including GPs, social workers, mental health teams, occupational therapists, or safeguarding teams, where information is needed to support tenancy sustainment, identify vulnerabilities, or assess housing needs such as adaptations.

Registered providers and housing associations: Where information is required to support housing applications, tenancy management, or to coordinate work across different landlords.

Housing developers, conveyancers, and the Land Registry: For example, where information is required about property ownership, sales, right‑to‑buy applications, or historic transactions.

Contractors and repairs providers: Such as operatives, surveyors, and call‑handling services who report back on repair issues, property condition, safeguarding concerns, or follow‑up actions required.

Banks, building societies, and Independent Financial Advisers: To confirm financial information where relevant to housing transactions or affordability assessments.

Identity verification services or documents: Such as passports, driving licences, birth certificates, or other proof of identity you provide to confirm eligibility and prevent fraud.

Members of the public, neighbours, or referrers: Where complaints, reports of anti‑social behaviour, or safeguarding concerns are raised.

Family members, carers, or advocates: Where they provide information with your knowledge or involvement, or where this is necessary to address support needs.

Other departments within the Council: Including revenues and benefits, community safety, safeguarding, early help, or environmental services, where information‑sharing is necessary to manage your tenancy, coordinate services, address risks, or meet statutory duties.

Online platforms and systems: Information may also be collected automatically when you use our online forms, repairs reporting systems, or tenant portals, such as login details, service usage, or security‑related data.

What is your personal information used for?

We use your personal information only where it is relevant, necessary, and lawful to deliver Housing Management Services. This includes managing your tenancy, supporting your household, maintaining your home, fulfilling our legal duties, and ensuring safe and well‑managed neighbourhoods. Your information is used for the following purposes:

Managing your housing application and tenancy

To assess your housing application and determine eligibility, priority, and suitability of accommodation
To create, manage, and administer your tenancy agreement or licence
To carry out tenancy reviews, visits, and checks to ensure legal requirements and tenancy conditions are met
To support you in sustaining your tenancy, address issues early, and provide referrals to support services where needed

Delivering repairs, maintenance, and property services

To arrange and manage repairs, maintenance, inspections, gas and electrical safety checks, adaptations, and property improvement works
To communicate with you and contractors about repairs, appointments, and follow‑up actions
To monitor the condition of properties and ensure homes meet health, safety, and quality standards

Managing rent, charges, and financial matters

To set up and administer rent accounts and service charges
To help prevent and manage arrears, including contacting you about outstanding balances and discussing repayment options
To assess eligibility for discretionary financial support or other assistance

Responding to queries, complaints, and service requests

To respond to your enquiries, complaints, and requests for information or assistance
To resolve issues you report relating to your home, neighbourhood, or tenancy

Preventing and addressing anti-social behaviour and community safety issues

To investigate, manage, and resolve reports of anti‑social behaviour, nuisance, crime, or community safety concerns
To work with partner agencies to protect residents, staff, and property where risk is identified
To take proportionate enforcement action where required by law or tenancy conditions

Safeguarding and supporting vulnerable residents

To identify and respond to safeguarding concerns involving children or adults at risk
To work with other services to ensure appropriate support is provided where vulnerability, risk, or additional needs are identified
To arrange property adaptations and support assessments for medical or mobility needs

Carrying out statutory and regulatory duties

To fulfil our legal obligations under housing, homelessness, health and safety, equality, fraud prevention, and community safety legislation
To maintain accurate and complete housing records for audit, compliance, and accountability purposes
To provide information required by government departments, regulators, or statutory bodies

Improving and monitoring our services

To monitor the quality and effectiveness of housing services, including contractor performance and service outcomes
To carry out tenant satisfaction surveys, feedback exercises, and service reviews
To use anonymised information for reporting, planning, and improving housing services

Communications and engagement

To send you essential updates about your tenancy, your home, repairs, inspections, safety checks, or changes to services
With your explicit consent only, to include your name, photograph, or experience in newsletters or tenant engagement activities

Who we share your information with

We only share your personal information where it is necessary, lawful, and relevant to deliver Housing Management Services, protect residents and staff, or meet our statutory responsibilities. Information is shared on a strictly “need‑to‑know” basis, and all organisations receiving it are required to handle your data securely and in accordance with data protection legislation.

We may share your information with the following types of organisations:

Health and Social Care Services

NHS services, GPs, mental health teams, and other health professionals
Adult and Children’s Social Care
Occupational therapists and medical assessment services

These organisations may receive information to support tenancy sustainment, safeguarding, medical or mobility assessments, property adaptations, or to help manage risks.

Police, Probation, and Criminal Justice Agencies

Police
Probation services
Courts and other enforcement bodies
Youth justice services (where relevant)

Information may be shared to investigate anti‑social behaviour, prevent or detect crime, safeguard residents, respond to legal requests, or manage risks to individuals or the community.

Other Housing and Property‑Related Organisations

Registered providers and housing associations
Housing developers and management companies
Contractors, repairs providers, and surveyors
Gas and electrical safety partners
Companies providing out‑of‑hours or call‑handling services

These organisations may receive information to arrange repairs, carry out safety checks, manage your property, provide tenancy support, or deliver services on our behalf.

Government Departments and Local Authorities

Department for Work and Pensions
Other local authorities (for housing applications, safeguarding, homelessness, or cross‑boundary service delivery)
Regulatory and audit bodies
Revenues and Benefits or other internal Council teams

Information may be shared to fulfil statutory duties, verify eligibility, prevent fraud, coordinate services across authorities, or meet legal reporting requirements.

Financial, Legal, and Professional Services

Banks, building societies, and financial advisers (where relevant to housing‑related transactions)
Legal representatives, tribunals, and advisers involved in tenancy enforcement or housing matters
Debt support agencies or welfare‑benefits partners (where appropriate)

These organisations may receive information when legal processes, financial assessments, or formal advice is required.

Community and Support Organisations

Advocacy services
Specialist support providers
Domestic abuse, substance misuse, or tenancy sustainment organisations
Charities or voluntary sector organisations involved in providing housing‑related support

Information is shared to ensure you can access support services tailored to your needs, where lawful and appropriate.

Land Registry and Property‑Related Authorities

Land Registry
Valuation Office or property compliance bodies

These organisations may receive information when it is relevant to property ownership, right‑to‑buy processes, leasehold matters, or legal compliance.

Internal Council Teams

We may share information with other teams within Cheshire West and Chester Council where necessary for:

Safeguarding
Community safety
Environmental health
Revenues and benefits
Fraud prevention
Legal services
Property and compliance services
Customer services and contact centre operations

This helps ensure a coordinated and effective service and supports us in meeting our legal responsibilities.

When we do not share your information

We do not sell your information or share it for marketing purposes.
We only share your information where:

it is necessary to deliver the service
the law requires us to
it is needed to protect someone at risk
you have given explicit consent for optional communications (for example, tenant newsletters featuring your photo or comments)

Data Processors

We use data processors to support the delivery and administration of Housing Management services. Data processors act on behalf of the Council and process personal information only in accordance with our instructions. They are required to keep information secure and are not permitted to use personal information for their own purposes.

The data processors used for this service include:

Repairs and maintenance contractor

Liberty provides housing repairs and maintenance services on behalf of the Council. Personal data is shared with Liberty only where necessary to arrange, manage and complete repairs and maintenance work at Council‑managed properties. This includes information needed to schedule visits, access properties, complete works and return completion or compliance information to the Council. Information is shared on a job‑specific basis and is limited to what is required to deliver the repair safely and effectively.

Housing management system

An internal housing management system is used to manage tenancy and property‑related activities, such as rent accounts, repairs and maintenance, tenant engagement, and the recording of issues such as anti‑social behaviour. Access to the system is restricted to authorised staff and information is managed in line with the Council’s information governance policies.

Online repairs reporting tools

Online reporting tools may be used to allow tenants or residents to report repairs to the Council. These tools collect only the information needed to raise and progress repair requests.

Customer contact and case management systems

Internal systems are used to record and manage contact with tenants and residents, ensuring enquiries and service requests are handled consistently and appropriately.

Reporting and performance systems

Secure reporting systems are used to support service monitoring, compliance activity and contract management. These systems are accessible only to authorised staff and do not replace the Council’s main housing records.

Council‑approved IT and cloud service providers

The Council uses approved IT and cloud service providers to host systems, maintain secure infrastructure and support the safe operation of the digital tools used to deliver Housing Management services.

All data processors acting on behalf of the Council are contractually required to apply appropriate technical and organisational security measures, restrict access to authorised staff only, and comply with data protection legislation.

Data Controller

We are the Data Controllers for this processing.

The Lawful Basis for Processing

We process your personal information so we can provide Housing Management Services and fulfil our responsibilities as a social landlord. Under the UK GDPR, we rely on the following lawful bases:

Personal Data

UK GDPR Article 6(1)(b) – Contract:

We process your personal information because it is necessary to enter into, manage, and fulfil your tenancy agreement or licence with us. This includes activities such as:

assessing your housing application
managing your tenancy
arranging repairs and maintenance
managing rent accounts and service charges
responding to your enquiries or complaints
taking action where tenancy conditions are not met

Where you hold a tenancy with us, this is the main lawful basis for most of the information we use.

UK GDPR Article 6(1)(c) – Legal Obligation:

We process information where the law requires us to do so. This includes obligations under housing, homelessness, health and safety, safeguarding, equality, fraud prevention, and financial legislation. Examples include:

carrying out gas and electrical safety checks
investigating safeguarding concerns
preventing and detecting tenancy fraud
responding to court orders or statutory requests
fulfilling our duties under housing and homelessness legislation

UK GDPR Article 6(1)(e) – Public Task:

We process information where it is necessary to perform our official functions as a local housing authority, such as:

assessing housing need and making allocation decisions
delivering homelessness prevention and relief duties
managing anti‑social behaviour and community safety issues
maintaining safe and well‑managed housing stock

These functions are set out in housing and local government legislation.

Special Category Data

We only process special category data (such as health or safeguarding information) where it is necessary, proportionate, and lawful.

UK GDPR Article 9(2)(b) – Social Security and Social Protection:

Where processing is required to meet obligations relating to tenancy sustainment, supporting vulnerable residents, or assessing additional needs.

UK GDPR Article 9(2)(g) – Substantial Public Interest:

Supported by the Data Protection Act 2018 Schedule 1, for purposes such as:

safeguarding individuals at risk
preventing or detecting unlawful acts
supporting individuals with disabilities or medical conditions
equality of opportunity or treatment
protecting the public

When we rely on consent

We do not rely on consent to process information needed to manage your tenancy, assess your housing needs, or fulfil our legal or statutory duties.

We will only rely on consent where the processing is genuinely optional, for example:

using your name, photo, or comments in newsletters or tenant engagement material, you can withdraw this consent at any time

The legislation we rely on when using your personal information to meet our legal obligations or public tasks includes but is not limited to:

Housing Act 1996 (Parts VI and VII) – allocations and homelessness duties
Homelessness Reduction Act 2017 – prevention and relief duties
Housing Act 1985 – local housing authority functions
Local Government Act 1972 and Local Government Act 2000 – governance and service delivery powers
Equality Act 2010 (s.149) – Public Sector Equality Duty
Care Act 2014 – safeguarding and social care duties
Anti-social Behaviour, Crime and Policing Act 2014 – community safety and tenancy management
Protection of Freedoms Act 2012 – Surveillance Camera Code of Practice

International Data Transfers

Housing Management Services mainly store and process personal information within the United Kingdom. In most cases, your information will not be transferred outside the UK. However, there are situations where international transfers may be necessary to support you, your household, or your housing application. These situations may include:

When international transfers may occur

Supporting people arriving from another country

If you have recently arrived in the UK, we may need to request relevant information from overseas authorities, agencies, or organisations to understand your circumstances and support your housing needs. This may include identity documents, proof of household composition, or information about vulnerabilities or risks.

Working with asylum seekers, refugees, or people with no recourse to public funds

Where appropriate, and only where lawful, we may need to share information with UK‑based partners who themselves access information from international bodies. This may help ensure your safety, identify support needs, or verify essential information.

When you are moving to, or returning to, another country

If you tell us you are relocating abroad, we may need to share limited information with a housing authority, support organisation, or legal representative in that country to confirm your tenancy status or resolve outstanding housing matters.

When an overseas organisation is directly involved in supporting you

In some cases, charities, support agencies, or family representatives based outside the UK may be involved in helping you. Information is only shared where necessary, and only where an appropriate safeguard is in place.

How we protect your information during international transfers

Whenever personal data is transferred outside the UK, we ensure your information remains secure and protected. We use one or more of the following safeguards:

Adequacy decisions: Only transferring data to countries the UK Government has assessed as providing an appropriate level of data protection
Standard Contractual Clauses (SCCs) or International Data Transfer Agreements (IDTAs): Legally‑binding safeguards used when sharing information with organisations in countries without an adequacy decision
Technical and organisational measures: Such as encryption, secure email, controlled access, and strict handling procedures
Careful assessment of the request: Ensuring the transfer is necessary, proportionate, and in your best interests

Transfers based on your request

If information needs to be shared internationally because you ask us to, for example to support relocation, family contact, or representation overseas, we will explain what information is required and may request your written consent before sharing it. Consent is never relied on for statutory housing functions, only where the transfer is genuinely optional.

Retention Period

We keep your personal information only for as long as it is needed to deliver Housing Management Services, meet our legal and contractual responsibilities, and respond to any queries, complaints, or legal challenges. The retention periods we apply follow the Council’s Corporate Retention Schedule.

The main retention periods for housing‑related records are:

Tenancy Management Records

Information relating to managing your tenancy, including tenancy agreements, rent accounts, correspondence, tenancy breaches, visits, and case notes, is kept for:

7 years after your tenancy ends (ordinary agreements)
12 years after your tenancy ends (agreements signed under seal)

This includes records relating to rent arrears, tenancy enforcement, and day‑to‑day tenancy management.

Housing Applications, Allocations, and the Housing Register

Housing applications (successful or unsuccessful): kept for 7 years
Successful allocations: retained for 12 years
Housing Register records: retained permanently, as this is our statutory record of housing need and allocations

Homelessness and Prevention Records

Records relating to homelessness applications, prevention and relief duties, placements, decision letters, and casework are retained for:

7 years after the case is closed

Repairs, Maintenance, and Property Records

Repairs and maintenance records (including contractor feedback, property inspections, works orders):

retained for 12 years

Asbestos records (where held for housing stock):

retained for 75 years

Property adaptations records:

normally retained for 5 years

Anti‑Social Behaviour and Community Safety Records

ASB investigations, neighbour disputes, and case management:

retained for 7 years after closure

ASB orders or injunctions:

retained for 7 years after the order ends

Right to Buy and Leasehold Matters

Right to Buy documents (including applications and completion records):

retained for 12 years after closure

Leasehold and property conveyancing records:

retained for 12 years

Estate Management Records

Garage rentals: retained for 12 years after the rental ends
Estate inspections: retained for 5 years
Neighbour disputes (not ASB): retained for 7 years

Contractor and Service Delivery Partners

Records relating to contractors, repairs operatives, call‑handling services, and system providers are retained in line with our contract management schedule:

7 years for contracts not under seal
12 years for contracts signed under seal

If your information is used for reporting or research

Where information is used to produce reports, statistics, or service‑improvement analysis, it is anonymised so you cannot be identified. Any handwritten notes or working documents used during assessments or visits are securely destroyed once they are no longer needed.

Exceptional circumstances

We may retain information for longer when:

there is an ongoing complaint, legal claim, or investigation
safeguarding concerns require extended retention
legislation requires a longer retention period

Any such decision follows our Records Management Policy.

Your Rights

The UK GDPR provides you with a several rights to control what personal information is used by us and how it is used by us.

Further guidance about these rights can be accessed from the Information Commissioner’s Office (ICO) website.

If you are not happy about the way your personal data is being used, or you require further information about how we process your personal data, you can contact Council’s Data Protection Team:-

Online: Contact the DPO
By post: Data Protection Officer, The Portal, Wellington Road, Ellesmere Port, CH65 0BA

You also have the right to complain to the Information Commissioner’s Office using the following details:

Website: Information Commissioner's Office (ICO)
Instant Message: Live Chat
By post: The Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113