What this privacy notice is for

Our core data protection obligations and commitments are set out in the council’s primary privacy notice at:

• Data Protection

Updating our privacy notices

We may update or revise our privacy notices at any time so please refer to the version published on our website for the most up-to-date details

What we use your information for

We collect or obtain your personal information to administer and enforce the collection of:

• Non-Domestic Rates (also known as Business Rates),
• Housing Benefit Overpayments,
• Sundry Debts (often referred to as Miscellaneous Invoices or Accounts Receivable,

We may share your information with other departments within the Council if there is a legal basis to do so for the purposes of delivering other Council activities. Where this happens, data-sharing agreements are in place to control the use of this data.

What categories of personal information we use

Personal information can be anything that identifies and relates to a living person. This can include information that when linked with other information, allows a person to be uniquely identified. For example, this could be your name and contact details.

The law treats some types of personal information as ‘special’ because the information requires more protection due to its sensitivity. This information consists of:

• Racial or ethnic origin
• Sexuality and sexual life
• Religious or philosophical beliefs
• Trade union membership
• Political opinions
• Genetic and bio-metric data
• Physical or mental health
• Criminal convictions and offences

In order to carry out these purposes we collect and obtain the following personal information.

Legal basis for processing

Oldham Council has a statutory responsibility to provide services that administer and enforce the collection of local taxation and miscellaneous debts.

The legal basis for processing and or sharing your personal information is article 6(1) (c) and 6(1) (e) of the General Data Protection Regulations.

The legal basis for each Revenues Service is set out in the table below:

If you fail to provide certain information when requested, we may be prevented from complying with our legal obligations to administer and collect outstanding monies owed to the Council. Similarly, in not providing your information you may find yourself subject to legal and debt recovery proceedings.

Information sharing/recipients

We may share personal information about you with the following organisations:

• Council contracted external Enforcement Agents, Debt Collection and/ or Tracing Agencies, external solicitors: If you have accrued arrears and we have been unsuccessful in recovering any monies owed or you have absconded without providing a forwarding address.

• Telecommunication/SMS Messaging service provider: If we hold contact details for you and you have missed a payment, or we you need you to contact us we may use a provider to issue you a message via SMS text or email.

• Our software providers may have to access to our revenues systems on occasion where there is a fault, to perform necessary upgrades, or to host information on our behalf. Our current software providers are:
  • Capita PLC – We use Capita Advantage to administer and enforce the collection of, Non-Domestic Rates, and Housing Benefit Overpayments. We also use Capita One Digital for our online services.
  • Unit 4 – We use the Unit 4 A1 system to administer and enforce the collection of sundry invoices.
  • Civica Group – We use Civica Collect to administer the collection of arrears through Council-employed Enforcement Agents. Without the use of this software, the Council wouldn’t be able to use internal Enforcement Agents to collect arrears. Civica Collect also allows the Council to send SMS text message reminders to residents or businesses to request they contact prior to arrears being passed to Enforcement If you have not made payments as required we may also share information with our software provider to enable us to issue SMS text message reminders.
• Local Government and Social Care Ombudsman: We may share information when requested as part of any ongoing complaint investigation.
• HM Courts and Tribunals Service (HMCTS): If we are required to take legal action to recover the monies you owe, we will share necessary information with the HMCTS to ensure legal proceedings commence.
• Valuation Tribunal (VT): We may share information when requested as part of a VT appeal.
• Credit Reference Agencies: We may share your details to assess the ability to repay in order to apply the most appropriate recovery option if you do not pay as billed
• Department for Works and Pensions: we may share your details for the purpose of requesting a deduction from your benefits for unpaid arrears.
• Your employer: we may share your details for the purpose of requesting an attachment to your earnings.
• Valuation Office Agency: We may share details of occupancy or a material change of circumstances for Non-Domestic properties.
• Printing and Mailing Companies: We may share your details for the purposes of issuing printed correspondence. e.g. Bills, invoices, reminders, and state aid notifications
• Destin Solutions Ltd: provide software to analyse business rates data, andcross check business rates relief on non-domestic properties (excluding empty rate relief).
• Ascendant Solutions Ltd: for the provision of online business rates forms. Data is shared to enable validation of information provided by the user during completion. This is to prevent fraudulent claims for business rates relief and reduce the time spent by Council Officers validating the information upon receipt.
• Cabinet Office: We participate in the Cabinet Office’s National Fraud Initiative, a data-matching exercise to assist in the prevention and detection of fraud. We are required to provide particular sets of data to the Minister for the Cabinet Office for matching for each exercise. This data may then be passed on to other public bodies to investigate any matches.
• Any other Central Government department where we have a legal obligation to do so, or where a Data Sharing Agreement is in place to enable the administration of Government initiatives requiring the use of our records.

We may share your information with other departments within the Council if there is a legal basis to do so. Where this happens frequently, data-sharing agreements are in place to control the use of this data. These services currently include:

• Environment Health: to support housing enforcement activities in relation to empty properties subject to legal action due to disrepair or abandonment.
• Support and Inclusion Team (SIT): To support residents who have been identified as having needs beyond one-off crisis support with tailored support, signposting and referrals.
• The Audit and Counter Fraud Team: in order to prevent and detect fraud and help protect public monies.

If you provide another person or organisation authority to discuss or to act on your behalf in revenues matters we may share information with them. In all cases we would require evidence you had granted authority before any information is shared.

We may be asked to provide access to personal information by relevant authorities with regulatory powers such as the police, government departments and other local authorities for the purposes of the prevention or detection of crime and/or the apprehension or prosecution of offenders without the permission of the data subject. The Council will consider such requests on a case-by-case basis.

As well as information collected directly from you, we may also obtain or receive information from:

• Letting Agents: To provide confirmation of occupation and vacation dates for tenants.
• Solicitors: If they obtain relevant information in relation to you whilst acting on our behalf to recover monies owed.
• Debt Collection, and Tracing Agencies: If you have accrued arrears and we have been unsuccessful in recovering any monies owed or you have absconded without providing a forwarding address we may issue cases to external companies. If these companies obtain relevant information about you or contact details, they may share this information with us.
• Landlords: To provide confirmation of occupation and vacation dates for tenants
• Department of Work and Pensions: To obtain confirmation of any deductions from benefit in place.
• Valuation Office Agency: If they make any amendments to the rating list.
• Other Council Services: To keep our records up to date and to preventand identify 

Data Transfers beyond the European Economic Area

We do not transfer any of your personal information outside the European Economic Area (‘EEA’).

Automated Decisions

All the decisions we make through the processing of your personal data involve human intervention.

Our Guide to Exercising Your Rights outlines the procedure to ask us for an automated decision to be reviewed by an appropriate officer. This can be found at: 

• Your Data Rights

How long do we keep your data?

We will only keep your information for as long as it is required by us or other regulatory bodies in order to comply with legal and regulatory requirements or for other operational reasons. In most cases this will be a minimum of six years.

Where can I get advice?

More information on how to seek advice in order to exercise your rights, raise a concern, or complain about the handling of your personal information by the council can be found in the council’s privacy notice which can be found at:

• Data Protection