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 - web pages

This notice provides additional privacy information for:

• The Council Housing Services outsourced to two PFI Special Purpose Vehicles, Oldham Retirement Housing Partnership and Inspiral.

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 do we use your information for?

We collect or obtain your personal information for the following purpose(s):

• To enable the Council to deliver and discharge it’s Council Housing Landlord functions for the demolition and new build or refurbishment and the provision of management and maintenance services to sheltered, supported, warden controlled and general needs properties in Oldham Metropolitan Borough Council’s Housing Revenue Account pursuant to the Government’s Private Finance Initiative.

What categories of personal information do 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 biometric 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

The legal basis for processing and or sharing your personal information is dependent on what we use your information for, these may include, but are not limited to: 

• Where you consent to participate in consultation or research
• Where we have a legal obligation or it is in either the public of our legitimate interest

Examples of legislation that support this are listed below:

• Housing Act 1985 – Section 9, Section 10, Section 21, Section 27
• Local Government (Contracts) Act 1997 – Section 1
• Local Government Act 1972 – Section 3
• Local Government Act 1997 – Section 3
• Local Government Act 1999
• The Care Act 2014
• The Public Services (Social Value) Act 2012 – Subsection 7
• Local Government and Public Involvement in Health Act (s138)
• Race and Sex Discrimination Act 1976
• Equality Act 2010
• Town and Country Planning Act 1990

The legal basis for processing and or sharing your personal information is: 

The Authority instructs Oldham Housing Retirement Partnership Limited and Inspiral Limited through the PFI project agreements to process Authority Personal Data for the purpose of carrying out the services in the Project Agreement including in particular the following:

1. Administering and managing the process of transferring Tenants to alternative accommodation whilst improvements to their property takes place, and returning them home.
2. Assessing and maintaining the health, wellbeing and care of Tenants;
3. Administering the Project Agreement;
4. Managing the Project Agreement;
5. Providing any information required to complete key performance and/or best value indicators in relation to the Project Agreement as required by central government;
6. Managing Tenants and/or Tenancies; and
7. Managing Tenanted properties.

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (for example your tenancy agreement), or we may be prevented from complying with our legal obligations (to meet our statutory landlord obligations under the Housing Act 1985 or our obligations under the PFI Project Agreements).

Information sharing/recipients

We will share information for the following purposes:

• To inform First Choice Homes Oldham (FCHO) that a property is on notice or void and should be advertised.
• FCHO will provide Housing and Care 21 and Great Places Housing Group with details of applicants who have submitted a bid for a property
• Housing and Care 21 and Great Places Housing Group will inform FCHO that a property has been let.
• Housing and Care 21 will inform Cruden that a day to day repair is required to be carried out at a property.
• Great Places Housing Group will inform Wates that a day to day repair is required to be carried out at a property.
• Wates will advise Great Places Housing Group that a repair has been completed,
• Cruden will advise Housing and Care 21 that a repair has been completed,
• Housing and Care 21 and Great Places Housing Group will provide Wates and Cruden with details of assignments, successions, decants, new joint tenants or where a joint tenant has left to enable repairs and application information to be kept up to date.
• Housing and Care 21 and Great Places will provide FCHO with details of tenants who require Home Contents insurance provided by AON.
• Housing and Care 21 and Great Places Housing Group will inform FCHO when a property has been adapted so that the property database is kept up to date.
• Housing and Care 21 and Great Places will inform Wates and Cruden when a property has been improved so that the property data base is kept up to date.
• Housing and Care 21 and Great Places will request weekly rent details for new or re-designated properties (upon refurbishment or enlargement or new build)
• Housing and Care 21 and Great Places will provide a weekly Tenant’s Rent Account and reconciliation to the Council for the purposes of the HRA business plan.
• Wates and Crudens will send monthly invoices for property maintenance contract costs to Housing and Care 21 and Great Places Housing Group.
• Housing and Care 21 and Inspiral will provide full workings/calculations with monthly performance information with monthly unitary charge invoices to the Council.
• Data files will be sent to Data store to update Housing Benefits system to enable Housing and Care 21 and Great Places to view Housing Benefit clients.
• Data file sent to data store to inform Housing benefits system of client details and charges to be used in the benefit payments run.
• Data file sent to Data store to inform Supporting People of all Housing and Care 21 clients.
• To share personal and sensitive data with the Council Adult, Children’s and Social Care services, Community Occupational Therapy Team, Pennine Care, Oldham CCG and NHS Oldham Trusts to facilitate temporary or permanent moves of residents and to ensure that tenants remain safe and in receipt of appropriate care by sharing single assessment paper or electronic documentation and Adult Social and Children services database information in line with data protection.
• To share personal and sensitive data to ensure the Health and Safety of staff of provider organisations and carers by the sharing of Adult Social Care database warning indicator information in line with data protection.
• To share personal data

We may share personal aggregated data for statistical purposes with the following:

• Other parts of Oldham Council

• Healthcare, Social and Welfare organisations
• Providers of goods and services
• Service providers
• Local and Central government
• Survey and research organisations
• Data processors
• Healthcare professionals

Identifiable Personal Information could be shared under the following circumstances:

• Safeguarding, if something you tell us raises a safeguarding concern
• You raise a specific personal issue or concern that requires addressing
• You ask us to share your personal details

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

• Other parts of the local Authority or NHS Oldham for safeguarding purposes as outlined above
• HM treasury, Ministry for Housing, Communities and Local Government and Homes England for the purposes of PFI contract monitoring requirements under our best value obligations.

Data Transfers beyond 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 about you involve human intervention.

How long do we keep your data?

We will only keep your personal information for as long as the law specifies or where the law does not specify this, for the length of time determined by our business requirements. This ranges from three to six years, depending on the nature of the data collected and our requirements to retain it.

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 - web page