Privacy Notice and Data Protection

This privacy notice is to be read in conjunction with the full privacy notice.

This privacy notice sets out how the Revenue and Benefits Department at the Royal Borough of Kingston will use and process your information.

What type of information is collected about you?

• contact details; including name, address, email address, telephone number
• date of birth
• proof of identity
• national identifiers such as; NHS number and NI numbers
• information about your family
• IP address and information regarding what pages are accessed and when
• lifestyle, social and personal circumstances
• the services you receive
• financial details for purposes of receiving or making payments
• employment details (when you apply for jobs
• housing information relating your Council tenancy
• visual images, personal appearance and behaviour
• licenses or permits held
• business activities
• recordings of telephone calls

We may also collect sensitive personal data that may include:

• physical or mental health details
• racial or ethnic origin
• gender and sexual orientation
• trade union membership
• political affiliation and opinions
• offences (including alleged offences)
• religious or other beliefs of a similar nature
• criminal proceedings, outcomes and sentences

We need your information for the following services and functions: 

Your information will be used for the functions of the Revenue and Benefits Department. The services we provide are:

• Housing Benefit 
• Discretionary Housing Payments
• Council Tax and the Council Tax Reduction Scheme (CTRS) 
• Business Rates
• Local Social Welfare Schemes
• Council Tax rebate (Energy Rebate)

We will also use your information for our wider functions which are: 

• the prevention and detection of benefit fraud and any other crime
• to administer non-payment claims of council tax
• to protect public funds in investigating misuse of public money

Low-Income Family Tracker Dashboard (LIFT)

As part of its response to the current cost of living crisis, the Council has engaged with an external organisation, Policy in Practice, to utilise what is known as the Low-Income Family Tracker Dashboard (LIFT).

The dashboard brings together indicators of poverty from data supplied by the Council to highlight those residents or households at risk of falling into crisis. It specifically identifies households affected by multiple welfare reforms and allows staff to identify residents and families who would benefit financially from targeted proactive engagement, rather than just reacting to people who contact the Council.

The dashboard uses information from the Council’s administrative datasets covering Housing Benefit and Council Tax Support recipients, Housing data in regard to Council tenants, Universal Credit data which the Council holds as data controller and Free School Meals data. These datasets are controlled by the Council. Policy in Practice acts as a data processor working directly with these datasets.

Given the volume of personal information involved a Data Protection Impact Assessment has been undertaken to assess the level of any risk to data subjects and to identify ways of mitigating any such risks. The work being undertaken by Policy in Practice is governed by a formal Data Processing Agreement put in place by the Council.

The lawful basis for the intended processing is set out in UK GDPR Article 6 (e) Public task: as it is necessary for the Council to process the data to enable it to carry out its statutory duties in respect of Housing Benefit and Council tax administration in support of the Council’s official functions and statutory obligations.

No data will be processed outside of the UK and there are no automated decisions or 'profiling'.

Who your information may be shared with

We may share some of your information, for example your name and address, internally with other departments in the Council if this:

• helps you to access services more easily
• promotes the more efficient and cost effective delivery of services
• helps recover monies owed to the council

We match Council Tax data with Electoral Registration records. 

We are required by law to participate in National Fraud Initiative (NFI) data matching exercises. Council Tax information may be provided to the Audit Commission for NFI purposes and will be used for cross-system and cross-authority comparison for fraud prevention and detection

We will also share our data with companies who undertake data matching exercises for Single Person Discount, this is to identify discrepancies. We share our data through LOCTA - the Local Authority Council Tax data sharing hub, who locate debtors who no longer reside in the council. For some debts, we also use external bailiff collection.  We use an external provider to process our online claims and to identify changes in circumstances.

We may also receive/share your information with:

• the Cabinet Office
• the Department for Work and Pensions (DWP)
• the Home Office
• external credit agencies
• external bailiff companies
• the Office National Statistics (ONS)
• HMRC
• the Valuation Office Agency (VOA)

The legal basis for processing your information

We have statutory authority to collect and process your personal information for the provision of our service, your consent therefore is not required to process your information. Where the service is optional, we will not process your information until you have consented to receive the service. Once we have your consent for the service, your information will be processed under our statutory authority to provide the service.

We will use your information to:

• Process housing benefit and council tax reduction claims - a legal obligation. This may include the processing of information from His Majesty’s Revenue and Customs (HMRC) and the Department for Work and Pensions (DWP) in respect of every adult member of a household that is in receipt of housing benefit. And in the case of council tax reduction only, we may use data supplied by the DWP in respect of every adult member of that household.  
• Participate in the National Fraud Initiative and other data matching exercises - a legal obligation, public task.
• Collect council tax and business rates - a legal obligation.
• Text messaging reminder service - with consent.
• Administer discretionary housing payments and local social welfare schemes - a legal obligation, public task.
• Participate in the National Fraud Initiative and other data matching exercises - a legal obligation, public task.

How long will we keep your information

We will retain your information for the period in which your information is being used for service provision or for our wider functions including debt collection. We have legal authority to process your information; your right to be forgotten does not apply to our functions and services. 

The Council Tax team records all telephone calls for quality and training purposes, and these recordings will be securely stored for a period of 12 months.