Privacy notice: Customer relations

The London Borough of Hounslow is committed to protecting and respecting your privacy. Through this Privacy Notice we have sought to be as transparent as possible and fully explain how your personal data is held and processed.

This privacy notice applies to services provided by Customer Relations and tells you what to expect us to do with your personal information.

If you have any questions about this privacy notice or any concerns about how we process your data, please contact dataprotection@hounslow.gov.uk.

The privacy notice will continue to be monitored and updated. You are advised to check this page from time to time.

What type of information we have?

We currently collect and process the following information:

  • When you contact us by phone, email or through the Council’s website we may need to collect personal information about you or your family so that the appropriate service can be provided. The information we require from you may include personal information, such as:

    • Contact details – Title, first name, last name, address, email address, telephone number etc.
    • Date of birth
    • Proof of Identity (documents dated within 3 months to prove who you are)
    • Council services receive or enquiring about
    • Financial details for purposes of receiving or making payments (bank account details)
    • Housing information relating to your council tenancy
    • Historical information e.g., Subject Access Requests, Freedom of Information, Environmental Information Requests, complaints (if relevant)

We may also collect special categories of personal data that may include:

  • Racial or ethnic origin
  • Political opinions
  • Religious or philosophical beliefs
  • Trade union membership
  • Genetic data
  • Biometric data (where used for identification purposes)
  • Health data
  • Data concerning a person’s sex life
  • Data concerning a person’s sexual orientation

Additionally, we may process data relating to criminal convictions and offences, including allegations, proceedings, and outcomes. This type of data may be present in complaints, safeguarding concerns, regulatory investigations, or other interactions with the authority. Such data is handled with the highest level of confidentiality and in accordance with the UK GDPR and the Data Protection Act 2018.

It will only be necessary to collect this type of information where it is of relevance to the request you are making.

For the definition and examples of personal data please visit the ICO website.

How do we get your information?

Most of the personal information we process is provided to us directly by you for one of the following reasons:

  • General enquiries from members of the public
  • Complaint about a council service
  • Freedom of Information request (FOI), Environment Information Requests (EIR) and Subject Access Request (SAR).

This list is not exhaustive.

We also receive personal information indirectly from:

  • Elected Council members (Councillors)
  • Local Government and Social Care Ombudsman & Housing Ombudsman
  • Information Commissioner’s Office
  • Local Members of Parliament/Members of European Parliament (MPs)
  • Other Local Authorities
  • External agencies e.g Police, Solicitors, Investigating Officers, Advocacy groups, Housing Associations

This is not an exhaustive list.

If it is not disproportionate or prejudicial, we’ll contact you to let you know we are processing your personal information. ​

Our Lawful basis for processing your information

The lawful basis we rely on processing information includes Legal obligation or public task under various UK legislation including but not limited to:

  • Local Government Act
  • Localism Act 2011
  • Mental Capacity Act 2005
  • Mental Health Act 1983, 2007
  • Local Safeguarding Children & Adults Boards Regulations 2006
  • Care Act 2014
  • Crime and Disorder Act 1998
  • Welfare Reform Act 2012

For example, in relation to responding to freedom of information and data subject requests, the legal basis for processing your personal data, is legal obligation, as it is necessary to fulfil our responsibilities as a public authority and data controller.

 in relation to compliant from members of the public, processing is necessary for us to perform a task in the public interest under various UK legislation including but not limited to

  • Local Authority Social Services Complaints (England) Regulations 2006
  • The Care Act 2014

If the information you provide us contains special category data, such as health, religious or ethnic information the legal basis we rely on is reasons of substantial public interest.

As we are relying on the substantial public interest condition, we also need to meet one of the specific substantial public interest conditions set out in the DPA 2018. The service is therefore relying on:

Statutory and government purposes

  • Fulfilling the Council’s obligations under UK legislation for the provision of services to residents and partners. Complying with other legal requirements, such as the requirement to disclose information in connection with legal proceedings.

Use of Third-Party Cloud Provider for Data Subject Requests

To support the processing of data subject access requests (SARs) in compliance with our obligations under the UK General Data Protection Regulation (UK GDPR), we utilise a third-party cloud-based solution provided by Smartbox.ai. This tool assists in the secure and efficient redaction of documents prior to disclosure. Manual involvement is still to be used alongside this tool.

The following measures are in place to ensure data protection and compliance:

  • Purpose of Processing: Smartbox.ai is used solely to facilitate the redaction of personal data in response to SARs. The data processed through this service is not used for any other purpose.
  • Data Security and Location: All data processed via Smartbox.ai is stored securely within UK-based Amazon Web Services (AWS) data centres. Smartbox.ai operates under a contractual agreement with the Council, which includes robust data protection and confidentiality provisions.
  • Data Retention and Deletion: Data processed through Smartbox.ai is securely deleted following completion of the redaction process and is not retained beyond what is necessary for fulfilling the SAR.

We remain committed to ensuring the privacy and security of personal data and regularly review our processing arrangements to maintain compliance with data protection legislation.

Why we need your information (purposes of processing)

The personal data we collect will be processed for the following purposes:

  • To communicate and consult with you when you contact us
  • Investigating complaints
  • Freedom of Information Request (FOI)
  • Environmental Information Request (EIR)
  • Subject Access Request (SAR)
  • Exercising GDPR rights such as: right to be informed; right to rectification; right to erasure; right to restrict processing
  • To respond to general enquiries from residents, Members, MP/MEPs, Ombudsman, Information Commissioners Office (ICO)

This is not an exhaustive list.

Who your information may be shared with (internally and externally)?

The information you provide may be used within other departments of the council to provide a complete service to you. We may share your information with:

  • Partners providing a service on behalf of the Council

  • Local Government and Social Care Ombudsman & Housing Ombudsman
  • Information Governance team
  • Relevant Council department and/or Councillor to respond to your request
  • Local Members of Parliament (MPs)/Members of European Parliament (MEPs)
  • Other Local Authorities
  • External agencies e.g., Police, Solicitors, Investigating Officers, Advocacy groups, Housing Associations
  • IT system providers for the purposes of support and maintenance
  • Independent investigating officers and panel members (for Children’s Statutory Complaints)

This list is not exhaustive and there may be other parties who we may need to share your information with to process your request(s).

We will strive to ensure that any personal data in our care will be kept safe and that where your information is disclosed to a third party working on our behalf, we will seek to ensure that they have sufficient systems and procedures in place to prevent the loss or damage of personal data.

How long we keep your information

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. We keep data as per the following retention schedule below.

Record

Retention Period

Electronic case records relating to Information requests, Corporate Complaints, Member and MP enquiries, Local Government & Social Care and Housing Ombudsman enquiries, Adults and Children’s Statutory Complaints

7 years

Emails received by generic email mailbox e.g. feedback, FOI, recycling, complaints, data protection and LGO (for Ombudsman enquiries)

3 years

We will then dispose your information in the most secure manner possible. Information collected by customer services for services provided by other Council departments is kept as long as respective service areas data retention schedules, available in their privacy notice.

Transfers to third countries

All the information you provide us is held within the UK and European Economic Area

Your data protection rights

The rights available to you depend on our reason for processing your information. For further information about your data protection rights and how to make a request, please see ‘Your rights’

Your right to make a complaint

The Council tries to meet the highest standards when collecting and using personal information. For this reason, we take any concerns we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading, or inappropriate. If you want to raise a concern you can contact us on:

Customer Relations Team
London Borough of Hounslow
Hounslow House,
7 Bath Road,
TW3 3EB

Data Protection Officer

The Council’s Data Protection Officer can be contacted on:

Email InformationGovernance@hounslow.gov.uk

Information Governance Team
London Borough of Hounslow
Hounslow House,
7 Bath Road,
TW3 3EB

Information Commissioner’s Office

The Information Commissioner is the UK's independent body set up to uphold information rights.

If you would like to know more about your rights under the Data Protection law, and what you should expect, visit the Information Commissioner’s website.

If you have any concerns regarding any privacy practices or about exercising your Data Protection rights, you may contact the Information Commissioner’s Office:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow Cheshire
SK9 5AF

Telephone: 0303 123 1113 or 01625 545 745

Email:  icocasework@ico.org.uk

A full list of what information we control and process and for what purposes is set out in our notification with the Information Commissioner's Register of Data Controllers. Our registration number is Z5761176.  You can view our registration on the Information Commissioner's website.

Rate this page