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Privacy Notice

Privacy Notice


1. Scope

This privacy notice relates to the Preventing Homelessness Improving Lives (PHIL) homelessness prevention service. It applies to information provided by post, email, telephone and the online service accessible via


2. Privacy notice


2.1 The data controller

The data controller for the Preventing Homelessness Improving Lives (PHIL) homelessness prevention service is:

Rugby Borough Council

Town Hall

Evreux Way,

Rugby CV21 2RR

United Kingdom


We will store the data in our housing management system and restrict access according to our data security policies.


2.2 Personal data

The personal data we would like to collect from you is the information that we ask for during the application process. We will use this data for the following purposes:

• To provide a self-service account for you to access the service;

• To create a customer record that allows us to link details of service requests to your information;

• To refer you to housing support services, should this be appropriate.

• To refer you to another authority to manage your housing application, if you make one.


2.3 Legal basis

The processing is necessary so that we can create an account at your request; or in order for us to provide a service that you have requested. Data protection law describes our legal basis as performance of a task carried out in the public interest.


If you do not provide the information we ask for we may not be able to provide the service that you need.


We may need to collect special categories of personal data in order to assess your eligibility for housing. Data protection law describes this exemption as being of substantial public interest.


2.4 Consent

We do not need your consent to collect or process your personal information in relation to the homelessness prevention service. This is because we need the information to provide you with the services that you have requested.


2.5 Disclosure

Rugby Borough Council may pass on your personal data to third parties for the purposes of detecting or preventing fraud or other crime, or if it is necessary to provide the service that you have requested. These organisations may include North Warwickshire Borough Council, Nuneaton and Bedworth Borough Council, Stratford District Council, Warwick District Council, Warwickshire County Council, Warwickshire Police, the Department of Work and Pensions, or any other organisation where we are required by law to share information.


The council has a data processing contract with Civica whose systems will hold your data in a secure location in the UK, hosted by trusted partners

They are only permitted to process your data in accordance with our written instructions in order to provide you with the services you need.


If you ask us to, we will pass your details to landlords so that they can manage any offer of housing.


2.6 Retention period

Rugby Borough Council will process personal data for the period it takes to provide you with the service that you have requested. We will keep your data for a period of 2 years after your account was last active.


2.7 Automated processing

We may use software systems to analyse your circumstances. We use this information to provide you with tailored advice and support. If you believe this information is wrong you can ask us to check it manually.


2.8 Your rights as a data subject

You have the right:

• to request a copy of the information that we hold about you;

• to correct data that we hold about you that is inaccurate or incomplete;

• in certain circumstances you can ask for the data we hold about you to be erased from our records;

• where certain conditions apply to have a right to restrict the processing;

• in some circumstances, to have the data we hold about you transferred to another organisation;

• to object to certain types of processing such as direct marketing;

• to ask us to reconsider any automated decisions;

• to complain if we refuse a request you may make using these rights and you are not happy with our reason.


We may refer any request you may make using these rights to another organisation, if they have been involved in processing your personal data.


2.9 Complaints

If you are unhappy about how we are handling your personal data you can complain to the Data Protection Officer. You can also complain to the Information Commissioner’s Office.


The details for each of these contacts are:


The Data Protection Officer, Rugby Borough Council, Town Hall, Evreux Way, Rugby, United Kingdom, CV21 2RR


Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, United Kingdom, SK9 5AF, or 01625 545745



3.0 Updates to this notice


This privacy notice was last updated on 22 March 2018.


4.0 More information


You can find more information about how we use personal information and your rights at