First Homes privacy statement

Cheltenham Borough Council (hereby referred to as CBC or the council), as the data controller for the personal information you provide when applying for your First Homes scheme, is committed to protecting and respecting your privacy.

This privacy notice explains how we collect, use, store, and share your personal data when administering our First Homes scheme.

What information we collect

CBC may collect and process the following types of personal data or information to administer First Homes services:

First home applicant name(s)
Date of birth
Current and proposed address
Occupation
Email address
Contact telephone number
Whether you are a first-time buyer
Financial information, such as your household income, confirmation of mortgage lending in principle, reservation fee paid, deposit amount, discounted property price, mortgage amount and lender
Identification documents related to home purchase.
Title registration

We may also collect other information you provide during your application, enquiry, or correspondence.

Why we collect your information

CBC collect and use your information to:

Administer and assess eligibility for the First Homes scheme.
Verify identity, income, and mortgage details.
Recorded and managed property sales and related transactions.
Meet legal and regulatory obligations.
Respond to your enquiries, feedback, or complaints.

Why we collect your information (lawful basis for processing)

Article 6(1)(e) – Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the council.
Article 6(1)(c) – Processing is necessary to comply with legal obligations, including requirements under the Town and Country Planning Act 1990 (Section 106 agreements) relating to affordable housing.
Article 6(1)(a) – Consent, where we seek your feedback or invite you to participate in surveys.

First Homes is a form of affordable home ownership with local eligibility criteria set by the council. The discount, eligibility conditions, and terms of use are secured through a Section 106 agreement under the Town and Country Planning Act 1990.

Where we request your views or feedback on the scheme, participation will be voluntary, and our lawful basis for processing will be Article 6(1)(a) – consent.

Where we get personal information from

CBC collect personal data from the following sources:

You – When you contact us, apply for First Homes, or engage with CBC.
Legal and judicial sector organisations – For compliance with housing regulations.
Developers and their legal representatives – As part of housing agreements.

Who we share your information with

CBC may share your personal data with:

Cheltenham Borough Council’s internal teams – To provide relevant services.
One Legal (CBC’s legal services provider) – To ensure legal compliance.
Regulatory bodies – If required by law.
Other public authorities, such as the Ministry of Housing, Communities and Local Government (MHCLG) – which may ask the council for data relating to the scheme, this information will be provided anonymously as far as possible

We only share data where lawful and proportionate. CBC does not sell personal data to third parties.

How long we keep your information (data retention period)

We will only keep as much personal data as we need for administering the first homes/ discounted market housing scheme

Information will be retained for the scheme's lifetime, or until six years after you sell the property.
Information for planning and statistical purposes may be retained for up to five years after collection.

When information is no longer required, it will be securely deleted or anonymised in accordance with the council's data retention policy.

How we safeguard your information (data security)

Your personal data is stored securely on our systems and accessed only by authorised officers using individual logins, their own username and password created in line with pre-defined user credentials.

Personal data is also held in electronic files on the council’s network drives. These are only accessible through personal login credentials and access privileges to specific drives. Access to our council sites require a personal electronic pass to access staff only areas.

The council has strict procedures for the way this is done. Any and all information about you is treated as confidential and with respect. There are also clear rules and guidance about storing, recording and sharing information which staff receive training on.

International data transfers

We do not routinely transfer your personal data outside the UK. If an international transfer is necessary, we will notify you and ensure your data is protected to UK standards.

However, if data needs to be transferred internationally (e.g., to third-party service providers using cloud storage), we ensure:

Adequate safeguards are in place, such as:

UK data protection agreements with relevant entities.
International data transfer agreements (IDTAs) in compliance with UK GDPR.
UK government-approved adequacy decisions (where applicable).

Your data protection rights

Under UK GDPR, you have the following rights regarding your personal data:

Right of access – Request copies of your data.
Right to rectification – Ask for corrections to inaccurate data.
Right to erasure – Request deletion of your data (subject to legal exemptions).
Right to restrict processing – Limit how we use your data.
Right to object – Object to processing under "public task" or "legitimate interest."
Right to data portability – Request transfer of your data to another organisation.
Right to withdraw consent – If consent is the legal basis, you can withdraw it anytime.

If you make a right of access request, we will respond within one month.

How to contact us

For general First Homes enquiries email [email protected].

For data protection queries specific to the First Homes scheme email [email protected].

For general data protection enquiries email [email protected].

How to complain

If you are unhappy with how we handle your data, you can make a complaint using the contact details above.

If you remain dissatisfied, you can escalate your complaint to the Information Commissioner’s Office (ICO):

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

Helpline: 0303 123 1113

Website: www.ico.org.uk/make-a-complaint

Updates to this privacy notice

We may update this privacy notice occasionally to reflect legislation or council procedure changes.

The most recent version will always be available on the Cheltenham Borough Council website.