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Housing options, homelessness and related commissioned services privacy statement

Cheltenham Borough Council (hereafter referred to as “CBC” or “the council”) is committed to protecting your privacy and ensuring that your personal information is handled fairly, lawfully, and securely.

CBC collect information about you in order that we can: manage housing allocations, provide housing options and homelessness services to ensure that you are eligible for social housing and that any accommodation you may be offered will be suitable for you or your family needs.

CBC also commission a number of organisations to provide services on behalf of the council, as follows:

  • Julian House and P3 (People, Potential, Possibilities) for people who are sleeping rough or at risk of rough sleeping.
  • Citizens Advice for people seeking advice about their debt, benefits and housing rights.
  • GARAS (Gloucestershire Action for Refugees and Asylum Seekers), who provide advice and assistance to asylum seekers in connection with their claim for asylum, access into health and wellbeing services, English language courses, and community engagement.

This privacy notice explains how we collect, use, store, and protect your personal data when delivering and administering housing advice, allocations, and homelessness prevention services.

What information we collect about you

CBC and services commissioned on our behalf may collect and process the following personal information when you apply for advice and assistance in connection with the above services:

  • Name, address, and contact details (including email and telephone number)
  • Date of birth and gender
  • National Insurance number
  • Bank account details and financial statements, such as income and expenditure details, including debts and benefits you might be claiming
  • Details of dependants or household members and/or emergency contact details
  • Identity documents such as passport or driving licence
  • Employment details or benefit information
  • Information about your housing history or previous accommodation
  • Marital or relationship status
  • Case notes and support plans

We also collect ‘special category’ personal data when processing is necessary for reasons of substantial public interest.

  • Health and medical information (physical and mental health)
  • Racial or ethnic origin
  • Religious or philosophical beliefs
  • Criminal convictions and offences
  • Sexual orientation
  • Immigration status

We, and our commissioned suppliers, will only ask for the personal information that is necessary to deliver our services effectively.

In some cases, you may choose not to provide specific details; however, this may affect our ability to support you fully.

Why we collect your information

CBC and our commissioned suppliers may collect and use your information (where relevant) to:

  • Deliver and manage housing advice and homelessness services
  • Assess eligibility for social housing and homelessness assistance
  • Determine priority needs and suitability of accommodation
  • Manage applications through the HomeseekerPlus system
  • Prevent homelessness and provide support to individuals at risk
  • Process benefit or grant applications linked to housing support
  • Respond to enquiries or complaints
  • Maintain accurate records and monitor service performance
  • Provide you with tailored advice and support services
  • Assess eligibility for benefits, grants, or other financial assistance
  • Support applications for debt relief or housing schemes
  • Identify and support individuals who are rough sleeping or at risk of homelessness
  • Provide housing, support, and health-related services
  • Coordinate outreach and emergency accommodation
  • Reduce and prevent rough sleeping across Gloucestershire
  • Help reconnect rough sleepers to their area of origin or support networks
  • Verify rough sleeping numbers for reporting and commissioning
  • Support activities that promote safeguarding, public safety, and wellbeing
  • Assist with referrals for education, training, and employment opportunities
  • Provide you with tailored advice around your asylum claim
  • Assess eligibility for health and wellbeing services
  • Help to assess options for English language courses
  • Consider options for community engagement activities
  • Record the services provided and maintain case records
  • Monitor performance and quality of advice services
  • Provide anonymous statistical information to the council or government departments

Why we collect your information (lawful basis for processing)

Under the UK General Data Protection Regulation (UK GDPR), CBC must have a lawful basis for collecting and using personal data.

The lawful bases for this processing include:

  • 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 a legal obligation under legislation such as the Housing Acts, Homelessness Reduction Act 2017, and Local Government Acts.
  • Article 6(1)(a) – Consent, where you have given explicit permission (for example, where information is shared with third parties at your request).

Where special category data (such as health or ethnicity) is processed, the lawful condition is:

  • Article 9(2)(g) – Processing is necessary for reasons of substantial public interest, under Schedule 1 of the Data Protection Act 2018, including purposes of social protection, safeguarding, and equality monitoring.

Who we collect personal information from

CBC may collect your personal information from the following sources:

  • You directly, through application forms, online systems (e.g. HomeseekerPlus), emails, or phone calls
  • Other local authorities and government agencies
  • Partner organisations such as housing associations, social care, or support providers
  • Health and welfare services
  • Our commissioned services, either with your consent or where it is in the public interest
  • Police, probation, or other law enforcement agencies
  • Contractors or agents working on behalf of CBC
  • Members of the public who may provide information relevant to your case
  • Other advice or support agencies (with your consent)
  • Friends, relatives, or members of the public providing relevant information about rough sleeping

Who we share your information with

CBC may share your personal data lawfully and securely with:

  • Other departments within Cheltenham Borough Council involved in service delivery
  • Local housing authorities and social landlords
  • Gloucestershire County Council (including social care and safeguarding agencies), National Health Service (NHS) and local health services
  • Police and emergency services
  • Government departments such as the Department for Work and Pensions (DWP), HM Revenue and Customs (HMRC), and the Ministry of Housing, Communities and Local Government (MHCLG)
  • Partner organisations, such as housing support agencies, Citizens Advice, or voluntary bodies
  • Police and other law enforcement agencies (where legally required)
  • Contractors or data processors providing housing or IT services on our behalf

All data sharing is carried out securely and only where necessary. CBC does not sell personal data.

How long we keep your information (data retention period)

Information is retained in accordance with the council’s data retention policy and statutory requirements.

Retention periods for housing-related data are typically:

  • Homelessness and housing application records: Up to three years following a decision or successful application
  • Withdrawn or closed applications: Up to six months after closure
  • For commissioned services: the duration of the contract with CBC and ten years beyond the contract end, for the purpose of accurate statistics or audit evidence.
  • Rough sleeper case records: current year plus nine years (10 years in total).

When information is no longer required, it will be securely deleted or anonymised.

How we safeguard your information

Your personal data is stored securely on CBC’s systems and accessed only by authorised officers using individual credentials, and by authorised providers (P3, Julien House, GARAS, Citizens Advice) using encrypted, password-protected devices and case management systems.

CBC uses secure network drives and encrypted devices. Any physical documents are kept in locked storage with controlled access.

Staff are trained on confidentiality, information security, and safe handling of personal data.

We do not transfer or store your data on servers outside the United Kingdom or European Economic Area (EEA).

If, in future, data needs to be transferred internationally, CBC will ensure that appropriate safeguards such as international data transfer agreements (IDTAs) or UK adequacy decisions are in place.

Your data protection rights

Under UK GDPR, you have the following rights:

  • Right of access – to request copies of your data
  • Right to rectification – to correct inaccurate or incomplete data
  • Right to erasure – to request deletion of your data (subject to legal exemptions)
  • Right to restrict processing – to limit how we use your data
  • Right to object – to processing carried out under public task or legitimate interest grounds
  • Right to withdraw consent – if consent is the legal basis for processing

To exercise your rights, contact the information governance team at [email protected]

We will respond within one calendar month.

How to contact us

For general enquiries about housing options and homelessness services email [email protected].

For data protection enquiries about this service email [email protected].

How to complain

If you are unhappy with how your data has been handled, you can raise a complaint with CBC’s information governance team at [email protected].

Please include your full name, contact details, and details of your concern. We aim to respond within 20 working days.

If you remain dissatisfied, you can contact 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

This privacy notice may be updated periodically to reflect changes in legislation or council procedure.

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

© Cheltenham Borough Council 2026