As a billing authority for the city, Southampton City Council (SCC) collects, processes and stores personal information about you in order to administer and enforce Council Tax. We also use the data in our Council Tax database for other purposes, including the performance of our statutory enforcement duties and the prevention and detection of fraud.
This privacy notice tells you what to expect when SCC collects personal information about you.
This notice should be read in conjunction with our global privacy notice and when appropriate, we will provide a “just in time” notice to cover any additional processing activities not mentioned in this notice.
How we get your information
We get information about you from the following sources:
- Directly from you
- Central government agencies
- Other local authorities
- Family members
What personal data we process and why
The information we process about you will vary depending on the service being provided, but will fall within the following categories:
- Information about you, this could include your name, address, date of birth
- Number and status of other adults in the property to determine eligibility for discounts and exemptions
- Details about your lifestyle and social circumstances
- Financial details
- Employment details, to assess your eligibility for our Council Tax Reduction Scheme
Information relating to your health and wellbeing and other special category data
In order to meet our statutory and legal obligations in respect of this services, we may also need to process sensitive, or “special category” personal data about you, which could include data related to:
Physical or mental health details to assess your eligibility for discounts and exemptions
Lawful basis for processing your personal data
Depending on the service, we rely on the following lawful basis for processing your personal data under the GDPR:
- Article 6(1)(e) for the performance of our public task
Special category data
Where the information we process is special category data, for example your health data, the additional bases for processing that we rely on are:
- Article 9(2)(g) for reasons of substantial public interest
In addition we rely on processing conditions at Schedule 1 part 2 of the Data Protection Act 2018 (DPA2018). This relates to the processing of special category data for:
- Statutory etc. and government purposes
Our Policy on Processing Special Category Data provides further information about this processing.
How long we keep your personal data for
In accordance with our retention schedule, we keep our Council Tax records for six years, data may be retained in an anonymised form for statistical and reporting purposes.
In performing this service, it may be necessary for us to share some of your personal data with external organisations or internal departments. We may share information with the following types of organisations:
- Cabinet office – National fraud initiative, see further information section
- HM courts and tribunals service
- Local government
- Southampton Benefit Service
- Social housing associations
- Private landlords
- Department of works and pensions
- Welfare advisors
- Employment mentors
- Corporate fraud officers
- Corporate debt officers
- Financial assessment officer (care needs)
- Valuation office
- The Office for National Statistics (ONS) Council Tax data – see further information section
- Credit Reference – TransUnion (Call Credit)
- Health and social care organisations
In some circumstances, such as under a court order, we are legally obliged to share information, and we may also share information with the Police and other enforcement agencies for the purposes of the prevention, investigation, detection, or prosecution of criminal offences.
We may also share information internally, in order to verify or confirm your personal details, to ensure our records are accurate and up-to-date. Data held by this service will only be used by other internal departments or services when we are satisfied there is a lawful basis for doing so, and that is it fair.
Do we use data processors?
Data processors are third parties who provide certain parts of our services for us. We have contracts in place with them and they cannot do anything with your personal information unless we have instructed them to do so. Our current data processors for this service are listed below.
|Data Processor||Purpose||Privacy Notice|
|Capita One Revenues and Benefits (supplier Capita)||The system used to administer Council Tax and Council Tax Reduction||Capita One - Privacy Notice|
|Capita Intelligent Communications (CIC)||Supplier we use to send council tax and business rates bills, council tax and business rates recovery documents, benefit notifications, Financial Assessments documents, further request letters and communication letters||CIC - Privacy Notice|
|Civica digital Workflow 360||The system used to store correspondence||Civica - Privacy Notice|
|Tel Solutions||Supplier we use to send text and emails about Council Tax accounts that are behind in payments||Tel Solutions - Privacy Notice|
|TransUnion||Credit Reference||TransUnion - Privacy Notice|
Transfer of personal data
No data is transferred overseas as part of this service.
Automated Decision Making
We may make automated decisions to end some time-limited discounts, exemptions and processing new direct debit mandate, and to assist with income recovery (recovery of unpaid council tax). You have the same rights of appeal as when an officer makes a decision.
The Council has a duty to protect the public funds it administers and may use the information you have provided or share it with other bodies for the purpose of preventing and detecting fraud. This includes participation with the Cabinet Office.
The Cabinet Office is responsible for carrying out data matching exercises.
Data matching involves comparing computer records held by one body against other computer records held by the same or another body to see how far they match. This is usually personal information.
Computerised data matching allows potentially fraudulent claims and payments to be identified. Where a match is found it may indicate that there is an inconsistency which requires further investigation. No assumption can be made as to whether there is fraud, error or other explanation until an investigation is carried out.
We participate in the Cabinet Office's National Fraud Initiative; a data matching exercise to assist in the prevention and detection of fraud. We are required to provide particular sets of data to the Minister for the Cabinet Office for matching for each exercise, as detailed on:
The use of data by the Cabinet Office in a data matching exercise is carried out with statutory authority under Part 6 of the Local Audit and Accountability Act 2014. It does not require the consent of the individuals concerned under the Data Protection Act 1998.
Data matching by the Cabinet Office is subject to a Code of Practice
More information on the Cabinet Office's legal powers and the reasons why it matches particular information
We participate in the Cabinet Office's Debt Recovery and Vulnerability DEA Pilot; a data matching exercise to manage and reduce Council Tax Debt and to identify vulnerability among Council Tax debtors. We are required to provide particular sets of data to the Minister for the Cabinet Office for matching for each exercise, as detailed on:
The Office for National Statistics (ONS) Council Tax data
Council Tax is a key source for statistics on household incomes and inequalities. For example, Council Tax is one of the most important direct taxes that feeds into National Statistics on the Effect of Taxes and Benefits on households. Currently, these statistics are based on survey data, which are subject to measurement error and missing information (particularly for Council Tax).
Providing the ONS with administrative data on Council Tax significantly improves the quality of the statistics, and reduces the burden on survey respondents. These statistics are key for developing national policies aimed at combatting poverty and improving standards of living.
The Council shares the following personal data with the ONS:
- Address (personal or for business rates business address)
- NI number
- Company or business name
- Phone – personal and business (for business rates)
- Household Income/Rent
- Household Personal data – details on each person in household for benefit purposes
The ONS use it for the following purposes:
- Social Survey Division: Replace Council Tax related questions on four social surveys (Survey on Living Conditions, Living Costs and Food Survey, Wealth and Assets Survey, Family Resources Survey), that are used to produce new statistical outputs and enhance current statistical outputs
- Address Register Team: Creating and enhancing their address register for the Census
- Prices: Use in the measurement of Council Tax prices in Consumer Price Index including Housing costs and help weight sub-aggregates of households as they develop an index of household payments
- Admin Data Census: improve population research outputs by creating an indicator of activity to use for people and addresses
- Methodology: Efficient sample designs and improve precision of estimators
- Public Policy Division: Improve the statistics about the number of new properties built. Also help improve dwelling stock estimates by enabling a sub-national vacancy rate adjustment, which isn't currently possible between censuses
- Census Transformation Programme 2021: Help with enumeration, especially of hard to count population / geographic areas. Quality assurance and validation of census responses and estimates, improve the accuracy of census estimates (ensure that people who are no longer resident in the population are removed) and impute missing data for people who haven't responded to the Census.
The benefits to the Council for sharing this information are:
- Better authority level statistics
- Better ability of reporting alongside other local authorities
- Improved migration and demographic statistics at a local authority level
- Statistical evidence for requesting additional funding from Central Government
- The National Audit Office are also interested in the longer-term potential of this data extract. If this data is provided to ONS electronically, ONS can aggregate and disclose the data to The Ministry of Housing, Communities and Local Government – saving local authorities time and money when providing this data manually
- Circular migration within the UK. This would be achieved through matching Council Tax data with other administrative data sets within ONS, which could enhance statistical evidence
Section 45A of the Statistics and Registration Services Act 2007 (as inserted by section 79 of the Digital Economy Act 2017). It permits any public authority to disclose to the Statistics Board, (ONS), any information they hold regarding their functions. This legal gateway enables ONS to work collaboratively with data suppliers including government and local authorities.
As such, the legal bases for sharing the Council Tax data with the ONS under the UK GDPR are:
- Article 6(1)(e) for the performance of our public task
- Article 9(2)(j) for statistical purposes in the public interest