Housing Benefit and Council Tax Support - Privacy Notice

What this Privacy Notice covers

Adur District Council and Worthing Borough Council (referred to in this notice as 'the councils', 'we' or 'us') are data controllers for the personal information we process for the purposes of administering and maintaining claims for Housing Benefit and Council Tax Support.

This privacy notice explains:

  • how and why we collect and use your personal information;
  • the types of personal information we collect;
  • where we obtain your information from;
  • what may happen if information we need is not provided;
  • when and why we share information with other organisations;
  • how information received from the Department for Work and Pensions is handled;
  • how long we keep your information; and
  • your rights in relation to your personal information.

The Councils' Data Protection Officer can be contacted at:

Why we need your personal information

We process personal information to administer and maintain claims for Housing Benefit and/or Council Tax Support on behalf of Adur District Council and Worthing Borough Council.

This includes using information to:

  • assess and calculate entitlement;
  • verify information provided in connection with a claim;
  • identify and process changes in circumstances;
  • maintain the accuracy of claims and awards;
  • prevent and detect fraud and error;
  • recover overpayments where appropriate;
  • carry out checks required by law;
  • respond to appeals, reviews and other challenges;
  • protect public funds; and
  • undertake authorised system testing and assurance where necessary for the administration of these services.

Our legal basis for processing your information

Our principal lawful basis for processing this information is Article 6(1)(e) of the UK General Data Protection Regulation (UK GDPR):

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 controller.

Our official authority and public tasks arise from legislation governing the administration of Housing Benefit, Council Tax Support, local taxation and associated statutory functions.

This includes, where applicable, legislation such as:

  • the Social Security Administration Act 1992;
  • the Housing Benefit Regulations 2006;
  • the Local Government Finance Act 1992, including provisions relating to local Council Tax reduction schemes; and
  • other legislation, regulations and statutory schemes governing Housing Benefit, Council Tax Support and related functions.

Special category personal information

Where special category personal information is processed for the administration of Housing Benefit or Council Tax Support, we will only process it where an appropriate condition under Article 9 of the UK GDPR and the Data Protection Act 2018 applies.

Where applicable, this includes Article 9(2)(b) UK GDPR, where processing is necessary for obligations and rights in the field of social security and social protection law, together with Schedule 1, Part 1, paragraph 1 of the Data Protection Act 2018.

Where another Article 9 condition applies to a particular processing activity, the appropriate condition will be identified and documented.

Criminal offence information

Where we process information relating to criminal convictions or offences, we will do so in accordance with Article 10 UK GDPR and the Data Protection Act 2018.

Such processing will only take place where it is under the control of official authority or, where required, is authorised by an applicable condition in Schedule 1 to the Data Protection Act 2018.

What information we collect

Depending upon your circumstances and the benefit or support being administered, the personal information we process may include:

  • your name, address and previous addresses;
  • date of birth;
  • National Insurance number;
  • contact details;
  • information about members of your household;
  • marital or relationship status where relevant;
  • employment and self-employment information;
  • earnings and other income;
  • state benefits, tax credits and pensions;
  • savings, investments, property and other capital;
  • rent, tenancy and housing costs;
  • Council Tax information;
  • information concerning changes in your circumstances;
  • information required to verify your identity or entitlement;
  • information relevant to the prevention and detection of fraud and error; and
  • other information necessary to determine or maintain entitlement to Housing Benefit and/or Council Tax Support.

Where necessary and lawful, this may also include special category personal information or information relating to criminal convictions and offences.

We will only collect and use information that is adequate, relevant and necessary for the purpose for which it is being processed.

Where we obtain your information from

We obtain information directly from you when you make a claim, report a change in circumstances, provide supporting evidence or otherwise contact us.

We may also obtain information about you from other organisations where the law permits or requires this.

These organisations may include:

  • the Department for Work and Pensions (DWP);
  • HM Revenue & Customs (HMRC);
  • the Home Office;
  • other government departments;
  • other local authorities;
  • employers and pension providers;
  • landlords and housing providers; and
  • other organisations authorised to provide information for the administration, verification or protection of public funds.

Information supplied to us by DWP may include information which originated from HMRC, the Home Office or other authorised government sources.

What happens if you do not provide information

We may need you to provide information and evidence so that we can determine, verify or maintain your entitlement to Housing Benefit or Council Tax Support and carry out our statutory functions.

Where information is required for these purposes and you do not provide it, we may be unable to determine your entitlement. Depending on the circumstances and the legislation which applies, we may need to suspend consideration or payment of your claim, make a decision using the information available to us, or may be unable to award or continue Housing Benefit or Council Tax Support.

Where legislation gives us powers to require particular information, we will exercise those powers in accordance with the applicable law.

We will tell you where information is required and, where appropriate, explain the possible consequences of not providing it.

Information received from DWP, HMRC and the Home Office

The councils participate in statutory data-sharing arrangements with the Department for Work and Pensions for the administration of Housing Benefit, Council Tax Support and other specifically authorised purposes.

The access, handling, exchange and protection of information made available through these arrangements is governed by applicable legislation and by the Memorandum of Understanding between DWP and local authorities.

Under these arrangements, we may receive information held by DWP and information provided through DWP which originates from HMRC and/or the Home Office.

Depending upon the circumstances, this may include information concerning:

  • identity and National Insurance number;
  • state benefits and pensions;
  • employment and earnings;
  • occupational or private pensions;
  • income and other financial information;
  • changes in circumstances;
  • immigration or residency information where relevant to entitlement; and
  • other information necessary to establish, verify or maintain entitlement.

We use this information, where authorised, to:

  • verify information supplied in connection with a claim;
  • assess and maintain entitlement;
  • identify changes which may affect entitlement;
  • calculate the correct award;
  • prevent and detect fraud and error;
  • identify incorrect payments;
  • recover overpayments where appropriate; and
  • protect public funds.

We may also provide information to DWP and other authorised government bodies where this is permitted or required by law and, where applicable, by the relevant data-sharing arrangements.

Additional controls applying to DWP-derived information

Information made available to the councils by DWP, including information originating from HMRC or the Home Office, is subject to additional restrictions.

We will only access, use, re-use, disclose and otherwise process this information for purposes that are permitted by law and by the applicable DWP/Local Authority Memorandum of Understanding or other authorised data-sharing arrangement.

A lawful basis under data protection legislation does not, by itself, remove any additional restriction imposed by those arrangements.

Where the proposed use or disclosure of DWP-derived information falls outside an existing authorised purpose, we will obtain any further authority or permission required before the information is used or disclosed.

Access to DWP-derived information is restricted to authorised individuals who require access for an approved business purpose and who meet the applicable security requirements.

Sharing your information

We may share relevant personal information with other departments within the councils and with external organisations where this is necessary, proportionate and lawful.

Depending upon the circumstances, this may include sharing information:

  • with DWP, HMRC, the Home Office and other government departments;
  • with other local authorities;
  • for the prevention and detection of fraud and error;
  • for law enforcement purposes;
  • for criminal investigations and prosecutions;
  • in connection with court or tribunal proceedings;
  • where necessary to establish, exercise or defend legal rights;
  • where necessary to protect public funds;
  • with organisations processing information on our behalf under appropriate contractual and data protection arrangements; and
  • where another legal requirement permits or requires us to disclose information.

We will only share the information that is necessary and proportionate for the relevant purpose.

We will not disclose your personal information to another organisation or use it for an unrelated purpose unless there is an appropriate lawful basis and any other applicable legal, statutory, contractual or data-sharing requirements are satisfied.

Where information has been obtained from DWP, including information originating from HMRC or the Home Office, the additional restrictions described in this notice will continue to apply to its use and onward disclosure.

Support services

Where appropriate and lawful, we may use information held about you to identify or facilitate access to support services that may be relevant to your circumstances, including, for example, employment, money management or digital support services.

Where information obtained from DWP, HMRC or the Home Office is proposed to be used for such a purpose, we will only do so where that purpose is specifically authorised under the applicable data-sharing arrangements or where any additional permission required has been obtained.

Where the provision of a support service requires a different lawful basis, your consent, or another choice or right, this will be addressed in accordance with applicable data protection legislation.

Supported housing and West Sussex County Council

The Supported Housing (Regulatory Oversight) Act 2023 places duties on local housing authorities in relation to supported housing, including reviewing supported housing provision and need and preparing and reviewing a Local Supported Housing Strategy.

The Act also permits local housing authorities, subject to data protection legislation and any other applicable restrictions, to use information obtained through the exercise of Housing Benefit functions for purposes connected with the authority's supported housing functions.

We may share relevant information with West Sussex County Council where this is necessary and proportionate to support the councils and the county council in carrying out their respective statutory functions relating to supported housing.

This may include information necessary to:

  • understand the current supply and availability of supported housing;
  • assess current and projected supported housing need;
  • develop, implement, monitor and review the Local Supported Housing Strategy;
  • support lawful planning and strategic oversight of supported housing; and
  • enable West Sussex County Council, as the relevant social services authority, to provide assistance reasonably required by the local housing authorities in connection with their statutory supported housing functions.

Information will only be shared where there is an appropriate lawful basis and will be limited to what is necessary and proportionate for the relevant statutory purpose.

This provision does not, by itself, authorise the onward disclosure of information obtained from DWP, including HMRC or Home Office-derived information.

Where DWP-derived information is proposed to be shared for a supported housing purpose, it will only be disclosed where the disclosure is permitted by law and by the applicable DWP data-sharing arrangements, including obtaining any additional permission required.

Where special category personal information or criminal offence information is involved, the applicable additional processing condition will also be identified and documented.

As further provisions of the Supported Housing (Regulatory Oversight) Act 2023 are commenced, and as regulations, statutory guidance or other requirements are introduced or amended, we will review this privacy notice and update it where necessary.

Accuracy of information shared between organisations

The councils take reasonable steps to ensure that personal information used to make decisions about Housing Benefit and Council Tax Support is accurate and, where necessary, kept up to date.

DWP and the councils also have responsibilities for the accuracy of information processed under their data-sharing arrangements.

If information which has previously been shared is subsequently found to be inaccurate and is corrected, the organisation making the correction will, where appropriate and required, notify the other relevant organisation and provide corrected information.

This helps ensure that decisions affecting Housing Benefit and Council Tax Support are made using accurate and up-to-date information.

System testing, maintenance and assurance

Personal information may be used where necessary and lawful for authorised system or software testing, maintenance, assurance or development associated with the administration of Housing Benefit and Council Tax Support.

We will use anonymised, pseudonymised or synthetic information instead of identifiable personal information where this is reasonably practicable and suitable for the purpose.

Where identifiable personal information is required, access will be limited to what is necessary and appropriate technical and organisational security measures will be applied.

Where DWP, HMRC or Home Office-derived information is involved, the information remains subject to the purpose, access, security and UK-processing requirements of the applicable DWP data-sharing arrangements.

DWP-derived information will not be used in a testing or development environment where that use is not permitted under those arrangements.

Statistical and anonymised information

We may convert personal information into anonymised or aggregated information so that individuals can no longer be identified.

Anonymised or aggregated information may be used for:

  • statistical analysis;
  • research;
  • service planning;
  • performance monitoring; and
  • reporting.

Information will only be treated as anonymised where individuals are no longer identifiable by reasonably available means.

Where information has been effectively anonymised so that an individual is no longer identifiable, it is no longer personal data for the purposes of UK data protection legislation.

Automated decision-making

We may use automated processing within our system to look at your personal information, including details sent to us by other government departments (such as the Department for Work and Pensions, HMRC), or provided directly by you, to work out if you are eligible for support, update your claim, or manage your case. Any automated decisions are made strictly using set legal rules and standard calculations.

If a decision made entirely by automated processing affects your payments or entitlement, you have the right to ask us to explain how the decision was made, share extra details with us, ask a staff member to look at it, or request a formal review.

How long we keep your information

We retain personal information only for as long as it is necessary for the purposes for which it was collected, in accordance with:

  • the councils' records retention and disposal schedule;
  • statutory and regulatory requirements;
  • the requirements of applicable data-sharing arrangements; and
  • any legitimate requirement to retain information for audit, appeals, legal proceedings, fraud prevention or the protection of public funds.

Different types of records may be retained for different periods depending upon their purpose and applicable legal requirements.

Information received under a DWP data-sharing arrangement will not be retained for longer than permitted by the applicable arrangement.

Personal information will be securely deleted or disposed of when it is no longer required.

Your data protection rights

You have rights under UK data protection legislation. The rights which apply can depend upon the lawful basis and circumstances in which your information is being processed.

To exercise any of these rights, please contact the councils' Data Protection Officer using the contact details at the beginning of this notice.

Right to be informed

You have the right to be informed about the collection and use of your personal information.

This privacy notice is part of the information we provide to meet that requirement.

Right of access

You have the right to request access to personal information which we hold about you. This is commonly known as a Subject Access Request.

Where a Subject Access Request concerns information supplied to the councils by DWP, the information will be considered for disclosure in accordance with UK data protection legislation and the applicable DWP data-sharing requirements.

Where DWP-supplied information includes special category personal information, we will liaise with DWP before disclosure where required by the applicable DWP guidance or data-sharing arrangements.

We may also consult DWP where there is uncertainty about whether a statutory exemption, restriction or other requirement applies.

The councils remain responsible for responding to Subject Access Requests made to us in respect of personal information for which we are the controller.

Information taken from DWP systems will not be made available automatically through customer portals merely because it has been stored as a screenshot or other document. Requests for access to such information will be handled through the applicable statutory right-of-access process and in accordance with the relevant DWP data-sharing requirements.

Right to rectification

You have the right to ask us to correct personal information which is inaccurate and, in certain circumstances, to complete information which is incomplete.

Where inaccurate information has previously been shared with DWP or another relevant organisation, corrected information will be supplied to that organisation where appropriate or required.

Right to erasure

The right to erasure does not generally apply where processing is necessary for the performance of a public task, the exercise of official authority, compliance with a legal obligation or another applicable exception under data protection legislation.

We will nevertheless consider any request for erasure in accordance with UK data protection legislation and the circumstances of the particular case.

If an erasure request is upheld in relation to information which has been shared with another relevant organisation, that organisation will be notified where appropriate or required.

Right to restrict processing

In certain circumstances, you have the right to request that we restrict the processing of your personal information.

Where a valid restriction applies to information which has been shared with another organisation, we will take appropriate steps in relation to that information and notify the relevant organisation where required.

Right to data portability

The right to data portability does not generally apply to the processing described in this notice where processing is carried out under our public task or official authority rather than on the basis of consent or contract.

Right to object

You have the right to object to processing carried out under Article 6(1)(e) UK GDPR.

This right is not absolute.

We may continue to process your information where the requirements of data protection legislation allow us to do so, including where we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or where processing is necessary for the establishment, exercise or defence of legal claims.

Where information must be processed to enable the councils to fulfil statutory Housing Benefit, Council Tax Support or related public functions, this may affect whether we are able to uphold an objection.

Rights relating to automated decision-making

UK data protection legislation provides safeguards where a significant decision about you is based solely on automated processing without meaningful human involvement.

Where these provisions apply, the safeguards include measures enabling you to:

  • receive information about the decision;
  • make representations about the decision;
  • obtain human intervention; and
  • contest the decision.

The processing of DWP, HMRC and Home Office-derived information described in this notice does not involve significant decisions of this kind being made solely by automated processing without meaningful human involvement.

Processing in the United Kingdom and international transfers

Information made available to the councils by DWP which is covered by the DWP/Local Authority Memorandum of Understanding, including HMRC and Home Office-derived information, is subject to specific location restrictions.

That information will only be accessed from within the United Kingdom.

It will only be created, stored, transmitted or otherwise processed using ICT and information systems located within the United Kingdom, in accordance with the applicable DWP data-sharing requirements.

We will not permit employees, contractors or contracted service providers to access DWP-derived information covered by those requirements from outside the United Kingdom.

Where other personal information which is not subject to these restrictions is transferred or otherwise processed outside the United Kingdom, we will ensure that the processing complies with UK data protection legislation.

Where an international transfer takes place, we will ensure that an appropriate lawful transfer mechanism and any additional safeguards required by UK data protection legislation are in place.

Further information about any applicable international transfer safeguards will be provided where required.

Security

We take appropriate technical and organisational measures to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

Access to personal information is restricted to employees, contractors and other authorised individuals who require it for an approved business purpose.

Additional security, personnel and access requirements apply where required by DWP or another government data-sharing arrangement.

Organisations processing personal information on our behalf must comply with appropriate contractual, confidentiality, security and data protection requirements.

Changes to this Privacy Notice

We will review this privacy notice periodically and when there is a significant change to:

  • the way we process personal information;
  • the legislation governing Housing Benefit, Council Tax Support or supported housing;
  • the DWP/Local Authority Memorandum of Understanding or associated data-sharing arrangements; or
  • the organisations with which information is routinely shared.

The current version will be published on the councils' website.

Your right to complain

You have the right to make a data protection complaint to the councils if you consider that we have not handled your personal information in accordance with data protection legislation.

We will facilitate the making of data protection complaints and will acknowledge receipt of a complaint within 30 days.

We will take appropriate steps to investigate and respond to a complaint without undue delay and will inform you of the outcome.

Where appropriate, we will also keep you informed about the progress of our consideration of your complaint.

You can make a data protection complaint by contacting our Data Protection Officer at:

You also have the right to complain to the Information Commission (known as the ICO), the UK supervisory authority for data protection.

Further information about your data protection rights and how to make a complaint is available from the ICO.

Last updated: October 2026

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Page last updated: 08 October 2026

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