What this privacy notice is for

Our core data protection obligations and commitments are set out in the council’s primary privacy notice at:

• Data Protection

Updating our privacy notices

We may update or revise our privacy notices at any time so please refer to the version published on our website for the most up to date details

What we use your information for

We collect or obtain your personal information to administer and enforce the collection of:

• Council Tax

We may share your information with other departments within the Council if there is a legal basis to do so for the purposes of delivering other Council activities. Where this happens, data sharing agreements are in place to control the use of this data.

What categories of personal information we use

Personal information can be anything that identifies and relates to a living person. This can include information that when linked with other information, allows a person to be uniquely identified. For example, this could be your name and contact details.

The law treats some types of personal information as ‘special’ because the information requires more protection due to its sensitivity. This information consists of:

• Racial or ethnic origin
• Sexuality and sexual life
• Religious or philosophical beliefs
• Trade union membership
• Political opinions
• Genetic and bio-metric data
• Physical or mental health
• Criminal convictions and offences

In order to carry out these purposes we collect and obtain the following personal information.

We will use information about your physical or mental health, or disability status to administer discounts and exemptions. If you are in arrears, we may also use this information to determine whether you are vulnerable and tailor our recovery methods accordingly.

Legal basis for processing

Oldham Council has a statutory responsibility to provide services that administer and enforce the collection of local taxation and miscellaneous debts.

The legal basis for processing and/or sharing your personal information is article 6(1) (c) and 6(1) (e) of the General Data Protection Regulations.

The legal basis for this area within Revenues Service’s statutory duties is set out in the table below:

If you fail to provide certain information when requested, we may be prevented from complying with our legal obligations to administer and collect outstanding monies owed to the Council. Similarly, in not providing your information you may find yourself subject to legal and debt recovery proceedings.

Information sharing/recipients

We may share personal information about you with the following organisations, where it is necessary and appropriate to do so:

• Council contracted external Enforcement Agents, Debt Collection and/ or Tracing Agencies, external solicitors: If you have accrued arrears and we have been unsuccessful in recovering any monies owed or you have absconded without providing a forwarding address.
• Telecommunication/SMS Messaging service provider: If we hold contact details for you and you have missed a payment, or we you need you to contact us we may use a provider to issue you a message via SMS text or email.
• Our software providers may have to access our revenues systems on occasion where there is a fault, to perform necessary upgrades, or to host information on our behalf. Our current software providers are:
  • Capita PLC – We use Capita systems to:
    • administer and enforce the collection of Council Tax,
    • to assess entitlement to Council Tax Reduction
    • to take online payments and agent handled card payments.
    • to provide our online services.
  • NEC Software Solutions use the NEC document management system Information@Work system to store and manage documents and correspondence electronically. This normally includes non-system generated letters issued to taxpayers, correspondence from taxpayers, and details of any checks made in relation to discounts. Additional information may be stored, if necessary, for the administration of the taxpayers Council Tax account.
• The Civica Group - We use Civica Collect to administer the collection of arrears through Council employed Enforcement Agents. Without the use of this software the Council would not be able to use internal Enforcement Agents to collect arrears. Civica Collect also allows the Council to send SMS text message reminders to taxpayers to request they contact prior to arrears being passed to Enforcement Agents.
• Govtech Solutions Limited: We use Govtech Solutions Limited to process and cleanse information you provide to the local authority via our online services regarding your liability for or payment of Council Tax.
• Local Government and Social Care Ombudsman: We may share information when requested as part of any ongoing complaint investigation.
• HM Courts and Tribunals Service (HMCTS): If we are required to take legal action to recover monies you owe, we will share necessary information with the HMCTS during legal proceedings.
• Valuation Tribunal (VT): We may share information when requested as part of a VT appeal relating to liability, and the award of discounts or exemptions.
• Credit Reference Agencies: We may share your details to verify your entitlement to Council Tax discounts, to verify whether a property is empty, and to assess the ability to repay in order to apply the most appropriate recovery option if you do not pay as billed
• Department for Works and Pensions: we may share your details for the purpose of requesting a deduction from your benefits for unpaid arrears, administering Council Tax Reduction, or confirmation of any deductions from benefit in place.
• Your employer: we may share your details for the purpose of requesting an attachment to your earnings.
• Valuation Office Agency: We may share your details in order to obtain a Council Tax band for your property or details of any amendments to Council Tax bands.
• Printing and Mailing Companies: We may share your details for the purposes of issuing Council Tax bills and other notices.
• Cabinet Office: 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. This data may then be passed on to other public bodies to investigate any matches.
• The Office for National Statistics (ONS): We provide information to ONS as legally required per its inclusion of the Single Data List (SDL).
• Department for Energy Security & Net Zero (DESNZ: For the purpose of administering the Energy Bills Support Scheme (EBSS) Alternative Funding scheme.
• Any other Central Government department where we have a legal obligation to do so, or where a Data Sharing Agreement is in place to enable the administration of Government initiatives requiring the use of council tax records.

We may share your information with other departments within the Council if there is a legal basis to do so. Where this happens, data-sharing agreements are in place to control the use of this data. These services currently include:

• Children’s Safeguarding: To enable the Council to provide local Council Tax discounts to Care leavers up to the age of 25
• Environment Health: to support housing enforcement activities in relation to empty properties or those subject to legal action due to disrepair or abandonment.
• Children Missing in Education: The Council has a statutory duty to ensure that we are able to establish the identities of children, aged 5 – 16 years, in the borough who are not registered pupils at a school, and are not receiving suitable education otherwise than at a school
• School Admissions: To establish eligibility of Free School Meals, and to ensure the criteria is met regarding applications for school places.
• Electoral Register: to support the administration of the electoral register.
• Client Financial Affairs: To support the processing of fairer charging assessments.
• Support and Inclusion Team (SIT) and Welfare Rights Team: To support residents who have been identified as having needs beyond one-off crisis support with tailored support, signposting and referrals.
• The Audit and Counter Fraud Team: in order to prevent and detect fraud and help protect public monies.

If you provide another person or organisation authority to discuss or to act on your behalf in relation to your Council Tax, we may share information with them. In all cases we would require evidence you had granted authority before any information is shared.

We may be asked to provide access to personal information by relevant authorities with regulatory powers such as the police, government departments and other local authorities for the purposes of the prevention or detection of crime and/or the apprehension or prosecution of offenders without the permission of the data subject. The Council will consider such requests on a case-by-case basis.

As well as information collected directly from you, we may also obtain or receive information from:

• Letting Agents: To provide confirmation of occupation and vacation dates for tenants.
• Solicitors: If they obtain relevant information in relation to you whilst acting on our behalf to recover monies owed.
• Debt Collection, and Tracing Agencies: If you have accrued arrears and we have been unsuccessful in recovering any monies owed or you have absconded without providing a forwarding address we may issue cases to external companies. If these companies obtain relevant information about you or contact details, they may share this information with us.
• Landlords: To provide confirmation of occupation and vacation dates for tenants
• Other Council Services: To keep our records up to date and to preventand identify 

Data Transfers beyond the European Economic Area

We do not transfer any of your personal information outside the European Economic Area (‘EEA’).

Automated Decisions

The Council provides online options for Council Taxpayers to advise us of change of address details, apply, renew or cancel single person discount, apply for a student exemption, set up a direct debit or a payment plan. Decisions can be made including profiling customers to improve the customer experience and signposting support. Where an automated decision cannot be made this could involve human intervention.

Our Guide to Exercising Your Rights outlines the procedure to ask us for an automated decision to be reviewed by an appropriate officer. This can be found at www.oldham.gov.uk/yourdatarights

How long we keep your data

We will only keep your information for as long as it is required by us or other regulatory bodies in order to comply with legal and regulatory requirements or for other operational reasons.

In some instances, the amount payable in relation to Council Tax can change retrospectively to the date they came into effect. This is usually as a result of the Valuation Office Agency amending the Council Tax band of a property.

The Valuation Office Agency can amend a Council Tax band back to the 1 April 1993, Consequently, we keep necessary records in order that we are able to refund any money that may become due from a property being rebanded. Specifically, the name of the Council Taxpayer, the amount of Council Tax discount, the amount paid by the taxpayer and correspondence details.

Copies of information stored on the Council’s Document Imaging System is held for six years plus the current year (otherwise known as 6 years + 1) from the date received and/or uploaded onto the system.

Where can I get advice?

More information on how to seek advice in order to exercise your rights, raise a concern or complain about the handling of your personal information by the council can be found in the council’s privacy notice which can be found at:

• Data Protection