The First Homes programme is administered by Wealden District Council and the Ministry of Housing, Communities and Local Government (MHCLG), known as the Department for Levelling Up, Housing and Communities (DLUHC) at the time that this programme was established.
Personal Data processing performed by Wealden District Council, other public bodies, the relevant housing developer, and other third parties involved in the programme or purchase (for example, mortgage providers and conveyancers) is done so by each organisation acting as an independent data controller. This Privacy Notice relates to Wealden’s data processing activities. Please refer to the data protection and privacy notices provided by these other organisations, as relevant, for information about their processing of personal data and privacy practices.
How do we get your information?
We receive information about you when you apply for the First Homes programme. We receive this information from:
- You and/or the housing developer: The majority of your personal data comes from the First Homes application form and supporting information that you submit to us, or the housing developer submits on your behalf;
- Land Registry: We receive information from the Land Registry about the property you are purchasing, and confirmation of First Home provisions being registered against the property;
- Mortgage provider: We receive information from your mortgage provider regarding your mortgage offer in principle; and
- Conveyancer: we receive information from your conveyancer during the process to confirm that all necessary checks have been conducted and that your property purchase will be a compliant transaction. Later in the process your conveyancer will also confirm the legal completion of the property purchase and that all necessary paperwork has been completed.
What personal data do we process and why?
The information we process about you will vary depending on the nature of your application, but will fall within the following categories:
- Name;
- Date of birth;
- Address and contact details;
- Occupation information;
- Mortgage and financial information, including information relating to your income, the deposit you will be paying on the property, and information relating to your mortgage offer;
- Property information, including the house type, tenure, address, market value, reservation and expected build completion date, title number copies of entries of the Register and Title Plan;
- Personal circumstances where relevant to eligibility criteria, for example, whether you have a local connection, whether you are a veteran, whether you are a key worker, etc.;
- Supporting evidence for the relevant eligibility criteria, for example, bank statements, wage slips, contracts, proof of identity documents, family contact information; and
- Legal declarations as to the content of the application.
Special Category Data
We do not process special category data in relation to the First Homes programme.
Why we collect personal information about you?
Wealden District Council will collect and hold personal information relating to the First Homes programme. We use this information for the following purposes:
- Assess and determine your application;
- Issue an Authority to Proceed form and Authority to Exchange form;
- Process re-sales; and
- Internal and external programme monitoring and reporting.
Lawful basis for processing your personal data
We process personal data because it 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.
Who do we share your data with?
The data you provide may be disclosed with other departments of the Council or external organisations for related purposes or as required by law. We may share information with the following types of organisations:
We will share information with
- The housing developer: We share information with the relevant housing developer to confirm whether your application has been approved or denied and to issue the Authority to Proceed and Conveyancer Pack where applicable. If your application has been denied, we will also share information about the reasons for denial (e.g., which of the eligibility criteria has not been satisfied). The housing developer’s privacy notice will have been made available to you in your application pack, or can be made available upon request;
- Land Registry: We share information with the Land Registry in order to register first home provisions against the purchased property. The Land Registry’s privacy notice
- MHCLG/DLUHC: We may share information with MHCLG/DHULC for programme monitoring purposes. This data will be anonymised as far as possible, but there is a possibility that certain data remains identifiable. MHCLG’s/DHULC’s privacy notice will have been made available to you in your application pack;
- Mortgage provider and conveyancer: We share information with your mortgage provider and conveyancer, if applicable, namely the Authority to Proceed and Conveyancer pack. Please contact these organisations directly for further information about their data protection practices.
In some circumstances, such as under a court order, we are legally obliged to share information. 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, and to ensure that 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 is considered 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. Some of Wealden District Council’s existing data processors, in particular those who provide software and IT systems (for example, Microsoft) to Wealden District Council, will process your personal data.
Transfer of personal data?
Personal data may be transferred outside the UK where required or permitted, for example, where an appointed service provider performs part of their services from outside the UK. Any transfers outside the UK will be performed in compliance with applicable Data Protection legislation.
Automated decision making
We do not use automated decision making in respect of your personal data.
Retention Period
We process your personal data for the above purposes for no longer than necessary and in accordance with current legislation and the Council’s Retention Schedule.
Only in exceptional circumstances will we hold your information for longer, for example a pending court case. All information will be held securely and disposed of confidentially.
Anonymising your data
Your personal information may be converted into statistical or aggregated data that ensures that you cannot be identified from it. Anonymised data means it cannot be linked back to you as an individual and may be used to conduct research and analysis. This includes the preparations of statistics for use in our reports.
Your rights
Your rights are set out in the Data Protection legislation and include:
- the right to information about processing of your personal data;
- The right to access your personal information, to request rectification or erasure of certain personal
- The right to object to processing in certain circumstances
- the right to withdraw any consent you may have given to process your personal information
- the right to complain to the Information Commissioner if you feel we are processing your personal information unlawfully
- the right to restrict processing activity in certain circumstances
- the right to object to certain types of processing activity
If you wish to exercise any of these rights please contact our Information Governance team on informationgovernance@wealden.gov.uk in writing or by completing our online form. If you are dissatisfied with how we have used your personal data you have a right to complain to the Information Commissioner Office
Data Protection Officer
If you have any questions or concerns about how your personal data is handled, you can contact our Data Protection Officer (DPO), Clare McGough at dataprotection@wealden.gov.uk