Housing Adaptation Grants Privacy Notice

1.0 Purpose of the processing

Personal data is processed as part of housing adaptation grant application administration. The council is making available to applicants an online application option, in addition to the traditional hardcopy application process. The purpose of the personal data processing is to assess eligibility for a housing grant and where eligibility is confirmed, to put through a payment of grant aid, either to the applicant, or in some cases directly to a contractor employed by the applicant.

The council is obliged to protect personal data in accordance with the Data Protection Act 2018 and the provisions contained in the General Data Protection Regulation (GDPR). The purpose of the processing of personal data for housing grant administration is to:

• Assess eligibility for the housing grant schemes
• Process payments of grant aid to eligible applicants
• By having an online application process, to enable applicants to track the status and progress of their applications
• By having an online application process, to improve efficiency of housing grant administration

2.0 Legal basis

The main legal bases to process personal data in the case of applications for housing grants are the following provisions:

• Article 6(1)(e) of the GDPR - the processing is necessary for the performance of a task carried out in the public interest or in the exercise of an official authority vested in Clare County Council. The official authority in this case derives from the council's role as a housing authority and the Housing (Adaptation Grants for Older People and People with a Disability) Regulations 2007 [S.I. No. 670 of 2007 and S.I. No. 361 of 2023].
  
  
• Article 6(1)(b) of the GDPR – namely, that processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. The contract in this case is the provision by the local authority to the housing grant applicant of a financial grant for the purposes set out in the relevant housing grant application scheme.
  
  
• Article 9(2) (g) of the GDPR - processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject: in this case: S.I. No. 670 of 2007 and S.I. No. 361 of 2023].

3.0 The categories of personal data concerned

The identifiable personal information includes:

• Applicant name and address and contact phone number and email
• Applicant date of birth and PPSN number
• Photos of the works to the property
• Property details (makeup of no. of rooms)
• Health data relating to applicant
• Spouse details and household composition
• Child dependant details
• Income details
• Bank account details
• Contact and relationship of carer (where applicable)
• Name and contact details and VAT number of contractor
• Bank account details of contractor (if permitted to be paid directly)

Housing grant applications involve processing special category data, namely health data, where applicants supply details of medical conditions in applications by way of supporting their application and documenting eligibility for the statutory housing grant schemes.

4.0 Processing and recipients of the data

A small team of council officials, administration and technical, have access to the data in the performance of their roles on the housing grant schemes.

The Department of the Environment, Heritage and Local Government is provided with limited data on grants paid, namely, name, address, Date of Birth, PPSN, Eircode, nature of works, cost of works, amount of grant paid.

Third party access to personal data is not allowed, except in the very limited circumstances permitted by law. Access requests shall be processed in accordance with the Data Protection Act 2018, the GDPR and the council's data protection policies and procedures.

There are no plans to transfer personal data to a third country or international organisation.

5.0 The retention period for the data

The council subscribes to the records retention and destruction policy for local authority records

• For successful and unsuccessful applicants, applications will be retained for 7 years after grant is paid out.
• A register showing a record of payments and schedule of works carried will be retained permanently as archives.
• For unsuccessful applications retain records from decision + 7 years. Then destroy.

6.0 Data subjects have a range of data rights

• Right of access by the data subject
• Right to rectification
• Right to erasure ('right to be forgotten')
• Right to restriction of processing
• Right to data portability
• Right to object and automated individual decision-making

The council's data access request policy and procedures are available on www.clarecoco.ie or please contact dpa@clarecoco.ie.

7.0 The right to lodge a complaint with the supervisory authority

If you are not satisfied with a decision on your request for access to data or have concerns about personal data processing, you have the right to make a complaint to the Data Protection Commission, Canal House, Station Road, Portarlington, Co. Laois, Ireland. Before doing so it is recommended that you contact Clare County Council (DPA@clarecoco.ie) to establish the circumstances. We may be in a position to resolve the problem in a timely manner. 

The Data Protection Commission website www.dataprotection.ie has further details and the forms that are required to be completed if you wish to raise a concern or make a complaint.

8.0 Contact details for the data controller and data protection officer

The identity and the contact details of the controller:

Clare County Council,
New Road,
Ennis,
Co. Clare

Telephone: (065) 6821616
Email: roads@clarecoco.ie
Website: www.clarecoco.ie

The contact details of the data protection officer:

Data Protection Office,
Clare County Council,
New Road,
Ennis,
Co. Clare

Telephone: (065) 6846405
Email: DPA@clarecoco.ie

Page last reviewed: 03/09/24

Content managed by: Housing and Integration Department

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