Strategic Purpose Information Sharing Protocol – Empty Homes
1.
Introduction
This protocol will govern the sharing of empty property addresses, landlord names,
addresses, contact details and updates on referral information between Hull City
Council and the partners listed below as part of the Empty Homes Programme:
PANDA (Pickering and Newington Development Association)
WINNER (Preston Road Women's Centre)
Probe
DISC (Developing Initiatives and Supporting Communities)
Giroscope
Goodwin Development Trust
2.
Objectives
Information will be shared with the partners listed above in order for them to contact
owners of empty properties or their advocates. The Empty Homes Partnership aims
to bring empty properties in the City back into use through lease or sale.
3.
Roles and Responsibilities
Identifies for the sharing of information under the Protocol of

Who will disclose it;
Hull City Council and each community partner listed above

What will be disclosed;
Contact details of the owners or advocates of empty properties and progress
with acquisition of properties through leases or purchase

How it will be disclosed and when;
The data will be uploaded to a shared folder which can be accessed by all
partners and Hull City Council

Who will receive it;
The partners listed above at section 1 and officers of Hull City Council.

Who will have access to;
The data controllers listed at Section 1. Only staff directly involved in the
Empty Homes Programme will have access to the data.

What can it be used for;
The data may be used only to contact property owners, or their advocates, for
the purposes of the Empty Homes Programme.

How it should be stored;
Each of the data controllers must take appropriate technical and
organisational measures to safeguard the data and work in accordance with
the requirements of the Data Protection Act 1998.
The data must be held safely and securely on systems with strong passwords.
The data should not be stored on removable devices (e.g. memory sticks) and
if a removable device is used to transfer the data the device must be
encrypted. Any paper copies of the data must be stored in locking
cupboards/cabinets when not in use.

4.
When it should be disposed of.
The data should be disposed of when it is no longer required for the purposes
of the programme. Some data will need to be retained beyond the point that a
property is leased or sold, for example for reporting to the Homes and
Communities Agency, however wherever possible the data will be
depersonalised and details of individuals removed.
Legislation
Information will only be shared where the Council has explicit informed consent from
the data subjects/companies or their advocates or representatives. This will be
recorded on a consent form.
Disclosure without consent may constitute breach of confidence and/or the Data
Protection Act.
5.
Client Consent
In all cases specific consent will be obtained on a dedicated consent form before any
information may be shared.
6.
Monitoring / Review
This data sharing agreement will be reviewed whenever any there are changes to
the objectives of the Programme, changes to the method of sharing or in the event of
an information security incident (e.g. loss, theft or accidental disclosure of the data).
In the event of an information security incident the data controller(s) must notify Hull
City Council at the earliest opportunity.
7.
Signatories
Hull City Council
PANDA (based at Gipsyville Multi-purpose centre)
WINNER (Preston Road Women's Centre)
Probe
DISC (Developing Initiatives and Supporting Communities)
Giroscope
Goodwin Development Trust
Operational Management Information Sharing Agreement
1.
Introduction
The data will be shared as part of the empty homes project. The information will be
uploaded by Hull City Council and community partners through a shared electronic
folder held on a Hull City Council server.
2.
Legislation
Written consent of the data subjects/companies, or their advocates or
representatives, will be obtained in all cases in order to comply with the Data
Protection Act 1998.
3.
Data Controllers
The data controllers are:
Hull City Council
PANDA
WINNER (Preston Road Women's Centre)
Probe
DISC (Developing Initiatives and Supporting Communities)
Giroscope
Goodwin Development Trust
4.
How Subject Access Request will be handled:
Each organisation will answer any requests from data subjects for copies of
personal information they hold for the purposes of the Programme in
accordance with Section 7 of the Data Protection Act 1998.
5.
Information Format and Quality

The format and detail of the information to be shared:
Hull City Council will create the data on a Microsoft Excel spreadsheet when
explicit consent is been received from the data subjects. Depending on the
data subject’s preferences the data may consist of a combination of:
-Address of the empty property
-The data subject’s home or work address
-Telephone number
-Mobile phone number
-Email address
-Other as supplied by the data subject

Procedures for Quality Assurance:
As the data is input to the Excel sheet regular spot checks are performed on
the data quality. In the event that a Partner identifies incorrect data they must
report the details to Hull City Council at the earliest opportunity.
6.
Information Security and Confidentiality

The procedure for making requests and the arrangements for access to
information and restrictions including those for third party access:
Each data controller will answer requests for subject access in accordance
with the rights of data subjects under the Data Protection Act 1998.
Data Controllers who are public authorities for the purposes of the Freedom of
Information Act 2000, should make all reasonable efforts to consult the
owners of the empty properties, whether individuals or companies, in order to
inform their decisions on disclosure.

The storage standards
Each data controller is responsible for taking appropriate technical and
organisational measures to ensure the data is stored safely and securely.

The retention and destruction arrangements
The data should be disposed of when it is no longer required for the purposes
of the programme. Some data will need to be retained beyond the point that a
property is leased or sold, for example for reporting to the Homes and
Communities Agency, however wherever possible the data will be
depersonalised and details of individuals removed.

The procedures in place for the secure transfer of data
Data will be transferred through a shared electronic folder which is stored on a
Hull City Council server.
6.
Client Consent to Share Information

Details of the consents required including obtaining consent, withdrawal of
consent, disclosure without consent
Full explicit consent will be obtained from all data subjects/companies. Where
consent is withdrawn the data will be deleted by all data controllers at the
earliest opportunity and within 28 days. Some depersonalised data may be
retained for monitoring and reporting purposes.

Privacy / Fair Processing Notice requirements
The fair collection form obtains explicit consent and provides an assurance
that the data will only be used for the purposes of the Programme.
7.
Roles and Responsibilities
The lead officers for each data controller are:
Hull City Council
PANDA
WINNER
Probe
DISC
Giroscope
Goodwin Development Trust
Laura Carr
Ian Holmes
Ann Clarkson
Steve Altoft
Craig Stewart
Martin Newman
Key points of contact at each organisation are as follows:
Hull City Council
PANDA
WINNER
Probe
DISC
Giroscope
Goodwin Development Trust
8.
Liz Jamil / Benard Goren
Colin Turner
Ann Clarkson / Biddy Parker
Graham Longbone / Jayne Brindley
Claire McCreanor
Martin Newman / Caroline Gore-Booth
Jonathan Wilson
Monitoring / Review
This data sharing agreement will be reviewed whenever any there are changes to
the objectives of the Programme, changes to the method of sharing or in the event of
an information security incident (e.g. loss, theft or accidental disclosure of the data).
Any complaints about the use of data should be forwarded to the Partner(s) who are
the subject of the complaint. Where issues cannot be resolved to the satisfaction of
the complainant Hull City Council should be notified, as administrator of this
agreement of this. The agreement will then be reviewed to address any issues
which are identified.
9.
Signatories
Organisation
Hull City Council
Lead Officer
Laura Carr
PANDA
Ian Holmes
Signature
Date:
Date:
WINNER
Ann Clarkson
Probe
Steve Altoft
Date:
Date:
DISC
Craig Stewart
Giroscope
Martin Newman
Date:
Date:
Goodwin
Development Trust
Date: