Section 1: Data information
Source: gov.uk (2025-10-06)

Other Rent Officer related matters - data and information.

The UK General Data Protection Regulation and access to information held on office files

(v. 1 2022)

Background

We have a policy of being open and accountable in our dealings with the public. We aim to make information freely available where we can.

The General Data Protection Regulation (GDPR) came into effect on 25 May 2018 setting a new standard for data privacy, security, and compliance. Now known as the UK General Data Protection Regulation (UK-GDPR) from 1 January 2021, the UK-GDPR seeks to protect personal data by giving individuals more rights over how we handle their data and it also places new obligations on how we manage customer data. One of the rights to individuals is the right to access personal information (subject to certain exemptions) held on file about them. This guidance only covers the GDPR.

The first principle under GDPR requires that processing must be lawful, fair and transparent. This mean that personal data can only be processed if it meets one of the criteria set out in Article 6 of GDPR and special category data can only be processed if one of the criteria under Article 9 of GDPR is met. The third data protection principle requires that personal data shall be adequate, relevant and limited to what is necessary in relation to the purpose or purposes for which they are processed. This means that our organisation as a data controller has to exercise care when recording information.

Recording and disclosing personal data

You must exercise caution in recording personal data on file and seek guidance before recording special category data on file. Special Category data is any personal data relating to:
- their racial or ethnic origin;
- their political opinions;
- their religious beliefs or other beliefs of a similar nature;
- membership of a trade union;
- their physical or mental health or condition;
- their sexual life;
- the commission or alleged commission of any offence;
- proceedings for any offence committed or alleged to have been committed by them, the disposal of such proceedings or the sentence of any court in such proceedings.
You must also seek guidance from the Rent Officer Technical Services helpdesk before recording on file, or placing any marker on a file, indicating that a person is potentially violent.

You must not accept or consider any information which is or which may be, libellous (i.e. information which is false and derogatory without lawful justification made in a permanent form). If a letter is received, for example in a rent registration case, containing such information, the sender should be notified that correspondence is copied to the other party to the application, inviting them to resubmit the representations without the defamatory statements. If they refuse or do not answer, we may consider redacting the correspondence before copying it to the other party. If you are not sure whether the information is or may be libellous then please seek guidance from the Rent Officer Technical Services helpdesk. Sample letters to be used in Fair Rent cases are available from the operational forms section on the intranet site.

There is some information that we will not release to individuals. The information held on files which individuals must not be allowed access to are:
- documents which have been produced by a court or have been placed in the custody of the court or tribunal relating to proceedings;
- documents which are created by or given to a person conducting an inquiry (e.g. internal emails relating to any proceedings or internal investigation);
- documents relating to ministerial correspondence or communications;
- personal information relating to anyone other than the individual e.g. certain letters from a third party, details of previous tenants, specific market evidence which may identify individual properties. Please note landlords must not be allowed access to Housing Benefit files or information about specific claims. Determinations and redeterminations relate to specific housing benefit claims by tenants in the private sector and are confidential
- commercially sensitive information e.g. specific information about lettings information or agents’ portfolios
If an identical or similar request by the same individual has already been complied with, then you do not need to comply with a request unless a reasonable interval has elapsed between compliance with the previous request and the making of the current request.

Individuals rights of access

The ‘Right to Access’ is one of the rights enhanced under GDPR and enables the individual to obtain the following:
- confirmation their personal data is being processed
- a copy of their personal data; and
- other supplementary information – this largely corresponds to the information that is provided in our privacy notice.
The legal term for a request for personal information is a ‘Subject Access Request’ (SAR). A SAR is any request (including verbal) from an individual to an organization asking to know what personal data is held about them and what data is being processed.

Identifying a request

Given the timescales it is vital that any requests are acted on promptly and correctly.

The request does not have to specifically mention GDPR, Data Protection Act or Freedom of Information in order for the request to be treated as a SAR, as long as it is clear that the individual is asking for their own personal data. It is up to us to recognise that the customer is using their lawful right to access their personal data.

If you are unsure about whether you have received a SAR please speak to your manager as soon as possible.

What should you do if you receive a Subject Access Request?

We may receive a SAR:
- verbally (Face to Face or over the telephone)
- electronically or
- in writing
In each case, before we disclose any information we need to be certain of:
- The requester’s identity
- Their exact requirements
- Their legitimate link to the information
- The legality of disclosure
Handling the request

If someone approaches us and asks for all the personal information we hold on them, there are a number of places where the information may be held.

Generally requests are made following contact with one of our business areas/units within the VOA and relate to what has been undertaken and should be handled by that business area/unit.

If the applicant is unable to provide details of what information they wish to view you should help them with their request and explain the sort of thing they may want to see, e.g. the original HB referral form / RR1, the HB or Fair Rent worksheets or copies of the decision sent back to HB.

It is important that any information provided relates only to that person or property and you should be fully satisfied that the request is made by the Data Subject or have written verifiable consent of the Subject e.g. a letter of authority enclosed with a solicitors letter. Any information on the file relating to another person or property should be fully removed/redacted. Likewise if lettings information is being provided the addresses must first be fully redacted in accordance with VOA policy. See RO Handbook – Redaction of Lettings Information.

If the request is not clear about the information being requested we can ask the customer for more information to clarify their request, if appropriate. This is to help us find the information they are seeking. We must let the customer know as soon as possible that we need more information from them before responding to their request.

If there is no clear link to a business unit/area forward the request to the Information Rights and Ministerial Correspondence Team. They will ask the customer to clarify their request.

If a request mentions GDPR or is stated to be a SAR, if there is no existing case, send it to the Information Rights and Ministerial Correspondence Team.

The Information Rights and Ministerial Correspondence Team deals with such ‘formal’ requests for personal information, these are known as Subject Access Requests (SAR) and should be forwarded immediately to xxx@xxx.xx (mailto:xxx@xxx.xx).

The Information Rights and Ministerial Correspondence Team will consult Rent Officers to establish any background and details required before responding.

Once a request has been made our records are ‘frozen’ and we can’t destroy or weed out any undesirable information.

Time Limit

We have up to one month from the date the request is received anywhere in the Agency, together with enough details to allow us to locate the information and satisfy ourselves about the identity of the person making the request, to reply.

The time limit is calculated from the day after we receive the request, whether that day is a working day or not.

Where we need to ask the individual to confirm their identity or to provide more information about the information they are seeking, the period for responding to the request begins when we receive the additional information.

However we do have the option to extend this by two months in more complex or difficult cases. We must let the individual know as soon as possible, and within one month of receiving their request, and explain why the extension is necessary.

Related Pages
- FOI and GDPR Protocols
- information requests under FOI
- Redaction of Lettings Information
Correspondence and FOI/DPA protocols for rent officer teams

(v. 1 2022)

Procedures to follow when requests are received by Rent Officers (RO).

All correspondence should ideally be sent to VOA via the CSC. This page provides information on how to deal with correspondence if received locally.

General correspondence (no mention of FOIA or UK GDPR)

Any general correspondence must be forwarded to the CSC. Letters are logged, scanned and attached to the relevant V4 case by CSC. A copy is sent to the relevant RO to respond if necessary and copied to the Hub Manager. If no action is required the RO should add a case note to clarify that no further action is necessary.

Other correspondence

MP Letters – letters submitted by an MP on behalf of a constituent.

These requests are handled by the Strategic Engagement Team. As there is a strict 15 working day deadline for these cases, they must be sent on day of receipt to: xxx@xxx.xx (mailto:xxx@xxx.xx)

Complaints should be sent to the Complaints Investigation Team. Please email to: xxx@xxx.xx (mailto:xxx@xxx.xx)

Any ‘other’ correspondence received should be sent straight to CSC via the NSO Helpdesk immediately to ensure correct logging and targets are met. ‘Other’ correspondence would be:
- Councillor letters
- Requests for information
- Any other letter that doesn’t fall under general correspondence.
CSC will allocate to the appropriate person to liaise with the provide a response.

Freedom of Information Act 2000 / UK General Data Protection Regulation (UK-GDPR)

Any request that mentions the FOIA or Data Protection legislation, should be forwarded immediately to the Strategic Engagement Team.

FOIA requests must be emailed to: xxx@xxx.xx (mailto:xxx@xxx.xx)

Data Protection / UK GDPR must be emailed to: xxx@xxx.xx (mailto:xxx@xxx.xx)

The Strategic Engagement Team will either deal with the request, or advise on the appropriate handling of the case.

There are strict statutory timeframes for responding to these requests so they must be treated as urgent and sent over to the appropriate team immediately.

In order to follow this protocol, local teams must be able to recognise requests made under FOI. If a request is submitted that mentions the FOIA, you should seek guidance from the Strategic Engagement Teams FOI section.

If a requester asks about their own information, it should be sent to their SAR section.

If there is no mention of FOIA or Data Protection legislation but you are unsure about how it should be handled, you should contact RO guidance for help.

Information retention

(v. 1 2024)

Rent Officer practice in relation to retention of paper records.

1. Introduction

This Information Retention guidance covers rent officers’ operational casework files and other information obtained as part of rent officer (RO) functions. It is designed to provide a consistent and cost and space efficient filing system. Personnel, management, administration and other VOA files are not covered by this guidance.

2. Overview

It is a key principle behind our filing policy that as much filing as is possible should be electronic. There are situations where there is no alternative to paper records (for instance: where there are paper applications). The aim is to keep as much information as possible on the relevant VICTER electronic case file record and to remove as many unnecessary hardcopy records as possible.

Guidance on the retention of paper documents once they have been scanned and attached electronically to file records in the VICTER system is included below.

There must be a continual review to remove papers and files from manual filing systems when the timescales below have elapsed.

3. Housing Benefit files

Paper HB referral forms are stored in date order of receipt in the Customer Service Centre and would not normally be needed once the details have been input onto VICTER. Rent officers should take the referral details as transcribed onto VICTER as an accurate reflection of the paper referral. Referral forms over 3 months old should be removed and securely disposed of.

Complex referrals such as those relating to supported accommodation, including schedules of services etc., should be scanned and attached to the VICTER case, and the papers securely disposed of after 3 months.

There should be no other papers retained for HB cases. Any inspection sheets or notes taken during the course of the case should be entered onto VICTER at the appropriate screen. ‘Case notes’ on VICTER should be used to note anything relevant that may not be recorded elsewhere.

Correspondence including representations received for redetermination cases may be scanned and attached to the relevant case on VICTER. The paper documents may then be securely disposed of after 3 months.

Any hardcopy paperwork that is kept longer than this should be reported to the Information Asset Owner (to be contacted through the DIS mailbox) with details of why further retention is necessary.

4. Fair rent files

Any paper files where there has been no activity (i.e. an application for registration of fair rent) for at least 5 years should be removed and destroyed. The only records retained for such cases are those on VICTER.

Paper applications including RR1s, service schedules and any correspondence received or sent are scanned and attached to the VICTER case record. The attachments are retained on VICTER so the paper applications may be securely disposed of after 3 months.

The following documents may be scanned to the most recent VICTER case:
- any tenancy agreement
- any furniture inventory
- the most recent plan of the property, (and if necessary a plan of the property as let if the tenant has carried out substantial improvements/changes during the course of the tenancy)
- any other information that is specifically referred to on the current rent register
- consultation notes
- items of relevant correspondence
- this list may not be exhaustive – if in doubt please seek guidance
Once scanned and retained electronically, paper copies should be securely disposed of.

Any paperwork kept for more than 5 years should be reported to the Information Asset Owner as above.

5. Non-statutory advice

Any hardcopy paperwork or files for non-statutory advice (dealt with in the “informal advice” function in VICTER) should not be kept for longer than 3 months after the case has been closed. This refers to the applications for Equivalent Fair Rent for Almshouses. Any cases where retention of paperwork for more than 3 months is being considered should be cleared with management in consultation with the guidance unit. The information for future reference is retained electronically on the VICTER record, and any necessary invoicing information will be retained by the finance department.

6. Lettings information paperwork and VIS records

Rent officers obtain hardcopy paperwork about lettings information. This could either be produced by third parties, such as agents’ lettings lists or rent rolls, or produced by us, pro-formas for instance. Any relevant information on such paperwork should be transcribed onto VIS within 5 weeks of collection, so it can be accessed for our valuation and determination roles.

The original hardcopy paperwork should be labelled with the collector’s name and the dates of collection and entry onto VIS. In addition the contacts name should be recorded as well as appropriate notes about the property and rent achieved. It should then normally be filed and retained for 30 months, except where the LHA rate is being maintained at a previous years’ rate, and therefore the LI is still in use beyond the 30 month retention period. In those instances the LI should be retained until the rate is next updated.

This fulfils the audit requirement to be able to check the data used to compile the lists of rents used for the compilation of the Local Housing Allowance rates, which may be applied to current claims for HB or Universal Credit. It also fulfils the requirements of the Office of National Statistics as they use the data to help calculate the Consumer Prices Index.

7. Disposal of paperwork

Any hardcopy paperwork being disposed of must be placed in the secure recycling receptacles in VOA offices. Under no circumstances should any paperwork from any rent officer files be disposed of by any other method or at any other site without clearance from line management.

This includes disposal of paperwork by all staff in all circumstances, including home workers.

Redaction of lettings information

(v. 1 2024)

It is important we are consistent in providing information to members of the public. Lettings information cannot be given out to members of the public in the format in which it is stored on VIS. Full addresses are capable of being personal data and the process of making the data ‘confidential’ can be time consuming. Postcodes can be unique and are capable of being personal data. Obviously, we must not breach our data protection or commercial confidentiality responsibilities.

Explaining our determinations

For the above reasons, lettings information lists (intended for individual members of the public to support our decision-making) must be requested from VICTER in ‘confidential’ format (which automatically removes some columns) and must then be made completely ‘anonymous’ (‘redacted’) by removing any of the following that remain:
- landlords/agents and other source details
- all road names
- the last half of the postcode of properties (i.e. to leave SK10 instead of SK10 1XY)
The Rent Officer Technical Services team usually recommends that a maximum of the following columns of information are provided when lettings information is sent to a claimant or their representative:
- Market Rent
- Ineligible services
- Net Ret
- Period (Cal month etc)
- Trans’ (Y or N)
- Date of entry
- address (as redacted)
- postcode (as redacted)
- property type
- dwelling type
- sole LR
- sole BR
- sole rooms
The redaction of other columns allows the LI to fit neatly on a page. We must also provide similar lists from which we have extrapolated or interpolated where appropriate.

For some enquiries, instead of providing LI lists, it may be sufficient to tell enquirers the number of pieces of transactional evidence used in reaching decisions. We normally only provide LI when specifically asked for it. If appropriate, we can give additional information such as explaining the spread of the evidence within the BRMA. We should also explain the significance of only using transactional evidence compared with ‘advertised’ or non-transactional evidence, if this is appropriate for the list provided.

To help explain a decision, rent officers could in certain circumstances send claimants (or solicitors or their representatives) a graph showing the spread of transactional and supporting evidence used, or a GIS map showing the spread of lettings information or evidence across the locality or BRMA. However, as above, the provision of such graphical information in response to enquiries must be cleared first with the Rent Officer Technical Services helpdesk in the interests of quality assurance and ensuring consistency in the responses that we give.

In isolation, providing lettings information without contextual explanations can be misleading. Rent officers and their managers should be able to demonstrate that they have gathered a full picture of the rental market in reaching their decisions. It may be appropriate to give details of data that has been extrapolated or interpolated from, in accordance with rent officers’ guidelines, or to explain how socio-economic information or HB referral data has been taken into account in order to add to this full picture of the rental market. Rent officers should explain that lettings information is used to guide expert decision-makers but, ultimately, determinations are a matter of professional judgement. Again, such explanations should be cleared by the Rent Officer Technical Services helpdesk prior to dispatch.

Lists of Rents

Requests for the data used to compile Local Housing Allowances, the Lists of Rents (LoR), should be directed to the online publication page at Local Housing Allowance List of Rents - GOV.UK (https://www.gov.uk/government/collections/local-housing-allowance-list-of-rents).

Many requests for our data are received electronically, by email, and increasingly this is the preferred method of providing information in response. Great care should be taken if any redacted data is being provided electronically, because even if a spreadsheet is redacted and converted to a PDF document, it may be possible for that document to be reconverted by the recipient and the redacted data revealed. The recommended VOA policy on this is for the redacted document to be printed, scanned, and then emailed as a PDF. An alternative for those with limited or no access to a scanner or a printer is to create a new document or spreadsheet and copy the redacted information into it, column by column or field by field. The crucial element to our policy is never to send redacted documents containing background data electronically outside of the organisation.

Comparables and representations

When dealing with registration of rent casework, landlords and tenants and their representatives may submit lettings information in support of their requested rent. It is vital to ensure we comply with data protection provisions to ensure that such representations are redacted similarly to data from VIS used to explain our decisions, by removing any information which may lead to the identification of a specific address or a living individual. House numbers, road names and the second half of the post codes must be carefully blanked out. Only then can the representations be safely copied to the other party to the application for rent registration. They must be copied to the other party to serve the interests of natural justice, to allow the opportunity of counter representations.

Related pages
- Judicial reviews
- Explaining FR valuations
- Freedom of Information Act – dealing with information requests
- General Data Protection Regulation
- FOI/GDPR protocols
Lettings information - data security

(v. 1 2024)

Rent Officers collect lettings information either in hard copy or alternatively by electronic transfer. Due to the sensitivity of this information, it is necessary to keep these records in a secure manner at all times.

Data Entry

Once material has been obtained, it should be transferred on to VIS as soon as possible so that the information becomes available to support our valuations.

Rent Officers must enter data on to VIS within 5 weeks of receipt or should be diarised for entry at the tenancy commencement date if that is later. Exceptions as always should be reported to line management.

A hard copy cover sheet should be attached to the data entered, identifying the source, date of entry and filing date. This data should be stored in a secure cabinet in a VOA office within 6 weeks of collection.

Data that is received electronically (such as email or software reports) must be printed off, entered on VIS and stored like other hard copy data. Once the data has been entered on VIS, and the hard copy filed, the electronic file must be deleted.

Hard copy data when filed, should be placed in bundles with the correct number of papers in each bundle recorded on the cover sheet. Details of the lettings collected and filed from the data source should be recorded.

Quality Assurance

Team Managers are responsible for conducting a quarterly quality assurance review of the evidence entered on VIS. If no hard copy can be found for a piece of lettings information entered, this is escalated as a potential security breach. Guidance can be found for the correct process to follow on the Intranet.

Retention

Hard copy paperwork should be labelled with the collector’s name, date of collection, entry on to VIS and the rent achieved. Once filed, the information should be retained for 30 months. Once 30 months has expired, the LI data has to be removed and disposed of securely. This is done by placing the data in the secure recycling receptacles positioned in VOA offices. In no circumstances should data be disposed of in any other way.

Removing records from secure storage

If records from a secure filing system are taken from an office for whatever reason, the movement and likely time of return must be recorded. Hard copy lettings records should not be removed without G7 approval. Local offices must implement a system of logging records in and out so that they can be tracked. It must also include the Grade 7 approval if this was necessary. When the record is returned the actual return date should be added. Hard copy records should only be removed when absolutely necessary and returned promptly.

The record should be reviewed by line managers regularly and if there are records still outstanding, these should be investigated and if there are any missing they must be reported as a potential security incident within 2 working days. If any hard copy information can’t be found and it is suspected that it may be lost, it must be reported to line managers immediately and a security incident recorded within 2 working days.

Collecting Data

When officers are collecting lettings information from landlords’ agents or landlords’ themselves, they have to minimise the potential risks of data loss. Data must be stored in a secure bag and the data from different sources should be kept separate. We must be careful not to allow anybody to view data that we have not collected from them. Data suppliers must trust us to look after their data carefully and securely.

Related pages
- All pages on Lettings Information