DWP are sending me claimants NI numbers – ICO complaint

DWP are sending me claimants NI numbers – ICO complaint

11:31 AM, 28th February 2019, About 3 years ago 14

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Dear Information Commissioner,

DWP are disclosing multiple tenants’ National insurance numbers to me.

I am also copying in some of the Universal Credit UC staff that I have been sending the below to, some quite high up people actually, so you can see the UC Director Generals know about this, but have done nothing. The local job centre staff are innocent in this.

Please find enclosed screenshots of the DWP Universal Credit UC sending me National Insurance numbers for my tenants.
Should they be doing this?

All I want, as Housing Benefit have been doing for 20 years, is for UC to put the tenants rent in my bank with a reference that I can then use to identify which particular tenant it is for.

I do now know all my tenants National Insurance number, they are releasing this to me without the permission of the tenant.

I can get some tenants to back up that they are fuming with this too if you like.

My complaint is now with ICE who are taking 18 months to look at complaints. As DWP  UC just don’t take any of this seriously, I’ve not had one phone call from them about it, but the ICO I am told are interested in this. If you going after them for this and it solves my Ref number requests, then that is good for me.

Please take a look and ask me for anything as I have loads more, just not got time to send it all to you at moment.

I have sent and asked DWP many times and alerted them that they are using tenants Ref Number in payments and it’s like 2 year old kids replying.

If you fine them £1 million pound plus, because you can guess they doing it to other Landlords (which I will get for you too if you wish to pursue), then UC WAKE UP AND COMMUNICATE WITH US.

Yours sincerely




12:04 PM, 28th February 2019, About 3 years ago

You could just keep a note of your tenants national insurance numbers and match them to whichever property they live in which you have a legal right to keep for when payments come in.
This is how we keep track with our tenants payments via universal credit instead of being on the phone for up to an hour a time. As a landlord you are perfectly entitled to hold a tenants national insurance number under GDPR as this is used as a form of ID under the right to rent.


8:36 AM, 1st March 2019, About 3 years ago

I have asked UC repeatedly to reference my tenants rent by their names but they have just ignored this and used the NI number. Makes life far more difficult when working out who the rent is for. I did have one tenant who was extremely annoyed that I asked her NI number which she did not give until I informed her that I would not be able to confirm that her rent was paid unless she disclosed this. She very reluctantly disclosed this information. I now as a matter of course ask the tenants their NI number prior to the start of the tenancy.

Mick Roberts View Profile

8:41 AM, 1st March 2019, About 3 years ago

I agree Chris, we could keep their NI number, but it's not the answer.
We can't let UC get away with this, or they will be back to charging premium rate phone numbers for vulnerable tenants as they was 4 or 5 years ago & back to 6 weeks before payment which we've now got down to 5.

Why should I have to keep checking & cross referencing & find a NI number for a particular tenant, when for 20 years & UC was for first 2 years, putting the House & tenant as reference.
Example Elaine lives in 20 Sandon Street. So UC would ring me (up to only a month ago) & ask what reference I would like & I would say San20Ela simples. I understand it.

When I go on holiday, I don't want to take a database of tenants NI numbers with me, nor do I want to concentrate on searching for NI numbers for particular tenants.

But I do NEED to know which rents have come in & not come in, so I can at least start the process off of trying to recover & find out why rent hasn't come in. A NI number isn't gonna' solve this & put me & tenant in a mess if we delay the chasing.

What about tenants that don't want me to have NI number? Where is their choice?

I've since had email from a UC manager who acknowledges they should be there & they don't know why they aren't on any more.

It's basic 2019 human rights that when we u I set a bank payment up BACS Standing order etc., the bank says put the reference here so the receiver knows who has sent. So many million people in UK do this. Yet UC's bank must be on Planet Mars.

Mick Roberts View Profile

8:44 AM, 1st March 2019, About 3 years ago

Reply to the comment left by Clint at 01/03/2019 - 08:36
Clint, I agree, there is no need.

Clint please complain so we can get this changed.

Some tenants are going to be evicted soon by some Landlords once he starts getting 20 payments in one day & he is expecting 22 & he hasn't got a clue who's rent HASN'T come in. So he's gonna' have to give Section 21 to them all.

Robert M View Profile

10:11 AM, 1st March 2019, About 3 years ago

When potential tenants apply for housing with me, I get a housing application form completed which asks the tenants for the information that I may need in order to process their application, AND do their HB claim if necessary, so this form includes their National Insurance number.
I can then use this NI number when applying for direct deductions from their benefits, e.g. for rent arrears, so having the NI number is vital. I also ask the tenant for proof of their benefits (a "benefit entitlement letter"), so that I can ensure that the information is submitted with their HB claim, and of course that letter will also contain their NI number.
I therefore don't see any problem with UC (DWP or Councils) stating the NI number on documentation to me, in my opinion it is not a breach of GDPR as it is information that I have a legitimate reason to have.

However, when the DWP (UC or otherwise) send me the payment statements, I agree with you that it would be better if they could also provide the reference that the landlord has requested, so as to make it easier for the landlord to allocate the payments to the correct rent accounts.

Mick Roberts View Profile

11:44 AM, 1st March 2019, About 3 years ago

Yeah Rob, it's not major problem, & I am making it worse cause of all the other problems I am having with UC.

But I do genuinely get 20 rents go in the bank on the same day with HB.
HB itemise as u know each tenant with their amount & it goes in in one amount.
But cause it says Elaine £433.04 & Lena £606 etc. I know what each one has paid & that they have paid.

UC are doing each one SEPARATE with just a NI Number. I sometimes check rents while I am out on phone, & on way to tenants can tell them their top up due on that day. But with UC using NI numbers, I han't got a clue who's rent is what.

I'm making a mountain out of it cause ICO so far cannot believe UC are sending me these NI numbers willy nilly & if going that route gets UC to start putting the Ref numbers back on, so be it.

You've hit the nail on the head Rob.
it would be better if they could also provide the reference that the landlord has requested, so as to make it easier for the landlord to allocate the payments to the correct rent accounts.


12:33 PM, 1st March 2019, About 3 years ago

Reply to the comment left by Mick Roberts at 01/03/2019 - 11:44
Yes, it worked out well with HB where all rents were paid on the same day with names and addresses included. I had around 30 rents to check but now it is a nightmare. Worse still, the "Managed Payments" and "Third party Deductions" payments are made separately so a landlord could be getting two payments each month for the same tenant.

If one needs lessons on how to complicate and make things as difficult and as ambiguous as possible, they need to attend the “Universal Credit School” which is definitely the very best.

In respect of complaining, I have made several complaints which are at stage 2 of their complaints (Besides stage 1 complaints already made, have also made all other various complaints to staff I was told to address my complaints to) procedure and have not had a single reply or acknowledgement where correct procedures have not been followed in respect of tenants being more than two months in arrears and rent being paid to me. I am now trying to find the time to raise the complaints to the District Attorney in respect of the complaints already made which will ultimately possibly be raised to Amber Rudd.

I am finding that UC have created more than a full-time job excluding all the other work related to renting out properties.

Robert M View Profile

12:35 PM, 1st March 2019, About 3 years ago

Reply to the comment left by Mick Roberts at 01/03/2019 - 11:44
It would be great if they put the correct reference against each payment, but there are far far bigger problems with UC, e.g. them not acknowledging or dealing with UC47 forms, them being unwilling to communicate with landlords, them ignoring correspondence, them not dealing with complaints, the lack of flexibility in how a UC claim is made, the delays, the wrong decisions, the waiting periods before payment, the problem of tenants who have two payment days in a month, etc, etc, - the list of issues is endless!!! - so them providing NI numbers is perhaps at the bottom of an extremely long list of problems with the UC system.

Mick Roberts View Profile

12:58 PM, 1st March 2019, About 3 years ago

Reply to the comment left by Clint at 01/03/2019 - 12:33Brilliant Clint,
I need more of u & us to start these complaints.
Please use me & bring my cases up in your complaints.
I had Independent Case Examiner ICE ring me after your reply this morning, I said I have another Landlord this morning say the same no reference numbers.
I said u have got to start taking these complaints much sooner & stop giving Stage 2 months & months & so many last chances to reply. They delaying cause know u won't look for months & then ICE are another 18 months, by that time, the UC staff has moved office so he gets no blame. Just like the MP's.
Exactly, it's like a full time job just UC & I don't have that many tenants switched to it yet.

Mick Roberts View Profile

13:00 PM, 1st March 2019, About 3 years ago

Reply to the comment left by Robert Mellors at 01/03/2019 - 12:35
Ha ha Rob, the UC47 form. I've actually got now a job centre manager who is taking all my Bulwell ones, so hopefully going forward that may solve my issue with them. If u have local job centre, that may be one avenue to start.

Yes the waiting periods. From day 1, the tenant is now in more arrears, how can they not be? UC is destined to make them fail & put them in debt from day dot. I've opened up the managers eyes to a lot of things she didn't realise. I said they leave here, become homeless, go Housing Aid, u don't see that side of it.

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