Requiring the entire agency's salary table is an attack on personal data
As Lao Dong reported that many people submitted documents at the CT3 Kim Chung social housing project, Thien Loc commune (invested by the consortium of Hanoi Housing Investment and Development Corporation and Viglacera Corporation - JSC) reflecting the investor's unreasonable request to supplement documents.
Accordingly, in the case where employees have labor contracts, receive salaries in cash and have a salary table confirmed by the company, the investor of the CT3 Kim Chung social housing project still requires a photocopy of the salary table of the entire company.
Talking to Lao Dong, Mr. Nguyen Anh Que - Chairman of the Board of Directors of G6 Group - said that as a business participating in the development of many social housing projects, while consulting and reviewing customers' documents, all units must comply with legal regulations.
According to current regulations, the income condition applied to social housing is under 20 million VND/month for individuals and under 40 million VND/month for households. Regarding income proof, the law requires the provision of salary table or statement for the last 12 months.
"Workers receiving transfer salaries only need a photo of the salary table with the company's confirmation. In case of receiving cash salary, the enterprise where they work only needs to confirm the monthly income level, as long as it is in accordance with regulations. Currently, there is no regulation requiring employees to submit photo sheets of the entire company - Mr. Que emphasized.
He said that requiring people to provide salary tables for all employees is "not in accordance with regulations and showing signs of violating the law".
First, the law does not require this. Second, the salary table is the secret of the enterprise. Third, this requirement causes difficulties and obstacles for people in accessing social housing, he said.
Mr. Que said that if his company's employees are required to provide the salary table of the entire company to complete the social housing purchase documents, he will not accept it.
"I sympathize with the staff, but the salary table is internal information of the business. We only confirm the income of employees for 12 months, but cannot provide the salary table for the entire company" - Mr. Que affirmed.
Mr. Nguyen Hoang Nam - General Director of G-Home Joint Stock Company - a company specializing in developing social housing - said that the principle of determining income has been clearly regulated: the person declaring income must take responsibility for the information provided, while the agency or enterprise confirming income must also be responsible before the law for its confirmation. Currently, the law does not stipulate that home buyers must pay the salary table of the entire agency.
According to Mr. Nam, in reality, there are some cases of asking for income confirmation that are not in accordance with the actual salary level. However, the law has a post-inspection mechanism, if they confess, they will be prosecuted, and may even be held criminally responsible.
"It is impossible that investors are worried about false declarations and require people to provide documents outside of regulations, even tighten the records by illegal requests - especially documents related to the income secrets of colleagues or organizations, which could violate the Law on Personal Data Protection" - Mr. Nam emphasized.
He proposed that there should be regulations requiring all social housing buyers to be ready to face inspections and checks when necessary.
"We must be heavily fined, even prosecuted, then the situation of false statements will end" - Mr. Nam emphasized.
Many social housing projects require "child licenses"
In the fourth quarter of 2025, many social housing projects in Hanoi will open for sale, attracting thousands of people to submit applications. However, the process of reaching people's dream of settling down is not easy because many investors require additional "child licenses" not included in the provisions of law such as residence confirmation and confirmation of social insurance (SI).
Accordingly, in addition to the requirement to photocopy the salary table of the entire company, the investor of the CT3 Kim Chung social housing project also requires people to submit additional notarized copies of the Permanent/Temporarily Residence Certificate.
Or at the Rice City Long Chau social housing project (The investor consortium is Him Lam Capital Joint Stock Company and BIC Vietnam Joint Stock Company as the investor) also requires people to supplement their residence certificate and social insurance.
Explaining this, Mr. Le Quang Huy - Deputy General Director of BIC Vietnam Joint Stock Company - said that people who are required to register for permanent/temporary residence according to the 2020 Residence Law and guiding documents) have a need for housing and can buy social housing in the Hanoi area, which is well-founded because the Social Housing Fund of each locality is planned based on population and actual housing needs.
If the conditions for permanent/temporary residence are not bound, it will cause an imbalance in the allocation of housing funds, affecting the rights of people living stably in the locality.
Mr. Le Quang Huy said that by having to prove that participating in social insurance, this will immediately eliminate the components of fraudulent records and falsified records, while also minimizing risks, post-inspections and even recovering apartments for the wrong beneficiaries of social housing policies for the buyer or lessee of social housing.
Commenting on this issue, lawyer Nguyen Van Dinh (Hanoi Bar Association) said that the sale, lease-purchase, and lease-purchase of social housing; beneficiaries of the State's support policies on social housing; procedures for selling, leasing, buying, leasing social housing... have been stipulated in the Housing Law 2023, Decree No. 100/2024/ND-CP (amended by Decree No. 261/2025/ND-CP) and instructions in Circular No. 05/2024/TT-BXD. The law on housing is not assigned, decentralized, or delegated authority to localities or investors to issue documents and other conditions not included in the provisions of the above legal documents.
Therefore, the investor's request for a "sub-license" as a certificate of residence information for the petitioner who does not have a permanent registration in Hanoi is not in accordance with the provisions of the law on housing.
"Investors setting up documents that are not in the law themselves is a violation of the law on social housing, creating "technical barriers" to access social housing for customers, so it needs to be corrected and handled" - lawyer Nguyen Van Dinh emphasized.
According to Mr. Nguyen Hoang Nam - General Director of G-Home Company, in the past, some investors have requested many additional types of "sub-licenses" such as confirmation of residence, confirmation of social insurance... even though these conditions are no longer regulated by law.
"The responsibility for the appraisal belongs to the State management agency. If there are violations, the Department of Construction will check and handle them. We cannot, out of fear of responsibility, shift the burden to the people by making illegal demands. This approach Invisibly limits access to social housing for those who are qualified" - he commented.
