Homes for Ukraine - Privacy Notice

Who the Council is and what the Council does

Cotswold District Council is a data controller under the Data Protection Legislation as the Council collects and processes personal information about you in order to provide services and meet their statutory and regulatory obligations.

The Council provides services for local communities and the people who live in them. Undertaking this work means that we must collect and use information about the people we provide services to and keep a record of those services. Because we collect and use personal information about individuals we must make sure that they know what we intend to do with their information and who it may be shared with.

This privacy notice covers the Homes for Ukraine scheme as enacted by the UK Government.

Any questions regarding our privacy practices should be sent to:

Data Protection Officer (DPO)
Cotswold District Council
Council Offices, Cirencester, GL7 1PX
Email: data.protection@cotswold.gov.uk
Tel: 01993 861194

Why the Council needs your information and how the Council uses it

This scheme will support Ukrainian people with housing, education, health and integration into the community. As well as supporting the people who volunteer to sponsor Ukrainian people and their families.

It must be noted that during this time Councils have to quickly change the way in which they are working to continue to provide you with the support and services you need. We will always follow advice and guidance from the UK Government when making any changes to the way in which we provide you with the support you need.

We will use the information you provide to:

Facilitate the Homes for Ukraine sponsorship scheme within Gloucestershire
Undertake assessments to establish what support we can put in place for you and your family, as well as assessing the sponsor household
Keep a record of the support that we will be providing to you
Undertake regular reviews to establish whether the programme is working for you, or whether we need to change anything to help you

This will include:

Developing post arrival support plans involving organisations such as health and support services

We also use this information to assess the quality of our services and evaluate and improve our policies and procedures.

We may also use information in other ways compatible with the above.

What is the legal process for collecting and processing this data

We have legal grounds under the GDPR to process this information because it is necessary:

For the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller (Immigration and Asylum Act 1999)
To exercise a function of the Crown, a Minister of the Crown or a government department

We have legal grounds to process (including share) special category data and criminal convictions data because it is necessary:

For the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller (Immigration and Asylum Act 1999)
To exercise a function of the Crown, a Minister of the Crown or a government department

What type of information is collected from you

To enable the Council to co-ordinate and deliver appropriate and suitable housing and accommodation offers provided by vetted sponsors, to visa-cleared applicants to the scheme fleeing the conflict in Ukraine, we will process the following information.

"Guest" or "guests" refers to an individual or household previously resident in Ukraine, before 1 January 2022, who have secured a visa under the Homes for Ukraine scheme, which enables them to be housed by a sponsor.

Name
Address
Contact details including telephone number, email address
Date of birth
Visa / passport information
Family members information, including any children
Disability and health information
Ethnicity
Information relating to any safeguarding concerns
Religion

We receive most of this information from you, but we may also get some of this data from:

The Home Office (central government)
Department for Levelling Up, Housing and Communities (central government)
Other central government agencies
Disclosure and Baring Service providers

We also get empty property/2^nd home owner information from the Council Tax Service so we can give information to property owners about the Homes for Ukraine Scheme that bring empty properties into use by providing accommodation to Ukrainian refugees (see our Council Tax privacy notice).

Profiling

Profiling means any form of automated processing of personal data, consisting of the use of personal data to evaluate certain personal aspects related to a natural person, in particular to analyse or predict aspects concerning performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Who your information may be shared with (internally and externally)

We may need to share your information with:

Gloucestershire County Council
The Home Office and the Department for Levelling Up, Housing and Communities via Palantir*
Other Council services
Other local authorities, including district councils
Other central government agencies
Charities and other voluntary organisations who may be able to provide services to you

*Palantir was appointed by DLUHC (Department for Levelling Up, Housing and Communities) and the Home Office, as a Data Processor, to assist with the collation, secure transmission and sharing of your personal data with local authorities in England and their internal services via the “Foundry” platform, which has been procured for this purpose. All personal data related to the Sponsors and Guests is centralised in ‘Foundry’ and can be accessed securely only by authorised personnel working for the Homes for Ukraine Scheme.

Any information which is shared will only be shared on a need to know basis, with appropriate individuals. Only the minimum information for the purpose will be shared.

Your personal information may also be given to third parties contracted by the council to provide a service to the council. These service providers are known as data processors and have a legal obligation under the UK General Data Protection Regulation (UK GDPR) and to the Council to look after your personal information and only use it for providing that service.

How long the Council keeps your information (retention period)

Your personal information will be securely deleted and destroyed within three years from the closure of the Homes for Ukraine sponsorship scheme, unless the Department for Levelling Up Housing and Communities and/or the Home Office identifies that information should be securely deleted and destroyed before then.

How the Council protects your Information

All the information The Council collects is stored securely on our IT system and manual filing systems. The Council has strict procedures for the way this is done. Any and all information about you is treated as confidential and with respect. There are also clear rules and guidance about storing, recording and sharing information which staff receive training on. The Council will not transfer your personal data outside the EU without your consent.

The Council have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.

Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.

The Council will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.

Your rights

You have the following rights under the Data Protection Legislations:

To access your personal data
To be provided with information about how your personal data is processed
To have your personal data corrected
To have your personal data erased in certain circumstances
To object to or restrict how your personal data is processed
To have your personal data transferred to yourself or to another business in certain circumstances
To be told if the Council have made a mistake whilst processing your data and the Council will self-report breaches to the Commissioner.

How you can access, update or correct your information

The Data Protection law gives you the right to apply for a copy of information about yourself. This is called a ‘Subject Access Request'.

If you wish to see a copy of your records you should contact the Data Protection Officer. You are entitled to receive a copy of your records free of charge, within a month.

In certain circumstances access to your records may be limited, for example, if the records you have asked for contain information relating to another person.

The accuracy of your information is important to us to be able to provide relevant services more quickly. The Council is working to make our record keeping more efficient. In the meantime, if you change your address or email address, or if any of your circumstances change or any of the other information the Council holds is inaccurate or out of date, please email us or write to us at:

Ukraine Support Team
Cotswold District Council
Council Offices, Cirencester, GL7 1PX
Tel: 01285 623000
Email: Ukraine.support@cotswold.gov.uk

Further information

If you would like to know more about how the Council uses your information, or if for any reason you do not wish to have your information used in any of the ways described in this privacy notice, please contact the Data Protection Officer on data.protection@cotswold.gov.uk.

For more information about data protection please visit: www.cotswold.gov.uk/about-the-council/council-data-and-access-to-information/data-protection/

If you are concerned about the way the Council is handling your personal information you can contact the Information Commissioner (ICO): https://ico.org.uk/make-a-complaint/

The Council reserve the right to update this privacy notice from time to time by publishing a new version on our website.