Homes for Ukraine Scheme privacy notice

1 Council contact details

1.1
West Northamptonshire Council
One Angel Square
Angel Street
Northampton
NN1 1ED

1.2 West Northamptonshire Council (WNC) collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the United Kingdom General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We are responsible as ‘controller’ of that personal information.

West Northamptonshire Council will work with you under the Homes for Ukraine Scheme. As a local authority, WNC will process your personal data to complete all the necessary processes. WNC may also process your personal data to provide interpreting services and provide support and assistance to access relevant services.

1.3 If you would like to contact the team responsible for the Homes for Ukraine Resettlement Scheme please email [email protected]

2 Information that we hold

2.1 We will collect the following personal information when you provide it to us or we receive it from the Home Office, Department of Levelling Up, Communities and Housing, sponsors, or relevant WNC internal teams:

UK sponsors and their families - personal information e.g. your name, age, gender identification, property information including property inspection details, identification documents to support ID verification with the Disclosure and Barring Service for sponsors and their family members over the age of 16
Ukraine individuals and families - personal information e.g. your name, age, gender identification, passport details, address (if you're not staying with a sponsor), application number, arrival date, status of application, contact details e.g. email address, telephone number.
We also collect the following ‘special category data’ (personal data which is more sensitive and is treated with extra care and protection) when you provide it to us:
- information about your racial or ethnic origin
- information about you and your circumstances and health e.g. disability, health conditions, housing requirements.

2.2 For further guidance please view the Council’s website and the UK Government website.

3 How the information is obtained

In the course of working with you, we may collect information from, or share it, with some of the following third parties (non-exhaustive list):

Home Office
Department for Levelling Up, Housing and Communities
Disclosure and Barring Service
North Northamptonshire council (NNC)
Northamptonshire Children's Trust (NCT)
sponsors
interpreting services
contact centre for WNC
other local authority teams supporting the Homes for Ukraine Scheme, especially when rematching of accommodation is taking place

3.1 Most of the personal information we process is provided to us directly by you for one of the following reasons:

to process DBS applications for all household members aged 16 and over
to reconcile with personal data provided to the council by the Home Office and the Department for Levelling Up, Housing and Communities
to support the Council’s obligations to ensure that Homes for Ukraine accommodation is checked in line with Guidance for Councils from DLUHC (Homes for Ukraine: guidance for councils - GOV.UK)
to process monthly thank you payments

We also receive personal information indirectly, from the following sources in the following scenarios:

DLUHC government information portal, holding all visa information, including, names, addresses and contact details including telephone number and email address

3.2 When we collect your personal data, we rely on the following legal bases:

Article 6(1)(e) - processing 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

When we collect your ‘special categories of personal data’, (such as health, race, ethnicity) we rely on the following legal bases:

Article 9(2)(g) - processing is necessary for reasons of substantial public interest, on the basis of domestic law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject

We rely on the statutory etc. and government purposes from Schedule 1 Part 2 of the Data Protection Act 2018 when relying on Article(9)(2)(g) to process your special category data.

Where you give us information regarding your health because you require a reasonable adjustment to access our service, we will keep this information with your record to ensure that we can communicate with you in the way that you need. In these cases, we rely on explicit consent.

Where you may require additional support and assistance for care purposes or to access services etc., WNC and other organisations involved will process your personal information to do so. We will also keep a record of this information to ensure that we can continue to provide additional support and assistance where required. In these cases, we rely on our legitimate interests or those of a third party (provided that these are not overridden by your interests, rights or freedoms).

4 What we do with the information

4.1 We use your personal information to:

support the delivery of the Homes for Ukraine scheme
contact you regarding your application e.g., to get missing information, clarify information provided, arrange visits etc.
offer you services that you may need e.g., interpreting services, provide support and assistance to access relevant services.
we may also share with WNC internal teams or to certain external providers we contract
share relevant information with the Department for Work and Pensions (DWP), Disclosure and Barring Service (DBS) to progress your application during your stay within the UK.

The sharing of information facilitates a joined-up approach with partner agencies, to ensure support to the delivery of the Homes for Ukraine scheme.

4.2 The information will only be used for the purposes stated when it was collected. Information will not be sold, rented or provided to anyone else, or used for any other purpose than that for which it was originally collected unless required to by law.

We may share personal information with other relevant WNC teams e.g. private sector housing team, revenue and benefits, adult social services and the contact centre to provide support and assistance to access relevant services.
We may also share personal information with other organisations e.g. charities, public bodies (e.g. NHS, fire service) Northamptonshire Children’s Trust (NCT) and commissioned services etc. or providers that we contract who may be able to support you during your stay in the UK.

Each organisation listed above will ensure they have the relevant agreements in place to be able to process your personal information.

This data sharing enables us to ensure the delivery of the Homes for Ukraine scheme.

We will share personal information with our legal and professional advisers in the event of a dispute, complaint or claim. We rely on Article 9(2)(f) where the processing of special category data is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

We will share personal information with law enforcement or other authorities if required by applicable law. Any information sharing is undertaken in accordance with UK GDPR and the Data Protection Act 2018. We have mechanisms in place to share information lawfully and securely.

5 How long we keep your information for and how we securely dispose of it after use

5.1 We keep your personal information for all aspects of processing in line with the council’s retention schedules.

We will only hold your personal information for as long as necessary. Personal data shall be retained for 2 years upon closure of the scheme, unless the Department for Levelling Up, Communities and Housing and the Home Office identify that continued retention is necessary before 2 years of closure.

5.2 We will securely dispose of your information in line with the council's retention schedules.

6 How we store your information

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

6.1 Your information is securely stored on the council’s systems.

7 Your data protection rights

7.1 The law gives you a number of rights to control what personal information is used by us and how we can use it. Please see section 15 of the council’s Privacy Policy for further information.

7.2 Please be aware that your rights may differ depending on the lawful basis for processing your personal data.

8 Who to contact

8.1 If you would like further information about how we use your personal information, or you wish to exercise one of your data rights or you wish to complain about the use of your personal information please contact the Data Protection Officer.

8.2 If you are still dissatisfied once you have contacted the Data Protection Officer, you have the right to complain to the ICO.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

9 Changes to this privacy notice

9.1 Privacy notices are live documents, which will be updated or revised in line with legislation.

Last updated 09 January 2024