Privacy Notice for the Homes for Ukraine Sponsorship Scheme

Purpose for processing your information

As part of the Homes for Ukraine Scheme, Torridge District Council  will be working closely and sharing personal data with Devon County Council, the Home Office, Department for Levelling Up, Housing and Communities (DLUCH) and contracted local partner organisations such as the Pickwell Foundation.   The sponsorship scheme is being delivered within the District to meet the expectations placed upon local authorities to check that the accommodation provided by sponsors is appropriate and safe and to also check on the welfare of families placed in the accommodation when they arrive from Ukraine.  

The Council will undertake checks on the sponsor's property and will ask for bank details in order that sponsor payments can be processes.

"Sponsor" or sponsors" refer to an individual, group or organisation who has been approved to accommodate a Ukrainian guest or household from Ukraine under the Homes for Ukraine sponsorship scheme. The government privacy notice describes what personal data they will process and share with the council Homes for Ukraine visa sponsorship scheme.

In addition to the Homes for Ukraine scheme for which the Council has specific responsibilities, we also collect personal data in relation to other people arriving in the borough from Ukraine who come to the attention of other Council services. This is to ensure we provided a coordinated approach to people who may be vulnerable and need support.

Lawful Basis for Processing of Personal Data

The Data Protection Act requires that personal data is collected and processed only where there is a lawful basis to do so. The lawful basis which applies in this instance are as follows:

Public task: the processing is necessary for us to perform a task in the public interest and for our official functions, and has a clear basis in law.

Lawful Basis for Processing of Special Category Personal Data

In some cases it may be necessary for us to collect hold and process information of a more sensitive nature. Where this is the case, the lawful basis for us to do so is as follows:

Substantial public interest: the processing has a clear basis in law, is proportionate to the aim pursued and safeguards the fundamental rights and interests of the data subject.

Purpose of Processing Personal information

We are collecting your personal data for the following purposes:

Activities we are required to carry out as a data controller and public authority, specifically the administration of our duties in relation to the Homes for Ukraine Scheme.

We collect the following information

To enable the Council to co-ordinate and deliver our responsibilities under the Homes for Ukraine sponsorship scheme the following information is collected:

· Name of persons in the household

· Address and contact details

· Date of birth

· Financial information - if requesting the optional sponsor payment

· Property information in regard to space and facilities made available to Ukrainian guests.

· Housing Information  

· Family/Relationship Information

· Education information including schools attended

· Referral/Assessment Information

· Visa status

Where relevant to a sponsorship placement or breakdown, we may process other personal data:

· Equalities Information, such as ethnicity or religion

· Health/Medical Information e.g., where a Ukrainian guest has specific medical needs.

Your personal information is only used for a specified purpose(s) but if we intend to use it for any other new purposes, we will normally ask you first.  For instance, in some cases, the Council may wish to use your information for another purpose such as related to improving and developing services, or to prevent or detect fraud.  In any event our processing will always have a demonstrable lawful basis.  Where practicable and reasonable we will always seek to inform you of any significant proposed changes to how we process or intend to process your personal data, in order to ensure full transparency over how we handle your information

How we collect your information

Data will be provided by Devon County Council or directly from the DLUHC Foundry (central government portal). Access to either the DCC information or the Foundry platform is strictly controlled by logging into the portal using a username and password and is only accessible to Council staff.

The Pickwell Foundation will also collect additional data from the sponsors and Ukrainian guests in relation to welfare and need and may be shared with the appropriate authorities for reasons of safeguarding or welfare support.  

Who the information is shared with

The information collected from Devon County Council or the DLUHC Foundry will be shared securely with our local partner organisation, the Pickwell Foundation who will provide support to both sponsors and Ukrainian guests.

The following information taken from the Welfare Check will be shared back with Devon County Council/ DLUHC and the Home Office by the Council:

· That the accommodation offered exists and can be used as residential accommodation

· That the accommodation has been visited and it appears suitable for the proposed guests

· That the guest(s) expected has/have arrived in the accommodation

· That safeguarding checks, including visiting the guests in their accommodation have taken place and it can be confirmed there are no serious concerns

Information will be shared with other Council departments to ensure the appropriate services are provided to residents who are sponsors.

We will only ever share your information if we are satisfied that our partners or suppliers have sufficient measures in place to protect your information in the same way that we do.

We will never share your information for marketing purposes.

Legislation that applies

· Localism Act 2011 - general competence power

· Government expectations for Homes for Ukraine Scheme

· Immigration & Asylum Act 1999 - allows the council to share data with the Home Office for immigration purposes

How long do we keep your information?

The government expects retention of personal data to be within 2 years of the closure of the scheme unless DLUHC and the Home Office identifies that its continued retention is unnecessary before that point. Where existing processes such as safeguarding are used, those existing retention periods will apply.

If ongoing or additional support is needed for guest family members, the data in relation to this will be recorded on existing case management systems relevant to the service provided and fall under the specific retention periods of these systems/services.

Your rights and access to your information

You have the right to request a copy of the information that we hold about you. 

The UK GDPR and Data Protection Act 2018 also gives you additional rights that refer to how the council holds and uses your information.

Consequently, under certain circumstances, by law you have the right to:

· withdraw consent and the right to object and restrict further processing of your data; however, this may affect service delivery to you.

· request to have your data deleted where there is no compelling reason for its continued processing and provided that there are no legitimate grounds for retaining it.

· request your data to be rectified if it is inaccurate or incomplete

· have your data transferred or copied should you move to another authority

· not be subject to automated decision-making including profiling

If you have any concerns

Please contact us if you would like to know more about the information we hold about you and how we use it.

You have a right to complain to us if you think we have not complied with our obligation for handling your personal information; please visit our website

If you are not satisfied with the Council's response you have a right to complain to the Information Commissioner's Office (ICO). You can report a concern by visiting the ICO website.

Automated Decision Making

There are no automated decision making processes used in the provision of this service.

Changes in your circumstances

You must notify us immediately if there are any changes in your circumstances and personal details so we can maintain an accurate and up to date record of your information. Any failure to provide your personal information may prevent or delay us meeting our statutory requirements or in providing you with a timely and effective service.