As a local authority, we have a role to play in the success of the Homes for Ukraine Scheme and are uniquely placed to support local communities to offer Ukrainians the warmest possible welcome to the UK.
Processing activity - we will process personal information to:
- support the delivery of the Homes for Ukraine Scheme
- contact you regarding your application e.g. missing information, clarification on information provided, to arrange visit etc.
- offer you services that you may need e.g., interpreting services, provide support and assistance to access relevant services
Information requirements - our processing activities may include:
- your name, age, sex, passport details, address if not staying with sponsor, contact details e.g., email address, telephone number, application number, arrival date, status of application
- information relating to potential family members
We also collect ‘special category data’ (personal information which is more sensitive and is treated with extra care and protection) such as information about your racial or ethnic origin and information concerning your health.
Lawful bases[1] - our lawful bases for processing your personal information are:
• UK GDPR 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 us in service to section 137(1) Local Government Act 1972 (as amended), in conjunction with section 1 of the Localism Act 2011 – i.e. the discretionary power of competence
• UK GDPR Article 9(2)(g), supplemented by DPA 2018[2] section 10(3) & Schedule 1, Part 2, paras 6(1) and (2)(a) – processing of ‘special category data’ (personal information which is more sensitive and is treated with extra care and protection) such as information about your racial or ethnic origin and information concerning your health
- UK GDPR Article 10, supplemented by DPA 2018 sections 10(5) and 11(2), Schedule 1, Part 2, paras, 6(1) and (2)(a) – processing of criminal convictions and offences (including alleged offences) in service to the Fraud Act 2006 (as amended)
Processing of special category data and criminal convictions and offences are processed for reasons of substantial public interest under the laws that apply to us where this helps to meet our broader social obligations such as where it is necessary for us to fulfil our legal obligations and regulatory requirements.
We have a Data Protection Policy that sets out how this information will be handled.
Data sharing - we may receive from and share your personal information with:
- Charities, public bodies or providers that we contract with who may be able to support you during your stay in the UK
- Department of Levelling Up, Communities and Housing
- Home Office
- Interpreting services e.g. Language Line
- Kent County Council
- Law enforcement Agencies e.g. the Police to aid with the detection and prevention of criminal acts
- Our internal departments
- Sponsors
The sharing of information facilitates a joined-up approach with partner agencies, to ensure support of the delivery of the Homes for Ukraine Scheme.
We may rely on a number of exemptions, which allow us to share information without needing to comply with all the rights and obligations under the Data Protection Act 2018. Please refer to the Kent & Medway Information Agreement for further details on our sharing arrangements.
Retention period – we will only hold your personal information for as long as necessary. Personal data shall be retained for 2 years upon closure of the Homes for Ukrainians Scheme, unless the Department for Levelling Up, Communities and Housing and/or the Home Office identify that continued retention is necessary. All information will be held securely and disposed of confidentially.
Anonymisation- your personal information may be converted ('anonymised') into statistical or aggregated data in such a way that ensures that you cannot be identified from it. Aggregated data cannot, by definition, be linked back to you as an individual and may be used to conduct research and analysis, including the preparation of statistics for use in our reports.
Right to object – where processing your personal information is required for the performance of a public interest task (see our lawful bases above), you have the right to object on ‘grounds relating to your particular situation’. We will have to demonstrate why it is appropriate for us to continue to use your personal data.
Changes to this Privacy Notice – we review this Privacy Notice regularly and will place updates on our website.
Please refer to our Corporate Privacy Notice for further details of how we process your personal information and for details on your additional rights.