Homes for Ukraine privacy notice for hosts
We keep this privacy notice under regular review and it was last updated 7 November 2023.
Kent County Council respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
Who we are
Kent County Council (KCC) 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. Kent County Council will work with you under the Homes for Ukraine Scheme as a sponsor or host. As a Local Authority, KCC will provide vetting and safeguarding checks, and will share your personal information with district and borough councils, to complete further checks to ensure suitability.
Our Data Protection Officer is Benjamin Watts.
Personal information we collect and use
Information collected by us
We will collect the following personal information when you provide it to us or receive from the Home Office or Department of Levelling Up, Communities and Housing or district or borough councils:
- Personal information e.g. your name, address, date of birth, age, sex, details of property, district or borough council, confirmation of vetting and safeguarding checks.
- Contact details e.g. your email address, telephone number.
- Information relating to individuals living in the same household, for example, descriptions listed in personal information, contact details.
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 you and your circumstances, for example, are you or an individual living in the same household being supported or receiving a service from Adult Social Services or Children's Services.
Other information relating to vetting and safeguarding checks (including outcomes or flags) will also be collected by us or be provided by the Home Office or Department of Levelling Up, Communities and Housing.
How we use your personal information
We use your personal information to:
- support the delivery of the Homes for Ukraine Scheme
- receive expressions of interest from you to become a host
- ensure sponsors and their households undertake vetting (DBS) checks and enhanced checks
- ensure sponsors and their households undertake safeguarding checks where necessary. A check will be carried out to identify if you or an individual in your household are being supported or are receiving a service from Adult Social Services or Children's Services
- contact you regarding your application for example, missing information, clarification on information provided, to arrange visit etc
- offer you services to prepare your home for hosting, for example, fire checks, gas safety checks
- share relevant information with district and borough councils to complete further checks to ensure suitability.
The sharing of information facilitates a joined-up approach with partner agencies, to ensure support to the delivery of the Homes for Ukraine Scheme.
Reasons we can collect and use your personal information
We reply on 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 or in the exercise of official authority vested in the controller as the lawful basis on which we collect and use your personal data.
We rely on 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, as the lawful basis on which we collect and use special categories of personal data.
We rely on the Statutory 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.
We rely upon your consent for the processing of any criminal conviction and offence personal information, for the purpose of carrying out the vetting check (DBS). If you provide us with this information, we will only process it (including sharing the information with the organisations listed below) to the extent that it is necessary for that purpose. If you do not consent to provide this information, we may not be able to further your application to become a sponsor.
We take the following appropriate safeguards in respect of your special category data when relying on the conditions above:
- We have an Appropriate Policy for Lawful Processing which explains how the data protection principles are secured when using special category information. This policy is retained throughout the time we use your data and for six months after we cease to use it.
- We have a retention schedule which explains how long data is retained.
- We maintain a record of our processing in our ‘Record of Processing Activities’ and record for any reasons deviating from the periods in our retention schedule.
If you do not provide your data, it will limit the progression of your application and we may not be able to further your application to become a sponsor.
How long your personal data will be kept
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.
Who we share your personal information with
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
- District and borough councils (to complete sponsor checks)
- HR Connect (DBS check)
- Granicus (form provider for collecting information).
We may also share personal information with other relevant KCC teams such as Adult Social Services and Children's Services etc. to process the information so this can be used to complete safeguarding checks and distribute information to relevant district and borough councils.
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 law enforcement or other authorities if required by applicable law or in connection with legal proceedings.
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.
Granicus may store personal information in a backup server located within the EU. As we may transfer your data within the EU we rely on UK GDPR Article 45 which states that this transfer may take place where there are ‘adequacy regulations’ determining that data is adequately protected by the laws in that country. A copy of this decision can be found in section 102 of Schedule 2 of the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (2019/419).
Your rights
Under UK GDPR you have rights which you can exercise free of charge which allow you to:
- know what we are doing with your information and why we are doing it
- ask to see what information we hold about you (subject access request)
- ask us to correct any mistakes in the information we hold about you
- object to direct marketing
- make a complaint to the Information Commissioner's Office
Depending on our reason for using your information you may also be entitled to:
- ask us to delete information we hold about you
- have your information transferred electronically to yourself or to another organisation
- object to decisions being made that significantly affect you
- object to how we are using your information
- stop us using your information in certain ways
We will always seek to comply with your request however we may be required to hold or use your information to comply with legal duties. Please note, your request may delay or prevent us delivering a service to you.
For further information about your rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individuals’ rights under GDPR.
If you would like to exercise a right, please contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk.
Keeping your personal information secure
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.
Who to contact
Please contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.
You can contact our Data Protection Officer, Benjamin Watts, at dpo@kent.gov.uk.
UK GDPR also gives you right to lodge a complaint with Information Commissioner, who may be contacted via the Information Commissioner's website or call 03031 231113.