Homes for Ukraine privacy notice for Ukrainian nationals
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. Our Data Protection Officer is Benjamin Watts.
Kent County Council will work with you under the Homes for Ukraine Scheme. As a local authority, KCC will process your personal data to forward it to district/borough/city councils in Kent so that we and they can complete all the necessary processes. KCC may also process your personal data to provide interpreting services and provide support and assistance to access relevant services.
Personal information we collect and use
Information collected by us
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 KCC internal teams:
- personal information, for example, your name, age, sex, passport details, address (if you're not staying with a sponsor), contact details, for example, email address, telephone number, date of entry to UK, point of entry to the UK, visa status.
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 and health, for example, disability, health conditions, housing requirements, employment.
How we use your personal information
We use your personal information to:
- support the delivery of the Homes for Ukraine scheme
- contact you regarding your application, for example, to get missing information, clarify information provided, arrange visits etc. This may be via a district or borough council.
- offer you services that you may need, for example, interpreting services, provide support and assistance to access relevant services. We may also share with KCC internal teams or to certain external providers we contract to ensure this
- share relevant information with district and borough councils 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.
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, as the lawful basis on which we collect and use your personal data.
We reply 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 rights and the interests of the data subject, as the lawful basis on which we collect and use your special categories of personal data.
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.
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 6 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.
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, KCC 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).
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
- Sponsors
- Interpreting service, for example, Clear Voice.
We may share personal information with other relevant KCC teams e.g. adult social services and children's services 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) 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 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.
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.