Homes for Ukraine visa sponsorship scheme: privacy notice | #itsecurity | #infosec | #hacking | #aihp

The Department for Levelling Up, Housing and Communities (DLUHC) and the Home Office are data controllers for the Homes for Ukraine visa sponsorship scheme.

The purpose of this privacy notice is to tell you how DLUHC and the Home Office will process your personal data for their shared purposes to deliver the sponsorship scheme and the common objective of providing homes to those fleeing the war in Ukraine. You have rights concerning how your data is collected and used for this purpose. We inform you here what those rights are and how you can exercise them.

DLUHC and Home Office are committed to protecting the privacy and security of your personal data. As the two departments still have distinctive statutory responsibilities and accountabilities, we may publish separate privacy notices where appropriate which further explain how your personal data is used for their respective purposes.

Read more details of how the Home Office will use your personal data, including your data protection rights: Borders, immigration and citizenship: privacy information notice.

DLUHC – general privacy charter.

We are only allowed to use, gather, and share personal information where we have an appropriate legal basis to do so. We only collect and processes personal information to fulfil our legal and official functions. We will only use personal information when the law allows us to and where it is necessary and proportionate to do so.

DLUHC and Home Office each have an appointed Data Protection Officer (DPO) to help ensure that the departments fulfil their legal obligations when processing personal data. You can contact each DPO respectively, or both:

DLUHC dataprotection@levellingup.gov.uk or by writing to the following address: Data Protection Officer, Department for Levelling Up, Housing and Communities, 2 Marsham Street, London SW1P 4DF.

Home Office DPO@homeoffice.gov.uk, or by writing to the following address: Data Protection Officer, Home Office, 2 Marsham Street, London, SW1P4DF.

What personal data we are collecting and why

Your personal data is being collected and used to deliver the Homes for Ukraine visa sponsorship scheme, for the purpose of matching potential sponsors with visa applicants and providing applicants with suitable accommodation. We may also use your personal data to contact you about related matters.

We collect your name, address, contact details (including email), and details about your property. We may also need to collect and use personal data about others, such as your household members or others living in your property, or someone you have nominated to be a sponsor.

Organisations and non-governmental organisations (NGOs)

We collect your name, work email address, other contact details (including address), and details about offers of accommodation that you submit. If you may need to provide personal data about others relating to your offer, we will process this as well.

We may also collect certain technical data like your IP address, in order to manage delivery of our sponsor application portal.

How we use your personal data

DLUHC collects individual sponsor and organisational offers of accommodation that you submit for the scheme via our portal on gov.uk. and has overall responsibility for compiling, maintaining and managing the central repository of data necessary to collect information about accommodation offers, sponsors and refugees from Ukraine so that these can be matched.

The Home Office is responsible for processing visa applications for the purposes of the scheme and will do so under its borders, immigration and citizenship privacy policy. Home Office visa approval or rejection data will be submitted to the repository of data managed by DLUHC.

The Home Office may also process the data you submit for necessary vetting of sponsors as part of the matching process, which may involve a check against Police National Computer records and related safeguarding checks.

Both DLUHC and the Home Office will use the data that we separately collect and use, to enable suitable and safe matches of sponsors and organisation offers of help with applicants that have been visa cleared.

Lawful basis for processing the data

We are using the following lawful basis under UK GDPR to process personal data:

• Article 6(1)(e) of the UK GDPR – processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority

We may also process special categories of personal data which may include information about political beliefs, health, sexual orientation, religious beliefs, and biometrics. Where we do so our lawful basis is

• Article 9(2)(g) of the UK GDPR – processing is necessary for reasons of substantial public interest.

With whom we will be sharing the data

DLUHC and the Home Office may share your data will other external parties who are working to match potential sponsors with applicants to the scheme and who may provide matching services in addition to DLUHC. These currently include:

• English local authorities, so that they can take forward local placement in homes when a suitable match has been made;
• the UK devolved assemblies (Scotland, Wales and Northern Ireland), for the purpose of their acting as “super sponsors” for visa applicants;
• Reset, who are helping to register and match refugees from Ukraine with sponsors across the UK. Reset provide a hub for community sponsorship activities who can connect with selected charities and non-governmental organisations (NGOs) involved in supporting refugees from Ukraine.

Please note that where we may share your data externally, that organisation will take on responsibility for your data at that point, and you should refer to their own privacy notice for details on how they will process your data.

DLUHC and the Home Office may also separately appoint a ‘data processor’, acting on its behalf and under its instruction, to help analyse the responses to support the matching of potential sponsors with applicants or for the purpose of visa applications.

Where that is done, we will ensure that the processing of your personal data remains in strict accordance with the requirements of the data protection legislation and we will update this privacy notice to reflect those arrangements.

DLUHC is using gov.uk, to electronically collect individual sponsor submissions and submissions from organisations.

DLUHC and the Home Office have appointed a third-party company, Palantir, to assist with the collation, analysis and support relating to the expressions of interest and the matching of potential sponsors with applicants, once sponsor expressions if interest and visa applications have been received.

For how long we will keep the personal data, or criteria used to determine the retention period.

Your personal data will be kept only as long as it is necessary for these permitted purposes.

For data relating to the initial expressions of interest exercise, this will be held for two years from the closure of the site unless DLUHC identifies that its continued retention is unnecessary before that point.

It may also be that if your data is successfully matched to a visa application the information will be maintained for longer. You will be advised if this the case.

Your rights, for example: access, rectification, erasure

The data being collected is your personal data, and you have rights that affect what happens to it. You have the right to:

a. know that we are using your personal data

b. see what data we have about you

c. ask to have your data corrected, and to ask how we check the information we hold is accurate

d. complain to the Information Commissioners Office (ICO) see below

In some circumstances you may also have the right to object to particular uses of your data. We will tell you when these rights apply.

Is any personal data sent overseas?

DLUHC has required in its agreements that its data processors who may use your data on our behalf will not send this outside of the UK.

Automated decision making and profiling

No decision will be made about individuals solely based on automated decision making (where a decision is taken about them using an electronic system without human involvement) and which has a significant impact on them.

Each department may use personal information, for example from previous applicants, to develop tools that allows assessment and then processing of applications in a particular way. This helps us to target resources and ensure processing is efficient, allowing us to minimise costs while protecting the public effectively. However, a case officer would still decide these cases. Any such processing must comply with our wider obligations under equality legislation.

Storage, security, and data management

DLUHC and the Home Office a duty to safeguard and ensure the security of your personal data where we process this. We do that by having systems and policies in place to limit access to your information and prevent unauthorised disclosure, accidental loss, or alteration of your data. We have also procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Complaints and more information

When we ask you for information, we will keep to the law, including the Data Protection Act 2018 and UK General Data Protection Regulation.

If you are unhappy with the way DLUHC has acted when using your sponsor data, you can make a complaint.

If your complaint relates to how your data has been used for visa application purposes, please refer to the Home Office privacy notice link provided above.

If you are not happy with how we are using your personal data, you should first contact the relevant data protection officer at the addresses above.

If you are still not happy, or for independent advice about data protection, privacy and data sharing, you can contact:

Telephone: 0303 123 1113 or 01625 545 745
https://ico.org.uk/