FCDO privacy notice: coronavirus (COVID-19) emergency loan for British nationals abroad for living costs
Updated 30 October 2020
Date last modified: 30 October 2020
This privacy notice covers the collection of personal data for the purposes of authorising Foreign, Commonwealth & Development Office emergency loans during the coronavirus (COVID-19) pandemic.
The provision of these emergency loans stopped on 30 October 2020. This Privacy Notice remains published for British nationals who may wish to refer to it. The FCDO will continue to work with HM Passport Office in connection with unpaid loans (see para 5). From 30 October, personal data collected for the purposes of processing these loans will be handled in accordance with the FCDO’s Consular Services in the UK and missions overseas Privacy Notice.
1. Who we are
The Foreign, Commonwealth & Development Office, comprising teams working in the UK and at British embassies, high commissions and consulates overseas, is part of the UK government. The FCDO pursues our national interests and projects the UK as a force for good in the world. We promote the interest of British citizens, safeguard the UK’s security, defend our values and tackle global challenges with our international partners. In fulfilling these functions we process personal data.
We will ensure that we will treat all personal information in accordance with data protection legislation, including the UK General Data Protection Regulation and Data Protection Act 2018.
Foreign, Commonwealth & Development Office
King Charles Street
London
SW1A 2AH
Use telephone: 020 7008 1500
2. What data we process and why
During this time of crisis, British embassies, high commissions and consulates are processing personal data for the purposes of administering emergency loans for eligible individuals for their repatriation and/or while they are waiting to return.
The data that we process includes the following: name, address, gender, nationality phone number, email address, passport information (including a photograph of the main page of your passport), bank details, and date and place of birth. We will also need to process a proof of address, such as a driving licence, utility bill, recent credit card or bank statement or a tenancy agreement, which you will submit as part of the application process.
3. Data provided in times of crisis directly or by third parties
In most cases, you will have provided the data we hold. In some cases, data may have been provided by a family member, parent or friend calling us for advice or support. However, this data is necessary before we can provide you with a loan.
We provide a link to this privacy notice in our Personal Information Charter and whenever we communicate with individuals about how to contact us, (e.g. phone numbers/hotlines/webforms or SMS during a crisis) as a means of highlighting how personal data is held and processed.
4. Legal basis for processing
We process this data because it is necessary to perform our official functions as a government department or is otherwise in the public interest so that we can provide assistance during the current crisis. Specifically, it is necessary to process this data in order to check individuals’ eligibility for an emergency loan and the arrangements for repayment.
Where special category data such as health data is processed this is also done because it is necessary for us to be able to assess eligibility for an emergency loan and therefore to perform our functions as a government department, and it is necessary for reasons of substantial public interest.
5. Data sharing
As part of providing emergency loans, we will share personal data with third parties in order to, for example, confirm eligibility or book travel on your behalf. These third parties include airlines and travel agencies, and the Driver and Vehicle Licensing Agency to verify UK addresses. We may also share personal data with law enforcement agencies, the Department for Work and Pensions or HM Passport Office for the purpose of detecting and/or preventing possible fraud, including identity fraud and benefit fraud.
Where an emergency loan has been given but not repaid in accordance with the terms of that loan, we will also share personal data with third parties such as credit reference agencies and the government debt management service, Indesser, who may use debt collection agencies to recoup the debt. We may also share personal data with other government departments in connection with any outstanding debts including:
- HM Passport Office, as you may not be able to renew your passport until the loan has been repaid in full
- Department for Work and Pensions to request such information as may be relevant in respect of any non-payment of this debt, including details of your current address and any benefits or allowances paid to you
- the Driver and Vehicle Licensing Agency to verify any updates to the UK address on your driving licence
6. Data processors
While it is the FCDO that determines eligibility for an emergency loan, where eligibility is confirmed flights are usually booked using Corporate Travel Management Pty Ltd (CTM) acting as the FCDO’s preferred partner. As part of booking these flights CTM will be processing some personal data mentioned above as a data processor on behalf of the FCDO.
This will include sharing some of your personal data with the flight company and departure and arrival airports as necessary. This may include special category data, such as informing an airline of mobility or special assistance needs.
7. Security of your data
We take data security very seriously and we take every step to ensure that your data remains private and secure. For online services we have procedures and security features in place to keep your data secure once we receive it. We also use SSL in order to encrypt all data transferred to and received from our server.
8. How long we keep your data
We retain data in line with our retention schedules. We do not retain payment data.
9. How to contact us
If you have any questions about anything in this notice, or if you consider that your personal data has been misused or mishandled, or if you would like to exercise any of your rights, contact us: Data.Protection@fcdo.gov.uk.
You can also contact the Data Protection Officer at the Foreign, Commonwealth & Development Office:
Data Protection Officer
Knowledge Management Department
Knowledge and Technology Directorate
Room WHG 127
Foreign, Commonwealth & Development Office
King Charles Street
London
SW1A 2AH
Email: Data.Protection@fcdo.gov.uk
Telephone: 020 7008 1500
10. Complaints
You may also make a complaint to the Information Commissioner, who is an independent regulator. The Information Commissioner can be contacted at:
Email: casework@ico.org.uk
Telephone: 0303 123 1113
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF