Homes for Ukraine visa sponsorship scheme: privacy notice
Privacy notice for the Homes for Ukraine visa sponsorship scheme.
The Ministry of Housing, Communities and Local Government (MHCLG) 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 MHCLG 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.
MHCLG 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.
MHCLG – 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.
The identity and contact details of the Ministry of Housing, Communities and Local Government (MHCLG) and the Home Office Data Protection Officer
MHCLG 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:
MHCLG dataprotection@communities.gov.uk or by writing to the following address:
Data Protection Officer
Ministry of Housing, Communities and Local Government
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,
SW1P 4DF
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 such as wider opportunities to provide support to vulnerable people. If the potential sponsorship concerns a minor who is not travelling with or to join a parent or legal guardian, we will use your personal data to approve the suitability of the sponsorship.
Individual sponsors
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.
Visa applicants
In circumstances relating to the re-matching of visa applicants and sponsors we will hold your name, address, and contact details. We will use this information to help keep you advised of the options available to you.
If you are travelling to the UK as a minor who is not travelling with or to join a parent or legal guardian, we will collect your name, date of birth, passport or identification document number, and visa application reference.
Parents or legal guardians of applicants
If your child is travelling to the UK as a minor who is not travelling with or to join a parent or legal guardian, we will collect your name, address, and contact details (including email). We will also collect this data for your child’s next of kin.
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.
We are conducting ongoing research to inform policy development on the Homes for Ukraine scheme. The aim of this research is to continue to improve the service we provide to both sponsor and guest. This research will take the form of remote in-depth interviews, which will be recorded. If your sponsor or guest is participating in this research it is possible that some of your personal data will be shared.
- If you are an applicant - information about you may be provided by sponsor
- If you are a sponsor - information about you may be provided by guests
See the Homes for Ukraine user research privacy notice.
If any ‘special category’ personal data is inadvertently collected during this research process, we will delete or anonymise at the earliest opportunity.
How we use your personal data
MHCLG 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 MHCLG.
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 MHCLG 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.
If you are a visa applicant, after your visa has been granted your data will also be used by local authorities to produce management monitoring reports for MHCLG on local delivery of the scheme. These reports only contain anonymised data and will not contain any identifiable personal data about you once produced.
If you are a parent or legal guardian of an applicant travelling as a minor who is not travelling with or to join a parent or legal guardian, we will use the data you have provided to: confirm parental consent for sponsorship arrangements; and to contact you in the event of a change in circumstances of the sponsorship arrangement. If we are unable to contact you in this event, we will use the data you provided to contact your child’s next of kin.
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
MHCLG 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 MHCLG. 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;
- Ukrainian Sponsorship Pathway UK (USPUK) who can provide information and advice to Ukrainians on deciding whether the UK is right for them, finding a matching service, travelling to the UK and considering UK government benefit schemes for refugees. USPUK will support you in making contact with a re-matching provider
- Citizens UK – we will receive and return personal data about prospective sponsors from this charity, to check that they meet the scheme’s requirements as part of it re-matching efforts. 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.
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.
MHCLG 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. Our data processors are currently:
- GOV.UK – which MHCLG is using to electronically collect individual sponsor submissions and submissions from organisations.
- Palantir – MHCLG has appointed this third-party company to assist with the collation, secure transmission and sharing of your personal data with local authorities in England and the devolved assemblies.
- MHCLG is also using a secure platform run by the Department and based in Dublin, Republic of Ireland for the purpose of cleansing and analysing personal data collected under the Homes for Ukraine scheme.
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 MHCLG 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?
MHCLG has required in its agreement with Palantir that data held by the company, for the purpose of secure onward sharing with public bodies, will not leave the UK.
MHCLG will send personal data you provide to a separate secure analytics platform run by the Department. This is hosted in Dublin, Republic of Ireland, as stated above. The Republic of Ireland is a country judged as having equivalent data protection standards to 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
MHCLG 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 MHCLG 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:
The Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow, Cheshire,
SK9 5AF
Telephone: 0303 123 1113 or 01625 545 745 https://ico.org.uk/
Updates to this page
Last updated 7 July 2022 + show all updates
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Updated sections on 'What personal data we are collecting and why' and 'How we use your personal data'.
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Added section on conducting user research
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Added translation
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The sections “With whom we will be sharing your data?” and “Is any data sent overseas?” have been updated, to reflect DLUHC’s use of its department-run data analytics platform (Dublin-based) and role of Reset UK, a community hub supporting the Homes for Ukraine scheme.
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First published.