UNHCR Resettlement Programme Privacy Notice

General Data Protection Regulation

The General Data Protection Regulation (GDPR) / Data Protection Act 2018 came into effect in 2018.  It represented a substantial change in how organisations deal with information about you (your Personal Data) and what rights you have in respect of the handling of that Personal Data.

What does it mean for me?

The Information Commissioner’s Office (ICO), which is the regulator for Data Protection matters in the UK, has provided an extensive guidance on GDPR on its website at https://ico.org.uk/ and in particular the Guide to the General Data Protection Regulation found at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr provides an easy to navigate guide in respect of your Individual Rights under GDPR.

What does it mean for the Council when dealing with my personal data?

For the most part, the Council will continue to use the information it holds on you for the same purpose or purposes it did before the GDPR came into force; namely in relation to the resettlement programme

In that respect the Council’s processing of your data (holding and using it) may differ from a number of other organisations e.g. those who hold your information for marketing purposes, who may need to seek your permission for all uses of your Personal Data.

We have, in any event, provided this Privacy Notice which explains the basis for our use of your data.  If we seek to use your Personal Data in a different manner from that which we state in this Privacy Notice, we will tell you and if necessary, seek your permission unless we are permitted or required by law to use it for such purposes without your request.

Using your personal data

General Approach

This Notice tells you how West Dunbartonshire Council uses your Personal Data.   West Dunbartonshire Council, is a local authority established under the Local Government (Scotland) Act 1973 and having its principal place of business at Council Offices, 16 Church Street, Dumbarton, G82 1QL ("the Council", "we" or "us") and in terms of Data Protection legislation is the Data Controller for the Personal Data we hold.

Why do we need your personal information and what do we do with it?

You are giving us your personal information to allow us to effectively   implement the conditions of the United Kingdom resettlement programme  that West Dunbartonshire Council participate in the United Kingdoms resettlement programme.

The selection process for refugees considered for resettlement to the UK is carried out by the UNHCR ( United Nations High Commission for Refugees).  West Dunbartonshire Council receive from the UNHCR via the UK Home Office a Medical Health Assessment for and a Personal Biography including names, dates of births, wider family information and a recent biography for the family.

The Home Office guidance on the programme can be found on the following link:

https://www.gov.uk/government/publications/uk-resettlement-programmes-funding-instruction-2017-to-2018 

Post arrival West Dunbartonshire Council collect information on the persons being resettled for a variety of purposes as noted further below.

Throughout the programme West Dunbartonshire Council will process the information you provide in accordance with the following purposes:

• Your name, address, national insurance number and contact details, including your home address, telephone numbers and email addresses will be used to identify you and communicate with you as necessary. This information is used to register you for benefits, schools, municipal bank, school and GP practice and other relevant agencies to assist in establishing you as the resettled person in the UK, and promoting your well-being.
• The Home Office require us to collect information across a very wide range of topics for you, and report that to them, generally twice a year for the first two years post arrival. The Home Office guidance referenced above details the information that is required to be provided. This information is required by the Home Office to allow them to process the funding of the programme to West Dunbartonshire Council and to carry out compliance monitoring, statistical analysis and reporting and for national security purposes..
• West Dunbartonshire Council hold information on you which is shared across departments where this is appropriate to promote well being and assist in the performance by West Dunbartonshire Council of its statutory functions and to perform services for you as a service user. This information is typically the names, DOBs, addresses and national insurance numbers, and contact details for the families. This information is used to register you for benefits, schools, municipal bank account, with utility companies supplying your home, and GP practice.
• As service users we process information on service users (including service users who are resettled persons )in accordance with the privacy notices published for the various services we provide and you should consult those service delivery privacy notices for details of this processing.

Legal basis for using your information: 

West Dunbartonshire Council are participating in the resettlement programme, by virtue of the powers granted to the Secretary of State in terms of Section 59(1)(e) of the Nationality Immigration and Asylum Act 2002. West Dunbartonshire Council has powers to provide support in terms of the Immigration and Asylum Act 1999, and further under the Local Government in Scotland Act 2003 to promote the wellbeing of persons resident in its area. For all of these requirements we require to hold and use your information and require to process the information in the public interest. 

Services are provided in terms of the Council’s functions as a local authority, more details of which can be found on the staff intranet (see in particular the Scheme of Delegation which provides details of many Council Functions).

Therefore, processing your personal information is necessary for the performance of matters relating to the provision of services to you.  Some information needs to be shared with external bodies because the council is under a legal obligation to do so.

Who do we share your information with?

We are legally obliged to safeguard public funds so details will be checked internally for fraud prevention and verification purposes and may be shared with other public bodies for the same purpose. 

We are legally obliged to share certain data with other public bodies such as HMRC and will do so where the law requires this; we will also generally comply with requests for specific information from other regulatory and law enforcement bodies where this is necessary and proportionate.  Information is also analysed internally in order to provide management information, inform service delivery reform and similar purposes.

We also share information with the Home Office as referred to above to meet our legal obligations in relation the funding requirements of the resettlement programme.

In some circumstances there will be a requirement to share some information with organisations external to West Dunbartonshire Council. These may include but not be limited to the following:

• Primary Health Care Providers
• Police Scotland
• West Dunbartonshire Council is subject to the Freedom of Information (Scotland) Act 2002 and the Environmental Information (Scotland) Regulations 2004 (collectively referred to as “FOI”) legislation. Such requests are assessed carefully and we will only release information in response to FOI requests if doing so is compatible with our obligations under data protection law. 

International transfers:

Information published on the council’s website (including video footage of webcast meetings, audiocast recordings of meetings and committee reports) can be accessed from anywhere in the world. 

How long do we keep your information for?

The Council maintains a records retention and disposal schedule which sets out how long we hold different types of information for.  

Your rights under data protection law:

The General Data Protection Regulation provides you with the following rights regarding your personal information:

• The right to be informed about how your information will be used.
• The right of access to your personal information.
• The right to rectification, which is the right to require the Council to correct any inaccuracies.
• The right to request the erasure of any personal information held by the Council where the Council no longer has a basis to hold the information.
• The right to request that the processing of your information is restricted.
• The right to data portability.
• The right to object to the Council processing your personal information.
• Rights in relation to automated decision making and profiling.

Details on these rights are available in the ICO guide referred to above. 

Complaints:

If you do not have access to the internet you can contact us on the above number to request hard copies of any of the above documents. We seek to resolve directly all complaints about how we handle personal information. 

If your complaint is about how we have handled your personal information, you can contact the Council’s Data Protection Officer by email at dataprotection@west-dunbarton.gov.uk.

You also have the right to lodge a complaint about data protection matters with the Information Commissioner's Office, whose contact details are as follows:  Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone - 0303 123 1113 (local rate) or 01625 545 745; Website: https://ico.org.uk/concerns