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Multi Agency Rough Sleeping (MARS) group privacy notice

This privacy notice is designed to help you understand how we use personal information when delivering our housing services we have set out below the services types, the information we may use to deliver the services, who we may share it with, and how long we will keep it.

Services covered within this privacy notice

Multi Agency Rough Sleeping (MARS) group

Multi Agency Rough Sleeping working group meetings and gaps identified from DCLG Guidance Health Check for rough sleepers.

Information we hold about you

We only collect and use the minimum amount of personal information required when delivering a service to you. Wherever possible we use non-identifiable personal information.

The service will collect all of the personal information provided:

  • your name, email address, telephone number and date of birth
  • national identifiers such as your national Insurance number
  • details about your lifestyle and social circumstances
  • details about your housing needs
  • racial or ethnic origin
  • religious or other beliefs of a similar nature
  • your address history for the last five years
  • household makeup including children
  • financial details (income and expenditure and benefit entitlement
  • risk of harm to yourself or others
  • relationship status
  • third party contact information
  • agency involvement
  • support needs
  • criminal convictions
  • outstanding debts
  • health data
  • history and experiences of homelessness and housing

We get most of this information from you, but we will also get some of this data from:

  • central Government agencies
  • other local authorities
  • health and social care providers
  • police and probation services
  • members of the public (referrer)
  • commissioned partners
  • family members
  • third sector organisations that are supporting you e.g. CATH, SHARE, Soul Kitchen
  • The Ministry of Housing, Communities and Local

Why we need your information and how we use it

We use your information to:

  • deliver the service, or handle your query
  • plan and improve the services we offer
  • detect and prevent crime or fraud
  • research, however this would be in anonymised form unless we ask for your consent to use your personal information for this purpose
  • evidence positive outcomes to central government funding agencies
  • ensure that rough sleepers are being offered the appropriate support
  • ensure that we can target individuals and support them to find a way off the street
  • use a multi-agency approach to reduce the risks of harm coming to those people that are sleeping rough in the borough
  • sustain your accommodation, rehouse you to temporary accommodation or move you to independent accommodation

Who your information may be shared with (if applicable)

Sometimes we will need to share your information, but we will only do so where it is necessary or required by law. We will only share the minimum information for each circumstance.

We will sometimes need to share some of your information with:

  • CWAC Housing Options
  • ForFutures
  • Community Safety team
  • police
  • health service providers including NHS agencies (GPs, hospitals, ambulance, health visitor, mental health services)
  • Government agencies (Department of Work and Pensions)
  • housing associations
  • probation Service
  • third sector groups that are providing you with support e.g. SHARE, Soul Kitchen

We may also use data processors to support activities, for example by providing the systems we need or delivering services on our behalf, which includes our case management system (Locata).

The Data Controller

We are the Data Controller for this processing.

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment.

The lawful basis for the processing

We will always ask your consent to share your personal information unless we have a legal duty or power to provide it without your consent.

Most of the personal information we process is provided to us directly by you, under the Data Protection Act 2018, the lawful bases we rely on for using your personal information are:

  • we need it to perform a public task (GDPR Article 6 (e)

When we collect data about your race, health (including biometric or genetic data), sex life, sexual orientation, ethnic origin, politics or trade union membership, we also rely on the following lawful basis:

  • we need to collect it for Substantial Public Interest in order to comply with UK legislation (GDPR Article 9 (2) (g)

The legislation we rely on when using your personal information to meet our legal obligations or public tasks includes but is not limited to:

  • Housing Act 1985, 1996, 2004 and 2006
  • Homelessness Act 2002
  • Homelessness (Priority Need for Accommodation) England Order 2002
  • Homeless Reduction Act 2017
  • Housing Grants, Construction & Regeneration Act 1996

Protecting your information

Your information will be securely stored on our network.

How long will we keep your personal information?

We will only use your personal information whilst delivering the service to you and to deal with any questions or complaints that we may receive about this, unless the law requires us to keep it for a longer period. In practice, this means that your information will be kept for six years from the data the case is closed then deleted.

If we need to use your information for research or reports, your information will be anonymised and any information taken from notes (hand written or typed) during any consultation sessions will be securely destroyed. The information will continue to be used in a summarised and anonymised form in any research reports or papers that are published. The anonymised information in the papers may be of historic interest and may be held in public archives indefinitely

Your rights

Under data protection law, you have rights including:

  • your right of access - you have the right to ask us for copies of your personal information
  • your right to rectification - you have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • your right to restriction of processing - you have the right to ask us to restrict the processing of your information in certain circumstances
  • your right to object to processing - you have the right to object to the processing of your personal data in certain circumstances

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

To make a request follow the instructions on our Data protection for you page.

How to complain if you are unhappy about how your data is used

You can complain directly to our Data Protection team online or by post:

  • Contact the DPO
  • By post: Data Protection Officer, The Portal, Wellington Road, Ellesmere Port, CH65 0BA

You also have the right to complain to the Information Commissioner’s Office using the following details:

Will my personal information be accessible outside the UK?

Should the transfer of personal information outside of the UK become necessary, it will only take place if permitted by law, and then only where there are appropriate safeguards in place to protect the personal information.

Your information is stored within the UK.