Refugee and Asylum Seeker Privacy Notice

This privacy notice explains how we use personal information when delivering our Refugee and Asylum Seeker Resettlement and Support Service.

The service supports individuals and families who have been resettled in the borough through recognised UK Government resettlement schemes, including the UK Resettlement Scheme, the Afghan Resettlement Programme, and Homes for Ukraine. It also applies to asylum seekers placed in the borough by the Home Office. We work closely with central government, partner organisations, including voluntary, community and faith sector organisations and commissioned services to support people to settle safely and rebuild their lives within the local community.

Our Refugee and Asylum Seeker Team provides coordinated, practical, and emotional support to help people access essential services and live independently. This may include support with housing, benefits and financial assistance, employment and skills, education and training, digital access, health and wellbeing, safeguarding, and support during emergencies. The type and level of support provided will depend on individual circumstances, eligibility, and the specific resettlement or asylum scheme under which someone has arrived.

As part of these arrangements, we receive information from organisations such as the Home Office and the Ministry of Defence about individuals and families arriving in the borough. This information is used to assess needs, plan and coordinate support, meet statutory duties, safeguard children and adults at risk, and monitor service delivery.

This privacy notice explains what personal information we collect, how and why it is used, who it may be shared with, how long it is kept, and what rights you have in relation to your personal data.

This notice applies to individuals receiving support through the Refugee and Asylum Seeker Resettlement and Support Service and, where relevant, members of their household or family.

What information we collect, use, and why

Whenever you contact us, or we work with you as part of the Refugee and Asylum Seeker Resettlement and Support Service, we collect and use personal information to understand your circumstances and provide appropriate support. This information helps us identify you, assess your needs, coordinate services, safeguard individuals, and meet our legal and statutory responsibilities.

We collect and use different types of personal information depending on the resettlement or asylum scheme you are supported under and the services you receive. This information falls into the following categories.

Personal data

We may collect and use the following personal information where it is relevant and necessary:

name, address, and contact details - to identify you, keep in touch with you, and provide information about the support available to you
date of birth - to confirm your identity, determine eligibility for services, and ensure records are accurately matched
Nationality, immigration status, and scheme information (including visa, eVisa, passport details, Home Office reference numbers, and information about the resettlement or asylum scheme under which you arrived.) - this is used to confirm eligibility, understand entitlements, and coordinate support with central government
family and household details - to understand family arrangements, identify dependants, plan appropriate support, and safeguard children and other household members
housing and accommodation details - to support access to suitable accommodation, manage placements, and coordinate housing-related support
financial information (including benefits information and, where relevant, details needed to provide financial assistance or manage payments)
education, training, and employment information - to support access to education, skills training, employment advice, and related services
lifestyle and social circumstances (including information about your day-to-day circumstances, support needs, vulnerabilities, or safeguarding concerns) - to help us tailor support and keep people safe
case records and correspondence - to maintain accurate records of assessments, decisions, actions taken, and support provided, ensuring continuity and accountability

Special category data

We also process special category data where it is necessary to support you, safeguard individuals, or meet our legal duties. This may include:

health information (including physical or mental health information, disabilities, or medical needs) - to help us coordinate appropriate support and access to services
racial or ethnic origin - to support equality monitoring and ensure services are delivered fairly and appropriately
religious or cultural beliefs (where relevant) - to ensure services and support are provided sensitively and appropriately
safeguarding information (including information about risks, vulnerabilities, or protection needs relating to children or adults at risk)

We only collect and use personal information that is relevant, necessary, and lawful for delivering the Refugee and Asylum Seeker Resettlement and Support Service.

Criminal data

In limited circumstances, we may also process criminal data where it is necessary and lawful to do so. This may include:

information relating to criminal offences or allegations (where relevant) - to safeguarding concerns, risk management, or the protection of individuals, including children and adults at risk
information shared by statutory partners (e.g. the police or other safeguarding agencies) where this is necessary to help us assess risk, support individuals safely, or meet statutory safeguarding duties

We do not carry out routine criminal record checks as part of this service. Criminal data is only processed where it is strictly necessary, proportionate, and permitted by law, and is handled with appropriate safeguards in place.

Sources of information

We collect personal information directly from you wherever possible when you contact us, engage with the Refugee and Asylum Seeker Resettlement and Support Service, or receive ongoing support from the Council.

To ensure we have an accurate and complete understanding of your circumstances, and to provide appropriate support, we may also receive information from other organisations where this is necessary and lawful. This may include information from:

Central government departments:
Including the Home Office and the Ministry of Defence, who share information with us about individuals and families arriving in the borough under recognised resettlement schemes or through the asylum process.
Other departments within Cheshire West and Chester Council:
Including housing, benefits, safeguarding, education, social care, and public health services, where information sharing supports joined-up working and avoids unnecessary duplication.
Health services and professionals:
Such as NHS providers, GPs, mental health services, and other health or wellbeing services, where information is needed to support access to care or safeguard individuals.
Education providers:
Including schools, colleges, and training providers, where relevant to education, employment, or family support.
Police and safeguarding partners:
Where information is shared for the purposes of safeguarding, risk management, or the protection of children and adults at risk.
Commissioned service providers and partner organisations:
Including voluntary, and community and faith sector organisations and other agencies commissioned to provide support as part of resettlement or asylum arrangements.
Other local authorities:
Where individuals move between areas, or where information sharing is required to support continuity of care and services.

We only collect information from these sources where it is relevant, necessary, and lawful to deliver the Refugee and Asylum Seeker Resettlement and Support Service and to meet our statutory and safeguarding responsibilities.

What is your personal information used for?

We use your personal information to deliver the Refugee and Asylum Seeker Resettlement and Support Service in a safe, effective, and lawful way. Your information is only used where it is relevant and necessary to support you, meet our statutory responsibilities, and protect individuals.

Your personal information may be used to:

Assess your circumstances and support needs:
To understand your individual or family situation, identify what support is required, and ensure services are appropriate to your needs.
Provide and coordinate support services:
To help you access housing, healthcare, education, employment support, benefits, financial assistance, and other services linked to resettlement or asylum support.
Safeguard children and adults at risk:
To identify and manage risks, support wellbeing, and take appropriate action where there are safeguarding concerns.
Work with partner organisations:
To share relevant information with statutory partners, commissioned providers, and voluntary, or community and faith sector organisations where this is necessary to coordinate support and avoid duplication.
Meet legal and statutory duties:
To carry out our responsibilities under immigration, resettlement, safeguarding, housing, and other relevant legislation and government guidance.
Manage cases and maintain records:
To keep accurate records of contact, assessments, decisions, actions taken, and outcomes, ensuring continuity of support and accountability.
Monitor and improve services:
To monitor service delivery, report outcomes to funding bodies or central government where required, and improve how services are planned and delivered. This may include producing reports or statistics. Where possible, information will be anonymised.
Respond to enquiries, complaints, or requests:
To respond to questions, complaints, information rights requests, or legal enquiries relating to the service.

We do not use your personal information for marketing purposes, and we do not share it more widely than is necessary to deliver the service or comply with the law.

Who do we share your personal information with?

We only share your personal information where it is necessary, lawful, and proportionate to deliver the Refugee and Asylum Seeker Resettlement and Support Service, safeguard individuals, or meet our legal and statutory responsibilities. We do not share information more widely than is required.

Your personal information may be shared with the following organisations where relevant:

Central government departments:
Including the Home Office and the Ministry of Defence, to support resettlement arrangements, confirm eligibility, meet reporting requirements, and coordinate support linked to specific schemes.
Health services and professionals:
Such as NHS providers, GPs, mental health services, and other health or wellbeing services, where information sharing is necessary to support access to healthcare or protect your health and wellbeing.
Education providers:
Including schools, colleges, and training providers, where sharing information supports education, skills, or family-related needs.
Housing providers:
Including housing teams within the Council, housing associations, or accommodation providers, to support access to and management of suitable accommodation.
Police and safeguarding partners:
Where necessary to protect children or adults at risk, manage safeguarding concerns, or support crime prevention and public safety responsibilities.
Commissioned service providers and partner organisations:
Including voluntary, and community and faith sector organisations that deliver resettlement, wellbeing, advocacy, or support services on behalf of the Council.
Other departments within Cheshire West and Chester Council:
Including safeguarding, benefits, education, social care, public health, and related services, where information sharing supports coordinated service delivery and avoids duplication.
Other local authorities:
Where individuals move between areas, or where information sharing is required to ensure continuity of support.

We only share information that is relevant to the purpose, and all organisations receiving your information are required to handle it securely and in accordance with data protection legislation.

Data processors and systems we use

We use data processors and information systems to support the delivery of the Refugee and Asylum Seeker Resettlement and Support Service and to ensure that personal information is handled securely and efficiently. Data processors act on our instructions and are required to process personal information in accordance with data protection legislation and contractual requirements.

The main systems and processors we use include:

Resettlement Connect

Personal information is securely recorded and managed within Resettlement Connect, a case management system used to coordinate resettlement and asylum support. The system is operated by LoCTA Limited, with hosting and platform support provided under an access agreement with the London Borough of Islington. Access to the system is restricted to authorised staff and uses secure login controls.

Council-approved IT and cloud service providers

We use approved IT and cloud providers to host data, support secure document storage, provide system resilience, and maintain the Council’s ICT infrastructure. These providers do not use personal information for their own purposes.

Communication and notification services

We may use secure communication tools, such as Gov.UK Notify, to send service-related messages, updates, or appointment information where appropriate.

All data processors are required to:

act only on our documented instructions
keep personal information secure
ensure appropriate technical and organisational safeguards are in place
only retain personal data for as long as instructed by us

We remain responsible for how and why your personal information is used.

Data Controller

We are the Data Controller for the personal information processed as part of the Refugee and Asylum Seeker Resettlement and Support Service.

This means that we are responsible for deciding how and why your personal information is collected, used, stored, and shared in relation to this service. We are required to ensure that your information is processed lawfully, fairly, and transparently, and that it is kept secure.

Where we work with partner organisations, or service providers or voluntary, community and faith sector organisations, they act either as data processors on our instructions or as separate data controllers in their own right, depending on their role and legal responsibilities. In all cases, information sharing is governed by data protection law and appropriate agreements.

If you have any questions about how your personal information is used, or wish to exercise your data protection rights, you can contact our Data Protection Officer using the details provided later in this notice.

The lawful basis for processing your personal information

We do not rely on consent as the lawful basis for processing personal information where we are carrying out our statutory duties and public functions.

We process personal information for the Refugee and Asylum Seeker Resettlement and Support Service under the following lawful bases.

UK GDPR Article 6(1)(e) – Public task
Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority. This includes our role in supporting individuals and families who have arrived through UK Government resettlement schemes, supporting asylum seekers placed in the borough, coordinating access to services, safeguarding children and adults at risk, and delivering support in line with government guidance and statutory responsibilities.
UK GDPR Article 6(1)(c) – Legal obligation
Processing is necessary to comply with legal obligations placed on us. This includes duties relating to safeguarding, housing support, public health, equality, immigration-related support functions, and reporting or assurance requirements linked to government-funded resettlement and asylum schemes.

Special category data

Where we process special category data, we rely on the following lawful bases under Article 9 of the UK GDPR and the Data Protection Act 2018.

UK GDPR Article 9(2)(g) – Substantial public interest
We process special category data where this is necessary for reasons of substantial public interest, as supported by Schedule 1 of the Data Protection Act 2018.

This includes processing personal information in order to:

Support individuals with particular medical conditions, disabilities, or additional needs Including identifying health-related needs, coordinating appropriate support, and helping individuals access health, wellbeing, and social care services.
Safeguard children and adults at risk Including identifying vulnerability, managing risks, sharing information with safeguarding partners where appropriate, and taking action to protect individuals from harm.
Protect physical, mental, and emotional wellbeing Including supporting individuals who may have experienced trauma, displacement, exploitation, poor mental health, or other adverse experiences associated with the asylum or resettlement process.
Promote equality of opportunity and fair access to services Including ensuring individuals are not disadvantaged in accessing services due to disability, health conditions, race, or other protected characteristics.
Carry out statutory and government functions Including responsibilities associated with refugee resettlement schemes, asylum support arrangements, safeguarding duties, and public protection activities.

All special category data processed under this condition is limited to what is necessary for the purpose, handled proportionately, and subject to appropriate safeguards.

UK GDPR Article 9(2)(h) – Health and social care
Where relevant, we also process special category data where it is necessary for the provision or management of health or social care services, or to support individuals’ health and wellbeing. This includes helping individuals access healthcare, mental health services, and related support.

Criminal data

Where criminal data is processed, this is done in accordance with the Data Protection Act 2018. Criminal data is only processed where it is necessary and proportionate for safeguarding, risk management, or the protection of children or adults at risk, and appropriate safeguards are in place.

Information may be shared with relevant statutory partners under these lawful bases where this is necessary to deliver the service safely and lawfully.

Legislation we rely on

When processing personal information for the Refugee and Asylum Seeker Resettlement and Support Service, we rely on a combination of statutory duties, government directions, and public functions. This includes, but is not limited to, the following legislation and legal frameworks:

Immigration and Asylum Act 1999
Including sections relating to the provision of support to asylum seekers, accommodation arrangements, and cooperation between the Home Office and local authorities.
Nationality, Immigration and Asylum Act 2002
Including provisions that enable information sharing between the Home Office and local authorities for the purposes of immigration control, resettlement, and settlement-related functions.
Children Act 1989 and Children Act 2004
Including duties to safeguard and promote the welfare of children and young people, and to work with partner agencies where concerns about a child’s wellbeing or safety are identified.
Care Act 2014
Including duties relating to the safeguarding of adults at risk and the provision of support to individuals with care and support needs.
Housing Acts
Including duties relating to homelessness prevention, temporary accommodation, and housing support for vulnerable individuals and families.
Equality Act 2010
Including duties to prevent discrimination, promote equality of opportunity, and provide reasonable adjustments for individuals with disabilities or protected characteristics.
Health and Social Care legislation
Including legislation and guidance that supports access to healthcare, mental health services, and public health responsibilities.

International Data Transfers

The Refugee and Asylum Seeker Resettlement and Support Service primarily processes and stores personal information within the United Kingdom.

In some limited circumstances, personal information may be transferred outside the UK. This may occur where information is received from, or shared with, overseas organisations as part of government-led resettlement schemes, or where international agencies are involved in supporting individuals before or after arrival in the UK.

Where personal information is transferred outside the UK, we ensure that appropriate safeguards are in place to protect the information and the rights of individuals. These safeguards may include:

Ensuring the destination country has been recognised as providing an adequate level of data protection under UK data protection law.
Using legally approved transfer mechanisms, such as International Data Transfer Agreements or standard contractual clauses, where required.
Applying additional technical and organisational measures, such as access controls and encryption, to protect information.
Only transferring personal information where it is necessary, proportionate, and lawful to do so.

We do not routinely transfer personal information outside the UK, and any international transfers are kept under review to ensure compliance with data protection legislation.

Retention Period

We only keep personal information for as long as it is necessary to deliver the Refugee and Asylum Seeker Resettlement and Support Service and to meet our legal, statutory, and safeguarding obligations.

Personal information is retained in line with our Corporate Retention Schedule, which sets out how long different types of records must be kept before they are securely destroyed or archived.

In general, this means:

Records relating to adults Information relating to resettlement or asylum support provided to adults is usually retained for up to 7 years after you are no longer receiving support. This allows us to manage complaints, reviews, audits, safeguarding matters, and legal requirements.
Safeguarding and risk-related records Where records relate to safeguarding concerns, risk management, or legal matters, information may be kept for up to 25 years in line with safeguarding and statutory requirements.
Records relating to children and families Where services involve children or young people, records are retained for longer periods to protect rights and ensure accountability. Depending on the circumstances, this may include retention until a child’s 25th birthday, 31st birthday, or 75th birthday, in line with statutory safeguarding requirements.
Housing and accommodation records Records relating to housing and accommodation support are generally retained for between 7 and 12 years, depending on the type of record and legal status.
Monitoring, reporting, and funding records Some information may be retained to meet government reporting, assurance, or funding requirements. Where possible, this information is anonymised.
Historical and archival records Where information has long-term historical value or supports public accountability, it may be securely archived rather than destroyed, in line with archival guidance.

Once the relevant retention period has expired, personal information is securely destroyed or anonymised in accordance with our Records Management Policy. Retention periods may be extended where required due to legal proceedings, statutory inquiries, or safeguarding obligations.

Your Rights

The UK GDPR provides you with several rights to control what personal information is used by us and how it is used by us.

Further guidance about these rights can be accessed from the Information Commissioner’s Office (ICO) website.

If you are not happy about the way your personal data is being used, or you require further information about how we process your personal data, you can contact Council’s Data Protection Team:-

Online: 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:

Website: Information Commissioner's Office (ICO)
Instant Message: Live Chat
By post: The Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113