How we use your personal data
Privacy notice – high impact families
North Somerset Council is registered with the Information Commissioners Office for the purpose of processing personal data.
We, along with our partners, have committed to the Government to deliver the national programme in our area (known nationally as the Troubled Families Programme). In order to fulfil our obligations, it is necessary to share information with critical partners. This is important both for the delivery of the programme and evaluating its effectiveness.
The information you provide will be held and used in accordance with the requirements of UK and European data protection law. The information will form part of High Impact Families and held for 8 years after the programme ends in 2020.
Unless otherwise agreed with you, we will only collect the minimum personal data required to deliver the service, which includes the following sensitive/non-sensitive data:
- basic information
- family unit identifier
- date of birth
- relation in the family
- date screened for eligibility
- criteria type met
- intervention for comparison group
- date support started
- date support ended
- intensity of support
- unique identifier
- unique pupil number
- school unique reference
- national insurance number
- police national computer number
- NHS number
The lawful basis for processing personal data is under Article 6(1)(e) of the General Data Protection Regulations. The processing is necessary to perform a task in the public interest or for our official functions and the task or function has a clear basis in law. The lawful basis for processing special category data (sensitive personal data) is under Article 9(2)(g) of the General Data Protection Regulations. Processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject.
We will not use your personal information in a way that may cause you unwarranted nuisance. Failure to provide the information could result in
- not identify the families needing our support
- understand and meet the needs of the families
- understand the difference we are making
Our information relating to individuals and families will be matched with information from public agencies and organisations such as the NHS and health organisations, Department of Work and Pensions, the Police, the Ministry of Justice, the Probation Services, schools and Youth Offending Service.
We may also give your details to commissioned service providers e.g. a charity or third sector organisation that we ask to provide services on our behalf. These commissioned service providers will always have the same security standards as the council.
We may share your information with other councils and our partners in the NHS where this is lawful, and the recipient data controller has demonstrated that they have a lawful and legitimate interest in the information. Information shared with our local NHS partners is via a secure system called Connecting Care; read more information about at: https://www.connectingcarebnssg.co.uk/ . Information shared with other councils would assist in understanding and enhancing services to meet the needs of identified families, lawful under GDPR Article 6(1)(d). At no point is your data shared or processed outside of the UK.
In addition to this, the National Troubled Families Programme carries out an evaluation in which all local authorities are required to participate. Local authorities are asked to provide the following information:
- A small amount of personal information (see below for list) for every individual assessed for the programme to conduct a National Impact Study (NIS).
- Personal identifiers of information of individuals in all families assessed for eligibility (e.g. name, date of birth, gender, postcode)
- Eligibility problems met (as per financial framework document January 2018, https://www.gov.uk/government/publications/financial-framework-for-the-troubled-families-programme-january-2018-onwards
- Status of intervention (e.g. whether eligible, start/end date of intervention
- Available unique identifiers (e.g. National Insurance Numbers, Unique Pupil Numbers)
- Family Progress Data (FPD) every 6 months for all individuals in families who are being supported by the programme against measures for which there are no national administrative datasets. (For more information see above link on Financial Framework)
For your information re points 1 and 2:
- The data can only be used for carrying out research
- The linked data cannot be used to make decisions about individuals
- The linked information is anonymised to reduce the risk of individuals being identified
- It will be impossible for any person or family to be identified from any published reports
- The linked personal data will not be shared with or made available to the local authority or any other public agency
- All data is transferred, handled and stored in accordance with European and UK data protection law
- Appropriate measures are in place to prevent unauthorised use of the data
- The data is destroyed after 8 years
Legal Gateways for the sharing of information
- Childcare Act 2006 Section 1,3,10,11 https://www.legislation.gov.uk/ukpga/2006/21
- Children and Families Act 2014 Section 23 http://www.legislation.gov.uk/ukpga/2014/6/part/3/enacted
- Crime and Disorder Act 1998 Section 17 and 115 https://www.legislation.gov.uk/ukpga/1998/37/section/17
- Digital Economy Act 2017 Chapter 5 – http://www.legislation.gov.uk/ukpga/2017/30/contents/enacted
You have the right to see the personal data we process about you as well as the right of objection, rectification and restriction (of destruction only). For details of how to make such a request click on the link. http://www.n-somerset.gov.uk/my-council/data-protection-foi/data-protection/sar/
If you have any questions or concerns about the way we process your personal data our Data Protection Officer can be contacted at DPO@n-somerset.gov.uk