Privacy policy for refugee resettlement and relocation schemes

Introduction 

Migration Yorkshire’s Resettlement Team holds and processes personal information supplied or collected for the purposes of coordinating and supporting delivery of national programmes of resettlement and relocation within Yorkshire and Humber. 

Leeds City Council is the controller for this information, as Migration Yorkshire is based in the Council. This includes when the information is collected or processed by third parties on Migration Yorkshire’s behalf. 

This notice describes how Migration Yorkshire and Leeds City Council will look after and use personal information that partners share with us to: 

• fulfil each party’s legal obligations 
• help prevent abuse of the resettlement/relocation process 
• prevent and detect crime 
• report Cases of Interest (COIs), where the Home Office requires us or our delivery partners to do so or for Migration Yorkshire to identify trends and issues that could be resolved or addressed. 

This includes: 

• information provided to Migration Yorkshire by the Home Office, including information provided to the Home Office by the UNHCR and IOM; 
• information provided by Migration Yorkshire’s delivery partners - local authorities in Yorkshire and Humber and the Refugee Council 

Case of Interest reports are those that record events when a person who is a beneficiary of one or other of the resettlement and relocation schemes covered by Migration Yorkshire has:

• been charged with an offence involving violence; weapons; sexual offences, fraud, hate crime, robbery (CRIMINALITY) 
• been subjected to a hate crime (HATE CRIME) 
• has been arrested for terrorism offences or intelligence comes to the knowledge of authorities which has links to terrorism or radicalisation, or where there is intent and capability to exploit a vulnerability in the immigration system e.g. misuse of a travel document or facilitation or abuse of the immigration system where false applications/false documents have been submitted (NATIONAL SECURITY) 
• suffered a serious negative impact because of an act or omission by the Home Office and/or local authorities/delivery partners (PERCEIVED FAILINGS) 

or when Migration Yorkshire or its delivery partners become aware of: 

• serious safeguarding concerns where there is a high risk of the individual harming themselves or others. This may include cases where there are significant social service, mental health or police involvement with an individual or family. Any reports of harmful cultural practices such as forced marriage, Honour based violence or Female Genital Mutation (FGM) (SERIOUS SAFEGUARDING CONCERNS) 
• an incident that has media coverage or potential media coverage including social media (MEDIA INTEREST). 

Migration Yorkshire also collects and shares information for any cases of interest that do not meet any of the above criteria but are still of concern and may require action by Migration Yorkshire or its delivery partners.  This includes:  

Serious medical/mental health issues, serious housing issues that have an impact on families, serious school incidents and any other issues which may impact on the ability to successfully resettle.   

This Privacy Notice also covers what information we may share with other organisations. 

How we protect personal information 

We have a duty to safeguard and ensure the security of personal information. We do that by having systems and policies in place to limit access to personal information and prevent unauthorised disclosure. Staff who access personal information must have a business need for accessing the information, and their activity is subject to audit and review. 

Migration Yorkshire receives and processes personal information to fulfil its 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. 

Our legal basis for processing your personal data 

The legal basis for the processing of personal data will, in most cases, be Article 6(1)(e) of the UK GDPR – that is, that the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. 

In considering a case referral from the Home Office for resettlement or relocation within Yorkshire and Humber, we also process special categories of personal data on the basis of Article 9(2)(b) of the UK GDPR where the processing is necessary for reasons of employment, social security and social protection. This may include information about political beliefs, sexual orientation, religious beliefs, and biometrics. 

Safeguarding the welfare of children and vulnerable adults 

We may also process personal data under Article 10 of the UK GDPR where 'safeguarding of children and individuals at risk' is a processing condition that allows practitioners to share information, including without consent. 

Examples of how we may use data: 

• to ensure that relevant authorities and services can provide support to vulnerable individuals and families 
• to support decisions on vulnerable people 
• to identify people at risk 

Other organisations with access to personal information 

A number of organisations from the private, public and charity sectors are either contracted by, or subject to agreement with Migration Yorkshire to provide functions in relation to resettlement or relocation schemes. To do this they may process personal data on our behalf and under our direction. Where this is the case (unless the sharing is obliged under statute or regulation or under the instructions of a court), we will provide further privacy information to you when such processing may take place. 

Examples of these functions where we use other organisations in this way include: 

• to support the resettlement/relocation process – providing integration and caseworker services 
• to conduct customer experience research and operate customer contact centres 
• to help provide services in relation to vulnerable people and those seeking protection – this includes support for the processing of resettlement/relocation cases  

How long we keep personal information for 

We will keep personal information for as long as it is necessary for permitted purposes.  

Personal data will typically be retained for 12 months after the individual’s resettlement/relocation support entitlement has ended. 

Your data rights 

Leeds City Council is the data controller for the information you provide. Details of your rights under UK data protection legislation, including details of the Council’s Data Protection Officer, your rights as a data subject, and your right to complain to the Information Commissioner’s Office are available at the following link: www.leeds.gov.uk/privacy-statement/privacy-notice