Warm Scottish Welcome Programme: privacy notices

Privacy notice for displaced people

This privacy notice provides information for people displaced from Ukraine and seeking sanctuary in Scotland, about how The Scottish Government uses your personal data, and the rights you have under UK data protection legislation.

Who we are

The Scottish Government’s Warm Scottish Welcome Programme facilitates the Scottish Government’s humanitarian response to Russia’s illegal war against Ukraine and administers the Scottish Super Sponsor Scheme. Ensuring that displaced people are safe and supported, with the opportunity to integrate and thrive, for as long as Scotland is their home. 

We are working with the 32 Scottish local authorities and their umbrella organisation, the Convention of Scottish Local Authorities (COSLA), to provide support for displaced people, as well as those around them. This includes through the provision of initial accommodation, safeguarding and broader resettlement support.

The type of personal information we collect

The data we currently collect is detailed below. It may not always be case that we have the complete details below, as this is dependent upon the services you have interacted with before, and after, arrival in the UK. The initial data is provided to us by the UK Government, from your visa application. This is subsequently improved on by National Services Scotland and local authorities (if you have been in contact with them).

Identification data:

• names (given name, family name, other names)
• date of birth
• sex
• country of origin, citizenship
• languages spoken (incl. need for interpreter)
• passport details

• marital status

Contact and location details:

• email
• phone number
• contact preference
• current accommodation address

Visa data:

• visa status
• decision,
• date of decision
• visa application number
• person reference number

• scheme under which they applied (Super Sponsor, HfU, Family)

Connections with other individual data subjects:

• nature of relationship
• size of groups
• Details of previous cases/ groups (where case structure has changed)

Journey details:

• date and location of arrival (ahead of arrival)
• date and point of entry to the UK

System data:

• unique application identifier
• unique person identifier
• local authority reference numbers

Support needs (received from NSS):

• mobility assistance required
• pregnancy status (if relevant)
• number and type of pets they are travelling with
• health information, including current health conditions, pregnancy status, mobility issues, specialist referrals, and any support needs as a result of these Requirements for education and additional support needs
• ASN requirements

Details of support provided:

• responsible local authority
• temporary accommodation details, including proposed, planned, rejected, and complete – hotel, hotel room number
• hosting arrangements including proposed, planned, rejected, and complete
• publicly funded accommodation or private rental arrangements including proposed, planned, rejected, and complete
• “Moving On” outcomes such as private rentals, leaving the UK
• summary details of interactions with local authority and Scottish Government including meetings, phone calls and correspondence

Safeguarding data

Received as ad hoc data from local authorities, and third sector partners with details about specific safeguarding concerns for displaced individuals, Hosts, and/or Sponsors. This includes information key to the safeguarding of children and individuals at risk. This can include Personal data revealing:

• racial or ethnic origin
• political opinions
• religious or philosophical beliefs
• health
• sex life
• sexual orientation

Additionally, we may be made aware of criminal offence data concerning individuals when receiving information in the context of safeguarding concerns.

How we receive your personal information, why we collect it, and what we do with it

We receive information about you from the UK Government, which was provided to them during the visa application process. We share information with the Scottish local authority where you are based, to provide you with direct support, and ensure that any arrangements meet safeguarding requirements (such as having enough room for you and your family).

Local authorities collect further data to help administer their statutory duties. This may also be shared with us to ensure that an adequate amount of support is provided where needed, ensuring that risk to you is minimised and that the data we hold is correct.

We will provide NHS National Service Scotland (NHS NSS) with your contact details so they can contact you about the information above. NHS NSS facilitates the Warm Scots Welcome call centre on behalf of the Scottish Government and will collect the information listed above. As a data processor, NHS NSS will only process personal information at the direction of the Scottish Government and does not take ownership of the data.

The Scottish Government will use the data above to match you with a suitable host, or accommodation, to ensure that what they have offered meets your requirements (such as having enough room for your family). If you have identified a sponsor in Scotland, we will transfer your information to the local authority where that sponsor lives. The local authority is responsible for housing – as well as education and social services – in the area of Scotland to which you will be moving, so they can offer you direct support.

Your data will be stored on the Warm Scots Welcome (WSW) app as part of the Scottish Government's digital platform. The WSW app is used by local authorities and the Scottish Government's surge team to match displaced individuals with hosts and other suitable accommodation in Scotland.

Lawful basis

 Under the current data protection legislation, the lawful basis we rely on for processing this information are:

• to fulfil our public task (UKGDPR Article 6(1)(e));
• for special category data this is for substantial public interest (UKGDPR Article 9(1)(g); supported by DPA 2018 Schedule 1, Pt. 1, paragraph 6 (Statutory and government purposes); and 18 (Safeguarding of Children and individuals at risk);
• for criminal offence data this is for substantial public interest (UKGDPR Article 10); supported by DPA 2018 Schedule 1, Pt. 2, paragraph 6 (Statutory and government purposes); and 18 (Safeguarding of children and individuals at risk).

How we store your personal information

Your information is stored securely on the Scottish Government’s digital platform by one of our approved processors.

We will keep your personal information for as long as is necessary for the proper administration of the programme.

Once the programme is concluded, we will dispose of this information by removing it from our system. However, we may retain anonymised data for statistical and reporting purposes, subject to regular review.

Your data protection rights

Under data protection law, you have rights including:

Your right to be informed – about how we are using your personal data, which is done through this privacy notice. When other organisations, such as the UK Government or local authorities, use your data they will also tell you about this.

Your right of access - you have the right to ask us for copies of your personal information. You can also request data on behalf of someone else if they want you to do this.

Your right to rectification - you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - you have the right to ask us to erase your personal information our system, or limit how we use it, in certain circumstances. If we are legally obligated to store your data for longer than you wish we may not be able to carry out this request, but we will tell you this.

Your right to restriction of processing - you have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - you have the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, 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.

Please contact us at dpa@gov.scot if you wish to make a request.

These rights are not absolute and may be subject to exemptions.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at:

Scottish Government Data Protection Officer
Victoria Quay
Commercial Street
Edinburgh
EH6 6QQ 

DataProtectionOfficer@gov.scot

You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data.

The ICO’s address:   

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk