Warm Scottish Welcome Programme: privacy notices

Privacy notice for sponsors

This Privacy Notice provides information for an individual that has sponsored through the Homes for Ukraine Scheme, and the rights you have under UK data protection legislation.

A sponsor is presumed to be, and agrees to act as, a host under the Homes for Ukraine Scheme, and as such the data held (even whilst not acting as a host is the same) is the same for all sponsors.

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 and hold is detailed below.

Home for Ukraine Sponsor

• sponsor data (HfU)
• names
• DOBs
• address in Scotland where the subject will reside
• contact details – email address, phone number
• passport or other identification number
• connection between the applicant and sponsor
• sponsor check outcomes
• sponsor property check outcomes
• sponsor sex
• sponsor relationship status
• decision on whether you (and/or the other people in your household) have passed an Enhanced Disclosure Scotland check.
• decision on the suitability of the property offered.
• decision on whether you have passed Local Authority safeguarding check.
• confirmation that you wish to proceed with your host offer, along with any additional relevant information about your offer gathered through their initial checks.
• confirmation if you wish to withdraw your host offer.
• confirmation that your property is being used by the local authority(s) directly to undertake matching with your accommodation, with a displaced person(s) from Ukraine.

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 those you are sponsoring).

Initially, your information will be transferred to the relevant local authority(s) where your accommodation is located. As part of their initial assessment, they will then contact you to carry out the required checks. The applicable local authority(s) will also provide you, and the displaced people from Ukraine, with support and access to public services, as applicable.

We may retain de-identified data for statistics, reporting and research purposes. This will be subject to regular review, and we will continue to keep retention periods under review.

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