Troubled families service privacy notice
The data controller for your data
Brighton & Hove City Council is the data controller for purposes of the Data Protection Act (2018) and The General Data Protection Regulation (EU) 2016/679 ("GDPR") and is registered as a data controller with the Information Commissioner’s Office (ICO) under registration number Z5840053.
Brighton & Hove City Council are committed to protecting your personal information. As a data controller we have a responsibility to make sure you know why and how your personal information is being collected in accordance with relevant data protection law.
Why we’re collecting your data
We are collecting your data for the purpose of the National Evaluation of the Troubled Families programme.
Families with a range of problems often struggle to get the right help and support at the right time. The council is working to ensure that families with multiple issues receive coordinated help and support when it is most needed, and that this help and support is delivered using a whole family approach. This help and support is funded by the national Troubled Families programme and is known locally as “Stronger Families, Stronger Communities”.
Research into this is being led by the Troubled Families Analysis team at the Ministry of Housing, Communities and Local Government (MHCLG).
Your data has been identified as suitable because your family has two or more of the following problems that local services hope to help families with:
- Out of work or at risk of financial exclusion (debt and / or housing related problems, young adults who are NEET)
- School absence problems
- Children in need (those with behavioural or developmental issues, or those at risk, or on child protection plans)
- Offending and anti-social behaviour
- Domestic abuse
- Mental or physical health issues
You may or may not currently be receiving a service to help you deal with your problems.
What is the Legal Basis for collecting your Data
We have a lawful basis for processing personal data under Article 6 of GDPR. The processing is necessary for this reason:
- (e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
- We have an additional condition for processing special category data under Article 9(2) of GDPR. Special category personal data may be processed if:
- (g) 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 the interests of the data subject.
The DPA 2018 will provide a lawful basis to process criminal offence data (as required by Article 10 GDPR).
The local authority will collect the personal data under the public task basis (to fulfil their functions, in this case deliver services to troubled families) and agree to share this data with MHCLG under the public task basis (to fulfil our functions as a Government Department, in this case to improve services for troubled families).
The data we may collect
We may collect Personal data or Special Category Data. The type of information collected from you is as follows:
- Name and address
- Date of birth
- National identifiers such as NI numbers and NHS Numbers
Special Category Data
We may also collect Special Category (sensitive data) of personal data that may include:
- Physical or mental health details
- Racial or ethnic origin
- Offences (including alleged offences)
- Criminal proceedings, outcomes and sentences
Who we’ll share your data with
In order to assess how well services for families with multiple problems are working, what public services families use, and what benefits they receive, MHCLG will use your personal information to gather information held by other government agencies.
This information will only be used for research and will be anonymised so the researchers will not know whose data they have.
This information will be provided by your local authority to the partner for the evaluation, Office for National Statistics (ONS). They will keep your data secure.
Your personal information and some information provided by the local authority will be linked to information held by other government departments:
- Department for Work and Pensions (DWP) - to see what benefits you have received and whether you have been employed
- Ministry of Justice (MOJ) - to see what contact you may have had with the criminal justice system
- Department for Education (DfE) - to see when your child has been in school, how well they are doing at each Key Stage and whether they are a Child in Need.
MoJ, DWP and DfE will not keep your name on file for longer than a month and will not keep records showing you were part of this research.
Please note that any information you provide will not be used to make any decisions about what benefits you get, or services you use, now, or in future.
The information gathered from the local authority will be linked with the information on your benefits, your child's information and any contact you or your children have had with the criminal justice system.
All information collected about you by MCHLG will be kept strictly confidential. Your name, date of birth, gender, address and National Insurance number will be kept separately from all the other information in a secure, password-protected document on a computer system. You will be assigned a unique reference number, so that even though a researcher will see all your information, they will not be able to identify you.
The final results of this research will be published on the main government website. You will not be identified in any research report.
How long we’ll keep data for and why
All personal information held by the Local Authority and by ONS for the Troubled Families Programme will be securely destroyed by December 2022. The personal information held by DWP, MoJ and DfE for this research will be securely destroyed after a month and they will not keep records showing you were part of this research.
How your data will be stored
Your information will be stored electronically. We will only make your information available to those who have a right to see it.
- Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it.
- Regular testing of our technology and ways of working including keeping up to date on the latest security updates (commonly called patches).
Transferring Data outside the European Economic Area
Your data will not be transferred outside the European Economic Area.
You can talk to your local authority about whether your data is being used for this project without it affecting your legal rights or routine care. You can also see copies of all the data MHCLG hold about you and ask for it to be corrected or deleted.
You can also contact MHCLG's Knowledge and Information Team about seeing your data or withdrawing from the research by emailing MHCLG's Data Protection Officer at email@example.com
Depending on the legal basis for processing your information you may have the following rights:
- A right to a copy of data held about you, an explanation for its processing and who it has been shared with – this right applies to data processed under any lawful basis
- A right to rectification (correction) of data which is demonstrably wrong – this right applies to data processed under any legal basis
- A right to restrict processing – this right applies if it has been shown that there is no legal basis for processing your data, but you wish it to be retained
- A right to object to processing – this right does not apply where the council is under a legal duty to process your data, but can be used where you dispute that there is a legal basis to process your data until the Council can demonstrate what basis exists
- A right to erasure – this applies where there is no longer a legal basis to retain you data
- A right to portability of your data (having it moved to another organisation) – this right applies only where the legal basis was either consent or performance of a contract but data will usually be transferred to another local authority if a child in care moves to a new location.
- A right to object to automated decision making – this right is applicable under all lawful bases for processing
How to get advice or make a complaint
Data Protection Contacts
If you wish to discuss any of your data protection rights, you can contact the Data Protection Team on 01273 29 5959 or by email at firstname.lastname@example.org
The council has also appointed a Data Protection Officer. Contact the Data Protection Officer.
Whilst we would prefer that you contact us first with any concerns that you might have, you can also contact the Information Commissioner’s Office. The ICO is the national regulator with responsibility for ensuring compliance with data protection.
Information Commissioner’s Office
You also have the right to lodge a complaint with a supervisory authority.
Contact details for ICO are stated below:
The ICO can be contacted:
- on their website
- by phone: 0303 123 1113
- by post: Wycliffe House, Water Ln, Wilmslow SK9 5AF
This privacy notice will be subject to review when there is a change.