Youth homelessness prevention trailblazer – privacy notice
The Trailblazer partnership comprises of Lancashire County Council, Blackburn with Darwen Council, Burnley Borough Council, Chorley Council, Hyndburn Borough Council, Lancaster City Council, Pendle Borough Council, Ribble Valley Borough Council and Rossendale Borough Council. Trailblazer also works with third party partners, Positive Action in the Community (PAC), Ynot Aspire, Stepping Stone Project Ltd, The Salvation Army, M3 Project Ltd, Nightsafe and Methodist Action North West.
The partners have will deliver the first response, early intervention service for 14-25 year olds who are at imminent risk of homelessness from the parental home.
What Trailblazers do
Trailblazer delivers a range of early intervention, conciliation and mediation services for both young people and their parents/carers that are focused on increasing skills and resilience within the family. All partners of the project will deliver a flexible response required to enable the timely use of the other temporary accommodation options or interventions. It should be noted that although the service will aim to prevent homelessness across the 14-25 age group, preventing homelessness among the age group 14-17 will be a priority because of the potential adverse effects of early homelessness and the increased safeguarding risk.
Trailblazer also delivers activities in the educational and community settings aimed at young people aged 14 plus to increase awareness of homelessness and the highlighting the importance of staying at home and/or delaying early moves into independent living. As part of the outreach activity the partners will look to identify vulnerable young people in the community who may be at risk of future homelessness they will then develop a range of resources and interventions and engage effectively with the young person.
Information that will be shared
Each Trailblazer organisation will only share the necessary and relevant information required to achieve the purpose of working with children and young adults at risk of homelessness. Each organisation may already hold different categories of information if they've provided a service to the individual in the past. Lancashire County Council will only share the following categories of information with the Trailblazer partners; name, address, contact details, age, nationality, ethnicity, employment status, national insurance number, benefits status and information around homelessness status.
Your anonymised data will also be shared with the Department for Communities and Local Government for research purposes so that it can help improve the service that are delivered in the future. This data will not include any of your personal details (name, address, date of birth).
Information may be shared without your permission if:
- someone is being harmed or may be harmed in the future.
- the information may help to stop or solve a crime.
Legal gateways being to share the information
Data Protection Act 1998
Schedule 2 condition – Consent
Schedule 3 condition – Explicit Consent
General Data Protection Regulation
On the 25th May 2018 the Data Protection Act 1998 will be replaced by the General Data Protection Regulation (GDPR). The condition for processing under the GDPR will be:
- Processing shall be lawful only if and to the extent that at least one of the following applies:
- the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
- Paragraph 1 shall not apply if one of the following applies:
(a) the data subject has given explicit consent to the processing of those personal data for one or more specified purposes.
Children Act 2004 - Sections 10 and 11 of the Children Act 2004 place obligations upon agencies including local authorities, police, clinical commissioning groups and NHS England to co-operate with other partners in promoting the welfare of children and ensuring that they act to safeguard and promote the welfare of children in their area.
Children Act 1989 - For children and young people, the nature of the information that will be shared within Trailblazer may fall below a statutory threshold of Section 47 (children in need of protection) or even Section 17 (children in need of services).
Human Rights Act 1998 - Gives force to the European Convention on Human Rights and, amongst other things, places an obligation on public authorities to protect people’s “right to life” and “right to be free from torture or degrading treatment”. There needs to be a balance between the desire to share and a person’s right to privacy under “the right to respect for private and family life, home and correspondence”. The local authority cannot interfere with this right except such as is necessary in the interests of national security, public safety or for the prevention of disorder or crime, for the protection of health and wellbeing, or for the protection of the rights and freedoms of others.
The Mental Capacity Act (MCA) 2005 - Under the Mental capacity Act 2005 staff are required to apply five principles in their assessments to decide whether to share information without consent in a person’s best interests. Under the Mental Capacity Act 2005 there would have to be good reasons not to undertake an assessment of mental capacity regarding the decision to share information without consent. These reasons would need to be documented carefully.
How information will be used
Your information will only be used to decide whether:
- you or your family would benefit from help and support
- a crime has been committed or could be committed in the future.
- Your information will be held in a safe place and will not be shared with other people unless they have a legal power to see it.
Personal, sensitive and anonymised information
Lancashire County Council will share data with its Trailblazer partners that is classed as personal and sensitive under the Data Protection Act 1998. Only relevant data will be shared. The Data Protection Act 1998 defines personal and sensitive information as.
Personal information is:
- Information/Data which relates to a living, individual who can be identified from the data or other data/information that Lancashire County Council holds
- This could be single elements or a combination e.g. names, addresses, occupation, date of birth etc.it could also include opinions about them and intentions towards them.
Sensitive Personal Information/Data is:
- Physical or mental health, racial or ethnic origin, political opinions, trade union membership, sexual life, criminal allegations or record.
Anonymised Information/Data is:
- Data from which the individual cannot be identified by the recipient of the information.
How long your information is stored
Lancashire County Council will only store information received from their involvement with Trailblazer for as long as is legally required or in situations where there is no legal retention period they will follow established best practice. At the end of the retention period electronical data will be deleted and any physical files will be confidentially disposed of.
||Emails held in Outlook that haven't been exported or moved elsewhere||1 year from the date received and then automatically deleted.|
|Trailblazer Referral Form||The initial referral form made to Trailblazer but where no further action is needed.||3 years after the file is closed|
Trailblazer Case File
|Case file created to deal with successful referrals.||6 years after the closure of the file.|
How your information will be protected
Your information will only be accessible by staff involved with the Trailblazer project and on some occasions ICT support staff. Your data will not be stored outside the European Economic area and it will be stored and used in accordance with the Data Protection Act 1998.
If you would like more information concerning the Trailblazer project and their work then please contact Cathryn McCrink – Public Health Practitioner - Cathryn.McCrink@lancashire.gov.uk
If you would like to request a copy of the information Lancashire County Council holds on you then please make your request in writing to the Information Governance team.
If at any point you believe the information we process on you is incorrect you can request to see it and even have it corrected or deleted. Where possible we will seek to comply with your request but we may need to hold or process information in connection with one or more of the Council’s legal functions.
You have the right to opt out of Lancashire County Council receiving or holding your personal identifiable information. There are occasions where service providers will have a legal duty to share information, for example for safeguarding or criminal issues. The process for opting out will depend on the specific data is and what programme it relates to.
You have the right to remove your consent from Trailblazer at any point. If you do remove your consent for Trailblazer partners to share your information then the Trailblazer partners will not be able to provide a service to you. To remove your consent you must contact Cathryn McCrink – Public Health Practitioner - Cathryn.McCrink@lancashire.gov.uk
If you wish to raise a complaint on how we have handled your personal data, you can contact the Information Governance team who will investigate the matter. If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO).