Youth homelessness prevention trailblazer

In order to comply with the UK General Data Protection Regulation (UK GDPR), where personal data relating to a data subject is collected, Lancashire County Council would like to provide you with the following details.

Identity and contact details of the data controller

  • Lancashire County Council, PO Box 78 County Hall, Fishergate, Preston, Lancashire, PR1 8XJ

Contact details of the data protection officer

  • Our Data Protection Officer is Paul Bond. You can contact him at dpo@lancashire.gov.uk or Lancashire County Council, PO Box 78 County Hall, Fishergate, Preston, Lancashire, PR1 8XJ

Purposes for processing

Trailblazers

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.

Category of personal data being processed

  1. Personal data (information relating to a living, identifiable individual)
  2. Special category personal data (racial, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation)

Legal basis for processing personal data

The legal basis for processing your personal data, in accordance with the UK GDPR is:

(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

(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. You must reference the applicable task/function and its' basis in law if you wish to rely on this basis for processing.

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.

Legal basis for processing special categories of personal data

The legal basis for processing your special categories of personal data, in accordance with the UK GDPR is:

(a) The data subject has given explicit consent to the processing of this personal data.

(h) Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services.

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.

Recipients of the data

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.

Information we share

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.

Any transfers to another country

  • No

Retention periods

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.

File Type Description Retention Period
Email 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.

Your rights

You have certain rights under the UK General Data Protection Regulation (UK GDPR), these are the right:

  • to be informed via Privacy Notices such as this.
  • to withdraw your consent. If we are relying on your consent to process your data then you can remove this at any point.
  • of access to any personal information the council holds about yourself. To request a copy of this information you must make a subject access request in writing. You are entitled to receive a copy of your personal data within 1 calendar month of our receipt of your subject access request. If your request is complex then we can extend this period by a further two months, if we need to do this we will contact you. You can request a subject access request, either via a letter or via an email to Information Governance Team, address below.
  • of rectification, we must correct inaccurate or incomplete data within one month.
  • to erasure. You have the right to have your personal data erased and to prevent processing unless we have a legal obligation to process your personal information.
  • to restrict processing. You have the right to suppress processing. We can retain just enough information about you to ensure that the restriction is respected in future.
  • to data portability. We can provide you with your personal data in a structured, commonly used, machine readable form when asked.
  • to object. You can object to your personal data being used for profiling, direct marketing or research purposes.
  • in relation to automated decision making and profiling, to reduce the risk that a potentially damaging decision is taken without human intervention.

If you want to exercise any of these rights then you can do so by contacting:

Information Governance Team
Lancashire County Council
PO Box 78
County Hall
Preston
PR1 8XJ

Email: dpo@lancashire.gov.uk

To ensure that we can deal with your request as efficiently as possible you will need to include your current name and address, proof of identity (a copy of your driving licence, passport or two different utility bills that display your name and address), as much detail as possible regarding your request so that we can identify any information we may hold about you, this may include your previous name and address, date of birth and what council service you were involved with.

Further information

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

For more information about how we use personal information see Lancashire County Council's full privacy notice.

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.

Lancashire County Council, PO Box 78 County Hall, Fishergate, Preston, Lancashire, PR1 8XJ or email: dataprotection@lancashire.gov.uk

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).