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Housing First Privacy Notice

This page explains how your data will be held about you and how it will be used by the Greater Manchester Combined Authority (GMCA) and its Housing First Partner Great Places Housing Group and it will explain the relationship between GMCA and Great Places and their delivery partners who have been contracted by Great Places to deliver accommodation and support to service users on the Housing First Initiative.

 

You can also find out about the General Data Protection Regulations and Data Protection Act 2018 and your rights.

 

It is important that you read this notice, together with any other privacy information GMCA or Great Places may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

 

Who We Are

 

Greater Manchester Combined Authority (GMCA) and Great Places Housing Group are committed to ensuring that we are open about the ways in which we use your personal information and that we have the right controls in place to ensure it is used responsibly and is kept safe from inappropriate access, theft or deliberate misuse.  

 

GMCA commission and fund the Greater Manchester Housing First programme which is delivered by a partnership with Great Places Housing Group as the lead partner. 

 

Great Places Housing Group are contracted to deliver the above services on GMCA’s behalf and to deliver these services in accordance with contractual requirements.  In order to do so Great Places Housing Group have contracted with a number of Housing Providers and support agencies across Greater Manchester to help them deliver this contract. 

 

GMCA and Great Places Housing Group will act as joint Data Controller for the personal information you provide.  GMCA are Data Controller for performance monitoring and contract compliance purposes.  For delivery of services Great Places Housing Group are the Data Controller.

 

The agencies whom Great Places have contracted to deliver services will act as a Data Processor and Great Places Housing will be the Data Controller for the personal information you provide. Personal information can be anything that identifies and relates to a living person. This could be your name and contact details. As joint Data Controllers, GMCA and Great Places will use your information to provide and deliver housing related support services to you.

 

Why do we collect your Information?

 

GMCA use your information to:

 

  • Ensure services provided on behalf of the local authorities of Greater Manchester are of a good standard. 

  • Ensure services provided on behalf of local authorities of Greater Manchester are provided in line with contractual requirements

  • Help investigate any worries or complaints about the services

  • Understand and project the need and demand for services 

  • Commission new services or alter current service provision to ensure it continues to meet service user’s needs.

 

Great Places Housing Group and the partners they have contracted with use your information to:

 

  • Deliver services as set out in the service specification

  • Provide you with support and advice

  • Create and develop support plans and review your progress against agreed outcomes

  • Effectively manage and mitigate risk

  • Support you to access and receive support from other agencies as agreed with you

  • Deliver any health and social care inputs identified as needed 

  • Direct you towards training and group activities including potential peer mentoring opportunities

  • Ensure services provided by the delivery partners are of a good standard.

  • Provide contract monitoring data to GMCA in order to ensure they are providing services in line with contractual requirements

 

GMCA and Great Places Housing Group are not permitted to collect information we do not need or will not use. This document covers information that has been provided by the agency that has referred you to the Housing First programme and information you provide direct to Great Places Housing Group and their delivery partner organisations that are assisting them in the delivery of the Housing First Programme.

 

If GMCA doesn’t need your personal information we will either keep your details anonymous if we already have it for another service or we won’t ask you for it. If we use your personal information for research or analysis, we will always keep your details anonymous or use a fake identifier.

 

The Legal Basis for using your information

 

GMCA and Great Places Housing Group must have a reason to collect and use your information according to the General Data Protection Regulations (GDPR) and the Data Protection Act 2018, for example:

 

  • To enable us to manage the services provided

  • To enable us to provide you with the most appropriate support

  • To investigate any worries or complaints you may have about our services

  • To check the quality of our services

  • To train and manage the workers who deliver those services

  • To help with research and planning of new services

  • Ensure that public money is spent wisely and efficiently

 

There are a number of legal reasons why GMCA and Great Places Housing Group need to collect and use your personal information. For the Housing First service the following apply:

 

  1. Contract: you have entered into a contract. (Provision of Accommodation with Support)

 

  1. Vital interests: The processing may be necessary to protect someone’s life or protect them from significant harm;

 

  1. Legal obligation: it is required by law – Housing Acts, Local Government Act 1972, Crime & Disorder Act 1998, Anti-Social Behaviour, Crime & Policing Act 2014; Housing Act 1998, Homeless Reduction Act 2017

 

  1. Public task: The processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.

 

In addition to personal data such as name, date of birth, address, contact details GMCA and Great Places also need to use sensitive personal data called “special category data” which requires more protection to keep it safe. This is information very personal to you some of which you would not want to be widely known. It includes:

 

  • Sexual orientation

  • Religious or spiritual or philosophical beliefs 

  • Ethnicity and nationality

  • Marital status

  • Family circumstances

  • Gender

  • Physical or learning disability

  • Physical or Mental health

  • Criminal history

  • Education, employments information

  • Financial circumstances,

 

Both GMCA and Great Places will take extra care of the data they control and process. The legal reason for us to collect and use this personal information is:

 

  • you have entered into a contract with us (Provision of Accommodation with Support)

  • it is necessary to deliver health or social care services

  • processing is necessary for reasons of substantial public interest

 

Who we may share your information with

 

GMCA and Great Places Housing Group use a range of organisations to either store personal information or to help deliver our services to you. Sometimes we have a legal duty to provide your personal information to other organisations, for example Courts, HMRC.

 

Prior to being referred to Great Places for a place on the Housing First Programme your personal information will be provided to one of the following Greater Manchester local authorities to which you have a local connection with who will then share this with Great Places:

 

  • Bolton MBC

  • Bury MBC

  • Manchester City Council

  • Oldham MBC

  • Rochdale MBC

  • Salford MBC

  • Stockport MBC

  • Tameside MBC

  • Trafford MBC

  • Wigan MBC

 

Other agencies and partner who we may share with

 

  • Greater Manchester Police;

  • National Probation Service;

  • Greater Manchester Probation Service;

  • Youth Offending Service;

  • Department for Work and Pensions;

  • Immigration Compliance and Enforcement;

  • NHS Foundation Trusts (where you are living);

  • Your GP;

  • Your Landlord / Housing Provider;

  • Greater Manchester Community Rehabilitation Company;

  • Local Advocacy groups and/or Victim Support;

  • Department for Levelling Up, Housing and Communities;

 

Services within your Local Authority

 

  • Financial Services,

  • Housing & Community Services,

  • Social Services

  • Adult Social Care,

  • Children & Young People’s Social Care,

  • Children, Young People & Learning;

  • Commissioning & Improvement;

  • Audit and Management Assurance

 

We may also ask these organisations for information.

 

Your information will not be disclosed to any other organisations, except where we are required and allowed to by law.  

 

If accepted onto the programme, as part of ensuring you receive the service you require Great Places Housing Group will need to share your personal information with the relevant delivery partners working in your area.   The full list of delivery partners is as follows:

 

  • Regenda Homes

  • The Bond Board

  • Stockport Homes

  • Jigsaw Homes Group

  • Riverside Housing

  • Early Break

  • Community Led Initiatives

  • HumanKind

  • MASH

  • Greater Manchester Mental Health Foundation Trust

 

GMCA and/or Great Places Housing Group may seek your consent if we are able to offer additional services which we believe are of benefit to you. This will be clearly communicated to you. We will only share your details if we have your consent. We will not share your information otherwise.

 

GMTHINK

 

In order to manage the contract and provide support to you, GMCA have procured a database called GMTHINK for Great Places Housing Group  and their delivery partners to use to record your information.

 

GMTHINK (Greater Manchester Tackling Homelessness and Information Network) is a database which helps coordinate support for people facing homelessness and/or substance use and mental ill health in Greater Manchester. It has been developed in partnership with people who have experienced support services and it is designed to help coordinate support for people by improving communication between staff across support agencies and people accessing these services.  

 

Information held on GMTHINK is only available to carefully selected organisations. This means that only those working directly with people accessing services can enter information into the system. These include outreach teams, engagement workers, peer mentors and other specialist services. When your information is entered into GMTHINK most parts can be seen by other organisations. This will include your personal details, your accommodation situation, your support needs and whether you have had contact with that service.

 

More detailed information can be kept private and not shared with other organisations (you can speak to your Support Worker about this). Your information is also available to staff within organisations who are responsible for funding such services and developing plans to reduce or end homelessness. They will also have responsibility to ensure that your information is used appropriately and your rights are protected.

 

Information from GMTHINK will sometimes be used in statistics and research to help find ways to improve Services. Names and other information that could identify an individual are never included in research and statistical reports.

 

If you have any concerns about who can see your data you should discuss these with you GM Housing First Worker. A list of organisations using GMTHINK is available on request.

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Further information on onward transfers

 

Your data will not be transferred outside of the UK or European Union unless this is permitted in accordance with the Data Protection Act 2018.

 

How long will my personal data be kept for?

 

The personal data you have supplied will be destroyed in accordance with GMCA Data Retention Policy which is  six years after the end of the Housing First programme.

 

Great Places Housing Group and their delivery partners will however destroy any information they hold at the end of their contract and return it to GMCA.

 

Statutory Obligations to provide the personal data

 

There is no statutory obligation on you to provide any personal data about you, however, if you do not you will not be able to be referred to the Housing First Programme.  

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Accessing the information we hold about you

 

You have some specific rights in respect of your personal data. These may include some or all of the following rights to:

  • see what personal data about you GMCA or Great Places holds at any time (subject to certain caveats, for example where third parties are identified);

  • to have corrected any errors in the personal data held about you;

  • request your personal data is erased (though this right will not apply when your data is processed because it is necessary to comply with a legal obligation);

  • request processing of your personal data is restricted (this will only apply in certain situations, for example where its accuracy is contested, where the processing is unlawful and the you oppose its proposed erasure, or where GMCA/Great Places no longer needs to process the personal data, but it is required by you in connection with legal claims);

  • object to the processing where the processing is necessary for a task carried out in the public interest or in the exercise of official authority vested in the data controller (though GMCA will still be able to continue with the processing in certain circumstances, such as if there are compelling grounds for the processing which over ride your interests)

  • In defined circumstances [either where the processing relies on your consent or arises out of a legal contract], you may request a copy of personal data that you have provided to in a commonly used and machine-readable form.

  • Where the legal reason for processing your personal information is based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of our processing prior to the withdrawal of your consent. 

 

Automated Decision Making

 

The personal data provided by you will not be used for any automated decisions.

 

Data Protection Officer

 

If you wish to exercise your rights (as outlined above) or raise a concern about the handling of your personal information by GMCA, please contact our Data Protection Officer (DPO).

 

Great Places Housing Group

2a Derwent Avenue
Manchester
M21 7QP
Tel: 0161 447 5000

Data.Protection@greatplaces.org.uk

 

GMCA

Office of the Data Protection Officer

Greater Manchester Combined Authority

Churchgate House

56 Oxford Street, Manchester, M1 6EU

 

OfficeofDPO@greatermanchester-ca.gov.uk.

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Your Right to Lodge a Complaint

If you are unhappy with the way that your personal data has been processed you have the right to lodge a complaint with the Information Commissioners Office.

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Postal:        Information Commissioners Office
                   Wycliffe House
                   Water Lane
                   Wilmslow
                   Cheshire
                   SK9 5AF 

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Telephone: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

Email:          casework@ico.org.uk Web Form:  www.ico.org.uk

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Reviewed June 2024

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