Guidance

Changing Futures programme: privacy notice 

Published 17 July 2021

Ministry for Housing, Communities and Local Government (MHCLG) and The National Lottery Community Fund (TNLCF) are committed to protecting and respecting your personal information.

In this statement we refer to MHCLG and TNLCF collectively as “we”, “us” or “our”, as applicable.

TNLCF and MHCLG work together to deliver the Changing Futures programme. This is achieved, in part, by the sharing of your personal information between TNLCF and MHCLG (and subsequently, with our third party contractor Social Finance) when co-ordinating and managing the programme.

This statement describes the relationship between MHCLG and TNLCF and our data protection responsibilities for personal information that is shared between us in respect of the Changing Futures Programme. This statement also describes what types of information is shared about you, how it is used by us, how we share the information with others, how you can manage the information we hold and how you can contact us.

For the purposes of data protection laws, MHCLG and TNLCF are “joint controllers” of the processing of your personal information described in this statement. This means that both bodies work together to decide why and how your personal information is processed. It also means that we are jointly responsible to you under the law for that processing.

We do not perform all processing of your personal information as joint controllers. MHCLG makes decisions regarding certain processing of your personal information independently of TNLCF, for which MHCLG is solely responsible. Similarly, TNLCF makes decisions for certain processing of your personal information independently of MHCLG, for which TNCLF is solely responsible.

The following is to explain your rights and give you the information you are entitled to under data protection legislation.  

1. The identity and contact details of MHCLG and our data protection officer     

The Ministry of Housing, Communities and Local Government (MHCLG)’s Data Protection Officer can be contacted at: [email protected]

and

The National Lottery Community Fund’s Data Protection Officer can be contacted at [email protected]

2. Why we are collecting the data    

Your personal data (work contact details) will be collected as part of your participation in the Changing Futures programme. We may use your personal data to contact you throughout your participation in the programme.

Your personal data may be shared with The National Lottery Community Fund as an interested party, with Social Finance as our contracted provider of a delivery support service to local areas and, with Revolving Doors Agency as their subcontractor.

Your personal data (work contact details) will be shared with Social Finance to enable them to provide the support that they have been contracted to give to areas on the Changing Futures programme. This is to establish working relationships with areas on the programme so they can provide effective delivery advice and support, and perform basic administrative functions to facilitate this support offer such as set up meetings, email and talk to you directly as well as with fellow participants. They may also share your personal data with local partnerships such as health agencies, voluntary sector organisations and probation services to support local collaboration and partnership development.

Social Finance may share your personal data (work contact details) with other interested parties such as other persons employed by a local authority interested in learning from the programme or an industry professional. This is to fulfil the terms of the support contract to provide a ‘national support network’ which will include Communities of Practice, Learning Events, and an Online Collaboration Platform. Participation and engagement with these are expected by all local authorities and will provide valuable opportunities for networking, reflective practice, knowledge sharing and collective problem solving. As a Processor Social Finance are only allowed to process your personal data for the purposes of the programme as directed by MHCLG.

3. Legal basis for processing the data   

Data protection legislation sets out when we are lawfully allowed to process your data. The lawful basis that applies to this processing is Article 6(1)(e) of the UK GDPR which states that, as a government department, MHCLG may process personal data as necessary for our work in the public interest. 

Article 6(1)(e) - the processing is necessary for MHCLG to perform a task in the public interest or in the exercise of official authority. Section 8(d) of the DPA 2018 makes provision that this includes processing that is necessary for a function of the Crown, a Minister of the Crown or a government department. This function is funding projects aimed at supporting those individuals experiencing multiple disadvantage.

In order to rely on Article 6(1)(e), Article 6(3) requires there to be a separate legal basis laid down in UK law to justify the processing. MHCLG is relying on its common law powers to justify this processing. The Secretary of State for Housing, Communities and Local Government relies on the common law powers of the Crown as the separate legal basis for this processing.

The following is the UK GDPR lawful basis under which the Fund will process the personal data:

Article 6(1)(e) – the processing is necessary for the Fund to perform a task in the public interest or in the exercise of official authority. The Fund is a statutory corporation, created by the National Lottery etc. Act 1993; all its powers and functions are statutory and come from the National Lottery etc. Act 1993. When the Fund processes personal data in connection with applications and management of lottery grants, it is exercising official authority vested in it by the National Lottery etc. Act 1993.

4. With whom we will be sharing the data  

Your data will be shared with:

• The National Lottery Community Fund who have formed a collaboration with MHCLG for the purpose of the programme

• Social Finance and Revolving Doors Agency with whom we have contracted to provide support to areas on the programme.

• Local partnerships such has health services, probation service, VCSEs and similar organisations to encourage collaboration and develop partnerships.

• Other Area contacts on the programme to facilitate area to area learning. 

• Areas outside the programme to share learning from the programme and provide a national network.

5. For how long we will keep the personal data, or criteria used to determine the retention period.  

Your personal data will be held for the duration of the Changing Futures programme and for an additional 6 years by MHCLG once it has completed. Social Finance and Sub-Contractor Revolving Doors Agency will erase all personal data once their contract ends.

6. Your rights, e.g. access, rectification, erasure   

The data we are collecting is your personal data, and you have rights that affect what happens to it. You have the right to: 

a. know that we are using your personal data 

b. see what data we have about you 

c. ask to have your data corrected, and to ask how we check the information we hold is accurate 

d. ask to have your data deleted 

e. complain to the ICO (see below) 

In some circumstances you may also have the right to withdraw your consent to us having or using your data, to have all data about you deleted, or to object to particular types of use of your data. We will tell you when these rights apply. 

7. Sending data overseas 

Your personal data will not be sent overseas.  

8. Automated decision making 

We will not use your data for any automated decision making.  

9. Storage, security and data management 

Your personal data will be stored in a secure government IT system and will be stored in industry-recognised secure data storage by The National Lottery Community Fund and Social Finance.

The National Lottery Community Fund and MHCLG are committed to taking all reasonable and appropriate steps to protect the personal information we collect from you from improper use or disclosure, unauthorised access, unauthorised modification, and unlawful destruction or accidental loss. We have taken and will take appropriate information security, technical, storage and organisational measures to such end, including measures to deal with any suspected data breach.

Social Finance and their sub-contractors are contractually required to process Personal Data in compliance with its obligations under the Data Protection Legislation, to the same standard of security considerations as described above, and your personal data will be stored in industry-recognised secure data storage.

10. Complaints and more information 

When we ask you for information, we will keep to the law, including the Data Protection Act 2018 and UK General Data Protection Regulation. 

If you are unhappy with the way the department has acted, you can make a complaint. 

If you are not happy with how we are using your personal data, you should first contact [email protected]. 

If you are still not happy, or for independent advice about data protection, privacy and data sharing, you can contact: 

The Information Commissioner's Office  
Wycliffe House  
Water Lane  
Wilmslow, Cheshire,  
SK9 5AF  

  Telephone: 0303 123 1113 or 01625 545 745   https://ico.org.uk/