Homelessness Services Privacy Notice

1.0 The Personal Data involved

There are laws to protect personal information about you.  These are the General Data Protection Regulations (GDPR) and the Data Protection Acts. Staff who have personal information about you have to keep it private and protect it for you. Personal data is information about someone who is alive.  This might include any of the details on your homeless action team assessment form, such as your:

• Name  
• Date of Birth
• Health conditions
• PPSN
• Previous addresses 

It can also include:

• Information about you and your family if they too are accessing homeless services.
• Services you need to help you
• Health information and treatments you receive or need
• Previous addresses

2.0 Why we collect personal information about you and who are the recipients of it.

The staff in homeless services department in the Council and all staff in the services that you are accessing must let you know why they are using information about you. This privacy notice tells you the details. 

Clare County Council’s homelessness services department needs to collect information about you because you wish to access services. The purpose of obtaining your personal information is to provide you with support, help, advice and assistance. We need to know who has helped you in the past in order to offer assistance to you now. Staff involved in providing services to you must follow the law about how to protect and handle your information. The controller within Clare County Council of your personal data is the Homeless Action Team, (065) 6821616, or hat@clarecoco.ie

In order to give you the best possible assistance, sometimes your personal information is shared with other services. Services involved in helping people who are homeless use a system called PASS. PASS is the emergency bed management and client support information system for people experiencing homelessness in Ireland. It is utilised by all local authorities and every service provider who receives funding to deliver homeless services for you. 

Sometimes we may have to share information about you with other organisations. This includes An Gardaí Síochána, the Health Service Executive, Dept of Employment Affairs and Social Protection and TUSLA. We also may share with Approved Housing Bodies who provide accommodation. It also includes the Irish Naturalisation and Immigration Service for the purposes of assessing eligibility and need for social housing supports, including support provided on the basis of homelessness. They must only use your personal information to assess the services you may need, or to provide those services to you. The personal information is for this purpose and nothing else. They must make sure that the information about you is correct. You have the right to amend incorrect information on your record and to seek for it to be erased. You have the right to seek to restrict processing or object to processing as well as the right to data portability.  Your information will be stored for as long as necessary. Your PASS data is stored for 2 years after the last activity on your PASS record. After that, it is purged and anonymised. This anonymised data can be used for research and statistical purposes only. 

3.0 How do we keep information about you safe and secure?

Only authorised staff have access to your information and they must keep it confidential and safe. Information about you that is stored on the PASS system is only available to those who are helping you with your services application.

4.0 How do I get a copy of my personal information?

You can request your information under the GDPR Law. An access request should be made to the data protection officer of Clare County Council on number is (065) 6846405, or dpa@clarecoco.ie.  We would verify your identity so as to ensure that your personal information is released only to you.

5.0 Legal basis for collecting and using your personal information.

GDPR Data Protection Act:

Article 6 EU GDPR

“Lawfulness of processing”

• Article 6(1) (b) – necessary to perform a contract to which the data subject is party or to take steps at their request prior to a contract;
• Article 6(1) (d) – necessary to protect the vital interests of the data subject or another person;
• Article 6(1) (e) – necessary to perform a task in the public interest or in the exercise of official authority – The Housing Act, 1988, Section 10.

 & Article 9 EU GDPR

“Processing of special categories of personal data”

• Article 9(2) (g) - necessary for reasons of substantial public interest, on the basis of 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 Housing Act, 1988, Section 10.

6.0 Further Information

If you have a complaint about how your personal information was handled you have the right to complain to the Data Protection Commission (DPC).  Contact details are as follows:

Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland.  Phone: 0761 104800. Email: info@dataprotection.ie DPC Complaint webform: Data Protection Commission 

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