StreetLink London

StreetLink London privacy policy

StreetLink London is a self-referral phone line, for people who are currently rough sleeping in London.

We connect people who are rough sleeping with the local outreach team and can signpost the caller to local organisations, such as local housing options, where they can make a homeless application.

Below is information around what data we collect and how it is used.

Your rights

St Mungo’s recognises your rights to data including the following:

- The Right of Access to personal data – You are able to request all personal information which St Mungo’s holds on you. This will include what personal information we hold, why we hold it and if we are sharing it. You can do this by contacting your service manager, or contact our Information Security team directly using the details below.
- The Right to be Informed – St Mungo’s will help you understand any complex terms or codes on your record by providing explanations where needed. We would encourage you to ask questions to help you understand your record including why we hold types of personal information and what we use it for. We will also let you know if we do not hold some personal information you have requested.
- The Right to Rectification – If you see any personal information on your record you believe is inaccurate you can request we amend it. St Mungo’s will need to demonstrate that we have checked the personal information and ensure accuracy is maintained to the best of our knowledge.
- The Right to Erasure, Restriction or Objection – You can ask St Mungo’s to remove personal information, stop using some of your personal information for a certain purpose or to limit the way that we use your personal information. We will consider your request against the purpose and legal basis for holding your personal data. There may be some cases where we cannot remove or limit our use of your personal data, or where erasing it would prevent us being able to continue working with you. In these cases we will explain the reasons clearly and advise you on the options available to you.

Being clear about you and your personal information at StreetLink London

We collect personal and sensitive personal information from you to ensure we are able to provide you with the most appropriate and tailored support.

What is collected will vary between services and projects so you may have some personal information which is used for different reasons. This document will explain those reasons, and should answer any other questions.

If you have any questions about how your personal information is used you can ask your service manager, lead worker or contact Information Security at St Mungo’s using the details below. We will be more than happy to help and answer any questions you may have.

Your personal information

We ask you for your Name, Date of Birth, immigration situation and economic status

This information is collected to confirm your identity and better understand which services and benefits you are able to access. We also use this to ensure we are delivering a fair and inclusive service.

We also collect more general information about you to better understand the sort of support you might need. This could include whether you’re a parent, your education history, and boroughs or cities you have a local connection with.

We use this extra information to help us provide targeted support to you around the areas which are most important to you in fulfilling your hopes and ambitions.

Your sensitive personal information

Racial or Ethnic origin and Religious or philosophical beliefs – Recorded to assess your entitlements and eligibility to specialised support services, benefits and public funds. This information will never be used to discriminate against you. It may also be used for reporting on our services, but this would be done anonymously.

Mental and physical health diagnoses and well-being – We initially receive this information in referrals. This is used to assess accommodation and plan appropriate support before your arrival. This could involve contacting and sharing information with relevant agencies already working with you. We will also do this if we believe there may be undiagnosed conditions.

Details of drug and alcohol use, support and any related incidents – This information is used to understand whether or not there are any support needs we should be aware of to provide the right support and to keep you and others safe. It is also used to assess any patterns of behaviour to help provide better support.

If you are a victim or have support needs around domestic abuse – We record this information to make sure we can support any needs you may have.

Sexual behaviour and orientation – This information is used particularly to provide harm minimisation and support.

Information about offending history and behaviour – We may receive information from the criminal justice system or from the police. Only the relevant risk information will be stored. These checks are done to keep everyone safe including yourself, other clients and staff. This information will not be used to discriminate against you, and we will never share these details externally without your clear and explicit consent, unless required by law.

We collect this personal and sensitive information for five main reasons:

1. To identify any specific support or services you might be eligible for
2. To ensure we are providing you with a fair and inclusive service
3. To manage any risk to yourself, other clients, staff, the public and the environment appropriately
4. To evidence that we are delivering on our contracts with those who commission and fund our projects and services
5. To assess our own performance and provisions of services so that we can continuously improve

Where we are using the last two reasons, where possible we will take all reasonable measures to make sure that we minimise your personal information so that the information cannot be linked back to you.

In exceptional circumstances, for example, if we have safeguarding concerns, we may also have to use your information to effectively manage any risks to vulnerable adults and/or children.

What are our legal reasons for processing your information?

Generally StreetLink London will not rely on your consent to collect your personal information, including sensitive categories. This is because there is certain information we need to process so that you can engage with StreetLink London.

We process information under five legal bases:

(Substantial) Public interest

We collect the majority of your personal and sensitive personal information under the legal basis of (Substantial) Public Interest. This is where doing so is necessary for us to perform a task in the public interest. We will only use this information for the purposes as stated above. If you have concerns about your data, we promise to listen and support you around these.

Legitimate interest

This is where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests). For example, this may include your parental or grandparental status, details about previous accommodation, and your phone number. If you are not happy for us to store this information, we are able to remove it at any time.

Vital interests

Sometimes we need to process information to protect Vital Interests. This means we may have to share, collect or otherwise use your information to protect the life of yourself or others.

Legal obligation

Where there is a Legal Obligation. Sometimes we may need to store and share information where St Mungo’s has a legal obligation to do so; for example, we may need to store information to comply with health and safety legislation.

Consent

Generally we will not rely on consent to process your personal information, however sometimes we may need to. Where this is the case and we will capture your genuine and meaningful consent. This means when we ask if you are happy for us to process your information we will only do so in a way which you agree to and will fully inform you about what you are consenting to. If we need to obtain your consent to use your personal information for a specific purpose and you do not consent, we will not use, share or process your information for that purpose. You can also withdraw any consent that you have given, at any time.

Sharing your information

We have to share information between ourselves and other agencies to provide combined support. There are some agencies which we work more closely with, below is a list of these agencies, grouped according to why we would share your information.

Physical and mental health services

Your current and/or past GPs / doctors
Your Community Mental Health Team and other mental health professionals
Hospitals, health centres, local response teams and pharmacies

Council statutory agencies

Previous or prospective housing authorities or providers
Local Authorities of boroughs you have lived in
Department of Work and Pensions (DWP) – for proof of benefits, or benefit teams
National Records Office or Embassy to obtain ID
Council Commissioning teams

Support agencies

Advice agencies for example housing and welfare advice providers; drug and alcohol support services
Your social workers
Support agencies e.g. Domestic Abuse support agencies, LGBTQ+ support services network and such other agency as St Mungo’s considers necessary to protect my vital interests or those of another natural (living) person

Offender services

Your current and/or past probation or other criminal justice professionals

Immigration advisors

Immigration providers who are able to support you.

To confirm, it is St Mungo’s policy that we do not share any information about our clients with the Home Office without the client’s full and informed consent unless we are legally obliged to do so.

Sharing your information outside of the United Kingdom is not covered by this privacy notice. We will only do this with your signed consent if it is necessary to identify and facilitate a sustainable route into accommodation.

How do we keep your personal data secure?

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How long will we keep your data?

We will keep your personal, including sensitive, data for a period of three years, after you have left the service. Your personal data will then be minimised and only the following information will be kept:

Your name and date of birth to identify you should you re-engage with a St Mungo’s service in the future.
A list of the services you engaged with including dates of entry and exit, again this would be able to help us better support you should you re-engage.

In some exceptional cases we may have to keep additional information. This will only be done if there were any significant risks to yourself, other clients, staff, the public and the environment which we’d need a record of, should you re-engage. This information will only be kept for a maximum of seven years after you have left the service.

Queries and complaints

Information Security Team

Data Protection Officer InfoSec@mungos.org

Tel: 020 3856 6121

Write: Information Security, St Mungo’s, 3 Thomas More Square, Tower Hill, London, E1W 1YW

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Complaints

complaints@mungos.org

Tel: 020 3856 6068

Write: Quality team, St Mungo’s, 3 Thomas More Square, Tower Hill, London E1W 1YW.

Please note – we are unable to see personal callers at this address

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If you are not happy with the response you receive from St Mungo’s, you can contact the UK representative for data protection.

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The Information Commissioner’s Office

www.ico.org.uk

0303 123 1113

StreetLink London

StreetLink London