Changing Futures Privacy Notice
What this privacy notice is for
Our core data protection obligations and commitments are set out in the Council’s primary privacy notice at www.oldham.gov.uk/dataprotection
This notice provides additional privacy information for:
- The Changing Futures Programme
Changing Futures is a 3-year, £64 million programme established by the Department for Levelling Up, Housing and Communities (DLUHC) which aims to improve outcomes for adults experiencing multiple disadvantages, including combinations of homelessness, substance misuse, mental health issues, domestic abuse and contact with the criminal justice system.
The intention for this programme is for the Changing Futures Team at Oldham Council to work together with local partners to facilitate the reform of how services are delivered to improve outcomes for this particular group of beneficiaries.
Updating our privacy notices
We may update or revise our privacy notices at any time so please refer to the version published on our website for the most up to date details.
What we use your information for
We obtain your personal information for the following reason(s):
- To provide you with help to improve your life situation and help inform future work to support people facing multiple disadvantage
- To check how Changing Futures is doing, and whether they are having a positive impact
- To generate statistics about who engages with Changing Futures. This helps to make decisions such as where to use resources to ensure the service reaches the people who need it and are as effective as possible. When generating statistics all data is anonymised and aggregated
- To test a different approach to funding, responsibility and joint working between local services and between central government and local areas
- To support and contribute to national research undertaken by the Department for Levelling Up, Homes and Communities.
National Research
At a national level the Department for Levelling Up, Homes and Communities (DLUHC) is undertaking research to evaluate whether Changing Futures is making a difference to individuals experiencing multiple disadvantage.
The personal data will be used to establish baseline information on participant’s joining the programme and to track the progress of participants against outcomes. In addition, some information such as name, address, date of birth will also be linked with personal information held by national government departments relating to benefits, health and health care use, and any contact with the criminal justice system.
Your name will be removed before any information is shared and the researchers looking at the information will not know whose information it is. You will not be identified in any research reports.
Personal information linked for research purposes at national level will:
- be anonymised after it has been linked so individuals cannot be identified
- be kept securely to prevent any unauthorised use
- not be used for making decisions about individuals
If you do not wish to take part please let your Changing Futures Support Worker know, this will be noted and your personal information will not be shared with DLUHC.
In addition, if at any point you would like to withdraw agreement after your personal information has been shared, please inform your Support Worker and this will be communicated to DLUHC via Oldham Council. DLUHC will ensure all personal data is deleted by government departments/ agencies where relevant.
What categories of personal information we use
Personal information can be anything that identifies and relates to a living person. This can include information that when linked with other information, allows a person to be uniquely identified. For example, this could be your name and contact details.
The law treats some types of personal information as ‘special’ because the information requires more protection due to its sensitivity. For example, this could be around your physical or mental health or criminal convictions and offences.
In order to provide you with help and support for your particular needs, Changing Futures collects the following information:
Data collected by Changing Futures |
Is this special or sensitive data? |
Is this required for anonymised Government returns? |
Name (First Name, Surname, Alias) |
No |
No |
DOB/Age |
No |
Yes (age) |
NHS Number |
No |
No |
Address |
No |
No |
Registered GP |
No |
No |
Referral source |
No |
No |
Current support provision from other agencies |
Yes |
Yes |
Nationality |
Yes |
Yes |
Ethnicity |
Yes |
Yes |
Religion |
Yes |
Yes |
Sexual orientation |
Yes |
Yes |
Described gender |
Yes |
Yes |
Gender assigned at birth |
Yes |
Yes |
Number of children |
No |
No |
Multiple disadvantage characteristic being experienced |
Yes |
Yes |
Relevant issues |
Yes |
Yes |
Reason for referral |
Yes |
Yes |
Any known risks (to self or others) |
Yes |
Yes |
Types of services accessed/accessing including dental and GP |
Yes |
Yes |
Employment status or receiving benefits |
Yes |
Yes |
Legal basis for processing
The legal basis for processing and or sharing your personal information between the partner organisations and Oldham Council’s Changing Futures Team for the purposes of enhanced support provision and direct care is
- Article 6(1)(d) of the UK General Data Protection Regulations (UKGDPR) allows us to process your data for the purposes of protecting an individual’s vital interests
- Article 6(1)(e) of the UKGDPR allows us to process your data for the purposes of a task carried out in the public interest
- Article 9(2)(g) of the UKGDPR allows us to process your special category data for the purposes of significant public interest in accordance with the following requirements under the Data Protection Act 2018 (DPA 2018)
- Schedule 1, Part 2(6) - Statutory and government purposes
- Article 9(2)(h) of the UKGDPR allows us to process your special category data for the purposes of health and social care in accordance with the following requirements under the DPA 2018
- Schedule 1, Part 1(2) - Health and Social Care
- Schedule 1, Part 2(6) of the DPA 2018 allows us to process special category and conviction data for statutory purposes to process Special Category Personal Data in accordance with Section 10(3) of the DPA 2018
- Under the UK GDPR, the lawful bases DLUHC will rely on for using your information is that they need to perform a public task.
We will also act as a Data Processor on behalf of DLUHC to provide baseline and continuing evaluation data directly to the researchers appointed by DLUHC.
DLUHC, as an emanation of the Crown, has ordinary common law powers to do whatever a natural person may do (subject to overarching legal constraints), in contrast with bodies which have powers conferred on them by statute and no powers under the common law and can share and process data for the purposes of research so long as that sharing is not otherwise prohibited by law and is in compliance with the Data Protection Legislation, Human Rights Act 1998 and the common law duty of confidentiality.
DLUHC will rely on the following legal bases to process the personal data provided by the programme and individuals themselves:
- Article 6(1)(e) of the UK GDPR - the processing is necessary for DLUHC to perform a task in the public interest or in the exercise of official authority, in particular to support households that are homeless or at risk of being homeless through furthering our understanding of repeat homelessness, the success of prevention activities, the outcomes of those in receipt of homelessness services, and the causes and factors associated with homelessness. In order to rely on Article 6(1)(e), Article 6(3) requires there to be a separate legal basis laid down in law to justify the processing. DLUHC is relying on its common law powers to justify this processing.
- Article 9(2)(g) of the UK GDPR – the processing is necessary for reasons of substantial public interest. DLUHC will rely on meeting the condition in Schedule 1, Part 2(6) of the DPA 2018 – statutory and government purposes to process Special Category Personal Data in accordance with Section 10(3) of the DPA 2018.
The conditions in Article 10 of the UK GDPR and section 10(5) of the DPA 2018 will also be met to process criminal offence data since processing is authorised under Section 10(5) and Schedule 1, Part 2(6) of the DPA 2018 – statutory and government purposes.
Information sharing/recipients
We may share personal information about you with the following organisations:
- Department for Levelling Up, Housing and Communities (DLUHC) – for the purposes of research and evaluation.
- Services providing support to you
- Health care providers providing support to you
- Other services or organisations who are directly involved in providing a service to you as part of delivering the Changing Futures programme
As well as information collected directly from you, we also obtain or receive information from:
- Greater Manchester Police
- NHS Greater Manchester Integrated Care
- National Probation Service
- Action Together
- Pennine Care NHS Foundation Trust
- Northern Care Alliance NHS Group
- Public Health
- Housing providers
- Greater Manchester Fire and Rescue Service
- North West Ambulance Service
- Voluntary sector providers
- Statutory and voluntary services directly commissioned by the lead MEAM Partners such as GPs, Rochdale and Oldham Turning Point, Jigsaw Housing, Age UK Oldham, Positive Steps, Action Together & POPS
Data Transfers beyond European Economic Area
We do not transfer any of your personal information outside the UK.
Automated Decisions
All the decisions we make about you involve human intervention.
How long we keep your data
We will only keep your personal information for as long as the law specifies or where the law does not specify this, for the length of time determined by our business requirements.
We will retain this information for the duration of the research programme plus two years.
Where can I get advice?
More information on how to seek advice in order to exercise your rights, raise a concern or complain about the handling of your personal information by the council can be found in the council’s privacy notice which can be found at www.oldham.gov.uk/dataprotection