Privacy Policy

Privacy / Data Protection Policy

Fair Processing-Rainbow Home (North East England)

The processing of personal data is essential to many of our services and functions and this processing will often involve sensitive personal data. Compliance with the Data Protection Act 2018 will ensure that this processing is carried out fairly and lawfully.

Both the Data Protection Act and Article 8 of the Human Rights Act stress that the processing of personal data needs to strike a balance between, on the one hand, the needs of the organisation to function effectively and efficiently and, on the other, respect for the rights and freedoms of the individual. This policy sets out how we will ensure that those rights and freedoms will be protected.


This policy applies to all personal data that we process.

or the Act, personal data held in manual files as well as on computer databases all counts.

Key Definitions

Personal data means data about a living individual who can be identified from those data (or from those and other information either in our possession, or likely to come into our possession). This can include not only personal details, details of family and social circumstances, education, employment, business and financial details, but also goods or services received, expressions of opinion or intentions, and images such as those recorded on CCTV.

This includes all the obvious details the council might hold about you like name, address, date of birth, NHS number, Council tax reference number, rent payment records, details of family and social circumstances, education, employment, business and financial details, but also goods or services received, expressions of opinion or intentions, and images such as those recorded on CCTV. Some data can be personal even if it refers to more than one individual, like joint tenancies, Council Tax assessment records, etc.

The act recognises that some types of personal data are more sensitive than others. There are extra rules for processing data about your ethnic origin, religious beliefs, trade union memberships, party political opinions, sexuality, health, involvement in court proceedings, etc.

Data controller means the organisation that determines how data is processed. Rainbow Home (North East England) NEE is the data controller for personal data that it processes. We are legally required to comply with the Data Protection Principles.

Processing of personal data is defined very widely in the Data Protection Act. It covers all actions and processes involved in obtaining, recording, holding, carrying out any set of operations on, storing or destroying personal data.

Processing personal data includes collecting, storing, accessing, changing and destroying any information about you. The amount of personal data we have about you and how we process it depends on where you are in the asylum process and your needs at any time within that process.

Data subject is any living individual who is the subject of personal data.

The policy

  • We will comply with all requirements of the Data Protection Act 2018.
  • We will aim to follow best practice in all purposes for which we are processing their personal data and will seek their consent where appropriate and necessary. Where we use data for another purpose, we will inform people of this.
  • We will hold the minimum personal data necessary to carry out our functions, and we will make every effort to ensure accuracy of the data. Where we record opinions or intentions, these will be carefully and professionally expressed. Data which is no longer required will be securely destroyed in accordance with relevant retention and disposal schedules.
  • An appropriate level of technical and organisational measures/we will ensure that are in place to ensure the security of the personal data.
  • We will only use personal data for the direct promotion or marketing of goods and services with the consent of the data subject.
  • When appropriate, we will carry out data sharing with external agencies as specified and agreed by you (in writing) e.g. solicitor, other Ass/Refugee Service.
  • We will only use non-person identifiable information to inform funders of our activity, or to apply for funding.

If you have any questions about your rights under the Data Protection Act 2018 or want to make a subject access request-you can also get information leaflets from the Information Commissioner’s web site at: or by telephone on 01625 545745

You have the right to request that Rainbow Home NEE stop processing your personal data in relation to your service. However, this may cause delays or prevent us delivering a service to you.


Rainbow Home NEE Board of Trustees

Freedom of Information and Data Protection Officer

  • Develop and maintain the corporate data protection policy and procedures
  • Provide advice and guidance on the data protection policy and procedures
  • Provide training in data protection issues
  • Co-ordinate subject access requests in conjunction with directorate/coordinators
  • Monitor and review the effectiveness of the policy and procedures
  • Identify and communicate any data protection issues to directorates
  • Report on compliance with the policy and procedures to the Management Team


FOI and data protection co-ordinators

  • Promote the policy and procedures within their directorate
  • Be aware of the requirements of the Data Protection Act and how they might impact on work within their directorate
  • Ensure that subject access requests are handled effectively by logging and coordinating requests

All employees

  • Be aware of the Data Protection Act and what it means to Rainbow Homes NEE
  • Follow the policy and procedures for handling personal data
  • There is a separate policy relating to data held for employees and another one for Job Applicants

Monitoring and review

Compliance with this policy and related procedures will be monitored by the Trustees of Rainbow Homes NEE

Any deliberate breach of this policy or the Data Protection Act will be misconduct and may be subject to action under the disciplinary procedure.

This policy will be reviewed by the Trustees of Rainbow Homes NEE on an annual basis