Home Fire Safety Assessments Privacy Notice
A Home Fire Safety Assessment (HFSA) is a home visit, or telephone call, delivered by the Greater Manchester Fire and Rescue Service (GMFRS) to assess and reduce the risk of fires in the home. To generate, schedule and deliver HFSAs we collect, store and process personal data. This Privacy Notice provides information about the personal data we collect, how we handle it and what we use it for.
The Data Controller for all personal data collected during this process is the Greater Manchester Combined Authority (GMCA)(ICO Registration No.: ZA347594). The GMCA is a Public Authority with a number of legal responsibilities to provide services to members of the public, including the Fire Service.
Sources of information
Referrals for a Home Fire Safety Assessment can be made online, via the Home Fire Safety Check, or by contacting the GMFRS Contact Centre. During the referral process we collect some basic information about your household and its occupants, to assess the risk of fire in the home. If we think you would benefit from a Home Fire Safety Assessment, we then collect contact details to arrange a telephone call or home visit.
As well as collecting information directly from you (‘self-referral’), we also receive referrals from friends, family members and partner agencies (such as Local Authorities, housing providers and NHS Trusts) where they have concerns about the risk of fire in your home. In all cases we advise that referrals should only be made with the agreement of the individual being referred.
During a Home Fire Safety Assessment we collect further information relating to the risk of fire in the home and record details of any advice or interventions offered.
To help us proactively identify households in Greater Manchester who may benefit from a Home Fire Safety Assessment, we collect and analyse demographic and geographical from various sources, including NHS England, Experian and ONS. By comparing this data to historic incidents, we identify households who are potentially at heightened risk of fire in the home. Where a large number of these households are close together, we promote Home Fire Safety Assessments in that area.
Types of information we process
The types of personal information we collect and process to deliver this service are listed below.
- Date of birth
- Contact details
- Number of occupants
- Age of other occupants (banded)
- Lifestyle and social circumstances
- Employment Status
- Property details
- Referrer name, role and organisation
- Referrer contact details
Special Category Data
- Physical health conditions
- Mental health conditions
- General health and wellbeing
What we do with your information
We use your personal information to:
- Communicate with you to arrange an assessment.
- Assess your risk of fire and your ability to evacuate the building, should that be required.
- Provide you with fire safety advice or equipment appropriate to your needs.
- Ensure we are delivering our prevention activities effectively in all of our communities.
- Make referrals to partner organisations. Some of these referrals we have a legal obligation to share information, usually to protect the health and wellbeing of yourself or another person. For any others we will ask for your permission before sharing any of your data, this is detailed further below.
We will only process personal information for the purposes it has been collected or subsequently authorised.
We also share information with our governing bodies and trusted partners to improve the effectiveness and efficiency of this process and other fire prevention activities. This information is anonymous, meaning that you cannot be identified.
Who we share your information with
The partner organisations we may make referrals to or share anonymised data with include:
- Greater Manchester Police
- Local Authorities (Social Care, Safeguarding, Homelessness)
- Housing Providers
- NHS (Hospitals, GPs, Health and Care Services)
- Other Private and 3rd Sector Health and Care Services
- Youth Offending Teams
Unless we have a legal obligation to do so, we will not share any information that can identify you without your permission. We will always tell you the name of the organisation, agency and/or service before sharing.
Data will only be shared with these partners to further improve your fire safety or to support you to improve your health, wellbeing or quality of life. We know that issues such as smoking, drug or alcohol use, memory impairment, mobility and mental health all impact on fire risk and on your ability to escape safely in the event of a fire, therefore we may direct you to services that can help you to address or manage these issues. We will give you the details so you can contact them yourselves or, with your consent, we can make a referral to the relevant service for you.
In some circumstances, we are allowed to share data without your consent, if there is another lawful basis for sharing it. For example:
- Protecting the vital interests of the data subject (the person the data relates to). For example, sharing medical data in an emergency.
- To safeguard somebody who is at risk of abuse or neglect or to prevent them from signification harm.
- For the purposes of preventing or detecting crime.
Lawful Basis for processing
As a public authority, in order to process any personal data we must have a valid lawful basis under Article 6 of the UK General Data Protection Regulation (UK GDPR). To process personal data throughout the HFSA process we rely on the following lawful bases:
- Article 6(1)(c) - Legal Obligation
The processing is necessary for compliance with a legal obligation to which we are subject. Namely, Section 6 (Fire Safety) of the Fire and Rescue Services Act 2004. Our processing is also underpinned by Sections 5A (Powers of Fire Authorities) and 21 (National framework) of the Act.
- Article 6(1)(d) - Vital Interests
In some specific circumstances, processing is necessary to protect someone’s life.
To process special category data (such as data relating to health or ethnicity) we must also have a separate condition for processing under Article 9 of the UK GDPR. These are:
- Article 9(2)(g) - Substantial Public Interest
We believe it is in the substantial public interest to prevent fires and save lives based on information about individual needs and circumstances.
- Article 9(2)(c) - Vital Interests (for special category data)
The processing is necessary to protect someone’s life.
How we ensure the security of your data
The GMCA is committed to providing the appropriate levels of security to the information we collect and we use reasonable measures to prevent unauthorised access to that information. We are required to demonstrate that our solutions meet the required levels of personal, procedural, policy, data and technical security. These include:
- All staff receive specific information security training.
- All staff comply with Information Security policies and procedures which set out how your information is protected and what happens if the security of the information is breached.
- All the laptops used by staff are encrypted and require a unique ID and password to access the computer systems.
- Staff only have access to the information they need to do their job. This means if they are not the right person in the right team, they will not be able to see your information.
- Staff with access to the most sensitive information may need to have a Disclosure and Barring Service (DBS) check.
How long do we keep your information for?
We are committed to managing information in line with the needs of our organisation, our partner organisations, UK Government best practice and any legal obligations. We keep the information collected during the referral process, Home Fire Safety Assessment and any subsequent interaction for seven years (from the date of the most recent update to your assessment). After this time your information will be securely deleted from our systems.
What are my rights of access to my information?
The GDPR gives you the following rights over your information:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling
If you would like to exercise any of these rights, or have any questions about how we process your personal information, you can contact us at: OfficeOfDPO@greatermanchester-ca.gov.uk
Please be aware that these rights are not absolute and are subject to conditions and exemptions. In some cases the rights described above only apply if the processing activity is undertaken on specific legal grounds and/or in defined circumstances.
For more information on the GDPR and your rights please visit the Information Commissioner’s Office website (opens in a new tab).
How can I make a complaint?
If you are not satisfied with how the GMCA is using the information we hold about you, please contact our Data Protection Officer at: OfficeOfDPO@greatermanchester-ca.gov.uk
If you are still not satisfied with the GMCA’s response to any request to exercise your individual rights or if you believe that the GMCA is not processing your personal data in accordance with the law, you can contact the Information Commissioners’ Office:
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone: 0303 123 1113