Guidance

Homelessness and rough sleeping: Accommodate or Connect: privacy notice

Published 21 November 2024

Applies to England

This privacy notice explains who we are, the personal data we collect, how we use, store and delete it, the legal basis for using personal data and what your legal rights are in relation to this research.

1. The data controller

The Ministry of Housing, Communities and Local Government (MHCLG) is the “data controller”. This means that we at MHCLG are responsible for determining what personal information we collect about you and use, why and how (the ‘purpose and manner’).

2. What personal data we are collecting and why

When we ask for your personal information, we promise only to ask for what we need and to make sure you know why we need it. If this includes contact details, we will tell you if we intend to use these details to contact you about anything else, and whether it is possible for you to opt out of this. If you agree to us contacting you about other things, you can withdraw your agreement at any time.

We have commissioned the Centre for Homelessness Impact (CHI) to lead a consortium (a group of organisations) to establish the effectiveness of 8 projects testing different approaches to tackling homelessness and rough sleeping (known as the Test & Learn programme).

One of these 8 projects is Accommodate or Connect (‘AorC’), which is covered by this privacy notice. AorC involves offering people short-term accommodation in an area and/or a supported, voluntary reconnection to an area where an individual has a local connection, or an area where they could obtain settled accommodation. For more information, read about Accommodate or Connect. For this project, King’s College London (KCL) is the evaluator (part of the CHI consortium).

The aim of the study is to explore whether AorC shows promise in reducing homelessness and rough sleeping, and the cost of the intervention for local authorities. If you allow us to use your personal data, you will be helping us to explore whether AorC is effective in reducing homelessness and rough sleeping.

Whose data we are collecting

As part of this project, we will be collecting information from:

• individuals who are or have been rough sleeping in a local authority where they do not have a local connection
• staff delivering services or making referrals to these services
• staff in local authorities that neighbour the local authorities that are delivering AorC
• staff in receiving local authorities where people are (re)connected as part of AorC
• staff bidding to take part in projects via Flexigrant

3. Why we are legally allowed to process your data

How we are using your data

The reasons that we can use to collect or use your personal information are set out in law. Most of the time, the lawful basis for us processing your personal information under data protection legislation will be because it is necessary for our work as a public body (the processing is necessary for the performance of a task in the public interest – (Article 6(1)(e) of the UK General Data Protection Regulation (UK GDPR))). Where we process data about criminal convictions, our additional legal basis for processing it is paragraph 6 of Schedule 1 of the Data Protection Act 2018.

For AorC, sensitive personal data known as ‘special category data’ will be processed (detailed below). Where we process special category data, our legal basis for processing it is Article 9(2)(g) of the UK GDPR, that processing is necessary for reasons of substantial public interest.

For any interviews or focus groups that take place during the course of this research, audio recordings may be used, which may contain personal data.

For individuals who are or have been rough sleeping in a local authority where they do not have a local connection

The data collected for this research will be routinely collected by the local authority or third sector organisation who are working with you to deliver the AorC service. They will then share this data with KCL, who are the evaluators for this project. All personal data shared between members of the CHI-led consortium will be shared via secure electronic systems.

The local authority or third sector organisation will provide the information to KCL without sharing any of your personal identifiers (such as names or contact details) so KCL will not know who the information is about. However, it may still be possible to identify you in the data based on putting certain pieces of information together. KCL will work with the local authorities and third sector organisations to reduce the risk of this happening. All reports and outputs from the research will be anonymous and it will never be possible to identify you in any outputs.   

The following personal data will be processed as part of the AorC research:

Background data (this will be routinely collected by the local authority or third sector organisation you are working with as part of AorC and shared with KCL. This background data may include special category data, such as ethnicity, sexuality and disability.) Examples of the background data (some of which is special category data) that will be collected are:

• age in years
• ethnicity  
• nationality  
• sexuality  
• gender 
• disability 
• mental health, employment, financial security and social connections           
• previous experiences of homelessness or housing insecurity 
• length of time rough sleeping in local authority that is participating in AorC
• local authority where there is a local connection

These data are needed for a number of reasons. Factors like mental health are risk factors in making a person more susceptible to homelessness/rough sleeping, and/or can influence the likely success or failure of interventions. For demographic factors such as age and ethnicity it is important to know whether interventions are more or less successful for different groups (particularly useful to breakdown results by protected characteristics under the Equality Act 2010). 

Service use data (this will be routinely collected by the local authority or third sector organisation you are working with as part of AorC and shared with KCL.) Examples of the service use data that will be collected are:

• the length of time you work with an AorC caseworker
• whether you receive accommodation as part of AorC, what type, and for how long
• other types of support you receive as part of AorC
• referrals to other services as part of AorC
• other types of support the local authority provides for you or refers you to outside of AorC (e.g. job centre, substance use support)
• the reason that your work with AorC ended

Outcome data (this will be routinely collected or will be collected via an anonymous survey by the local authority or third sector organisation you are working with as part of AorC and shared with KCL.) This will be collected in order to understand whether AorC has promise, for example:

• housing and homelessness (measured through administrative data and survey data)
• mental health and wellbeing (measured through survey data)
• employment and income (measured through survey data)
• social connections (measured through administrative data)

While survey and administrative data will be shared with background data in order to understand whether different groups have different experiences with the intervention, all of this data will be shared anonymously and without any personal identifiers.

Personal identifiers will be collected from local authorities or third sector organisations in some instances for the purposes of contacting you for qualitative interviews. They will not be linked to any of the other data that will be shared with KCL. When possible, local authorities or third sector organisations will invite people directly rather than sharing their contact details with KCL. The personal identifiers may include

• names
• contact details (e.g. telephone number, email address)

For staff delivering services or making referrals to services, staff in local authorities that neighbour the local authorities that are delivering AorC, and staff in receiving local authorities where people are (re)connected as part of AorC

Your personal details (name and contact details) will be shared by the relevant local authority or third sector organisations with KCL for the purpose of arranging interviews or focus groups. When possible, local authority or third sector organisations will invite staff directly rather than sharing their contact details with KCL.

Personal identifiers (provided by local authorities or third sector organisations), for example:

• names
• contact details (e.g. telephone number, email address)

All personal data shared between members of the CHI-led consortium will be shared via secure electronic systems. All findings will be anonymised in any disseminated/ published reports.

For staff bidding to take part in projects

For the Test & Learn programme, personal details (name and contact details) will be collected to process, score and oversee applications and grants to take part in specific projects. These will be managed by CHI through Flexigrant.

Personal identifiers

• names
• contact details (e.g. telephone number, email address)

4. Sharing your data

Personal data for participants taking part in research activities collected during this study will not be shared with any other body outside the members of the CHI-led consortium or MHCLG, the data controller.

Personal data (name and contact details) for professionals (local authority, third sector organisation and evaluators) interested in taking part in projects, for example, submitting an application through Flexigrant, may be shared with third parties for the purpose of scoring. 

5. Keeping your data

We will only keep data as long as we continue to have a lawful basis to do so. This will usually mean that it is still necessary for our work as a public body. This will be decided by our ongoing business need and any laws or government policies that affect how long we keep it. We have a ‘retention schedule’ that sets out how long we will keep personal data:

• CHI and consortium members will securely keep your personal data for up to 3 months after the completion of the Test & Learn evaluation.

You may ask to withdraw from the study by getting in touch with MHCLG or KCL using the contact details in section 11 of this privacy notice.

6. Your rights

The data we are collecting is your personal data, and you have rights that affect what happens to it. Generally, you have the right to:

(a) know that we are using your personal data;

(b) see what data we have about you;

(c) ask to have your data corrected, and to ask how we check the information we hold is accurate;

(d) ask to have your data deleted where the processing is no longer necessary for the purposes stated in this privacy notice;

(e) object to the processing of your personal data; and

(f) complain to the Information Commissioner’s Office (see below).

7. Sending data overseas

We will not usually send your data overseas. If for some reason we do, such as storing data on computer servers that are not in the UK, we will ensure that all necessary safeguards are in place.

8. Automated decision making

We will not use your data for any automated decision making.

9. Storage, security and data management

Your personal data will be stored securely and will be protected to make sure nobody has access to it who shouldn’t.

You can ask us for details of our instructions to staff on how to collect, use and delete your personal data.

10. What we ask of you

So that we can keep your personal information reliable and up to date, please:

• give us accurate information
• tell us as soon as possible if there are any changes, such as a new address or contact details.

11. Complaints and more information

When we ask you for information, we will keep to the law, including the UK General Data Protection Regulation, the Data Protection Act 2018 and any new legislation coming into force.

If you are unhappy with the way the department has acted, you can make a complaint.

If you are not happy with how we are using your personal information, you can get in touch with us: dataprotection@communities.gov.uk. If you have other queries, you may contact edit@kcl.ac.uk.

If you are still not happy, or for independent advice about data protection, privacy and data sharing, you can contact:

The Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 030 3123 1113

Website: https://ico.org.uk/