Guidance

Homelessness and rough sleeping: Citadel: privacy notice

Published 11 July 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 Citadel, which is covered by this privacy notice. Citadel uses community volunteers to support people who have a history of rough sleeping and homelessness, or are at risk of homelessness, to find or sustain their tenancies. Read more about Citadel.

The aim of the study is to establish the efficacy (how well it works) and cost-effectiveness of Citadel in reducing homelessness and rough sleeping. If you allow us to use your personal data, you will be helping us to determine whether Citadel is effective in reducing homelessness and rough sleeping.

MHCLG will hold some personal data for further research, including the impacts of Citadel on other outcomes.

Whose data we are collecting

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

• individuals with previous experience or at risk of homelessness and rough sleeping (and a trusted relative/friend, if they agree to provide this)
• staff delivering services or making referrals to these services
• staff bidding to take part in projects

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 Citadel, 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 with previous experience and/or at risk of homelessness and rough sleeping (and their trusted relative/friend)

Your personal details (name and contact details) will be shared by your local authority or third sector organisation with IFF Research Ltd, the data collection partner that is part of the CHI-led consortium. IFF Research will collect some additional information and allocate participants to either receive the project intervention or be part of the control group (these are individuals who will not receive the intervention). The main thing we will use to measure the success of Citadel is the impact it has on homelessness and rough sleeping. We will also assess differences in other outcomes including housing satisfaction, wellbeing, employment and income, and social connections.

IFF Research will contact you to collect personal data relating to homelessness and factors that are related to causing homelessness (for example, mental health). IFF Research will also ask you to provide the contact details of a trusted relative/friend, who might be able to let them know if your details have changed.

IFF Research will share your personal data with the evaluator (Ipsos UK, part of the CHI-led consortium) that has been appointed to evaluate the project, and the delivery partner (Housing Justice) that will be implementing the intervention.

The following personal data will be processed as part of the Citadel trial:

Personal identifiers (provided by local authorities, third sector organisations and by you (for your trusted relative/friend)), for example:

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

These data are needed to be able to contact participants and to enable data linkage with the relevant databases.

Background data (collected directly from you in most cases, but this may include some data processed by the person assisting the data subject where the information is already known to them, or shared where the organisation already holds this data. 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 / date of birth
• ethnicity
• nationality
• sexuality
• gender
• disability
• mental health, employment, financial security and social connections
• previous experiences of homelessness or housing insecurity

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). 

Outcome data (provided directly from individuals), for example:

• housing and homelessness
• mental health and wellbeing
• employment and income
• social connections

Administrative data and data linkage

Should MHCLG choose to link data with other governmental departments in the future for the purpose of understanding the impact of the intervention over longer periods of time, this may include, but will not be limited to:

• MHCLG: Statutory homelessness applications and duties
• NHS Digital data which may include: Mental health services dataset (MHSDS), Improving Access to Psychological Therapies (IAPT) dataset and Emergency Care Dataset (ECDS), Hospital Episode Statistics (HES)
• DWP/HMRC, e.g. Single Housing Benefits Extract, Universal Credit and Jobseekers Allowance data
• Police National Computer (PNC) for cautions and convictions
• Council tax debt and other administrative data held by local authorities

MHCLG will hold some personal data (such as name, date of birth and gender – see above for full list) for further research, including data linkage to understand the effectiveness of Citadel on other outcomes.

For staff delivering services or making referrals to services

Your personal details (name and contact details) will be shared by the relevant local authority or third sector organisations with Ipsos 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 Ipsos.

We will also ask for a named contact within organisations that referred each participant, to signpost participants if there are safeguarding issues or if it is not possible to contact them for data collection.

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, or other government departments who may provide additional personal administrative data (as described in section 3). MHCLG may link your data with other governmental departments for the purpose of understanding the impact of the intervention over longer periods of time, including but not limited to DWP, HMRC and DHSC.

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

If you agree to us processing your personal information, we will only keep it 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.
• MHCLG, the data controller, may keep your data securely stored for up to 5 years after the completion of the evaluation, after which this will be further reviewed.

You may ask to withdraw from the study by getting in touch with MHCLG or IFF Research 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 IFF Research: citadelsurvey@iffresearch.com.

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/