Guidance

Homelessness and rough sleeping: Using data to prevent homelessness: privacy notice

Published 6 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. Sharing your data

Personal data collected during this study will not be shared with any other body outside the members of the CHI-led consortium, including Verian and Xantura, or MHCLG, the data controller.           

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

3. What personal data we 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 also 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 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 ‘Using data to prevent homelessness’, which is covered by this privacy notice. This project uses council data, including council tax debt, housing benefit and social work data to identify residents at risk of homelessness and offer targeted support. For more information, read about Using data to prevent homelessness.

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

Whose data we are collecting

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

• all individuals located in areas covered by local authorities participating in the project: London Borough of Barking and Dagenham, Royal Borough of Kensington and Chelsea, Newham London Borough Council, Stockport Metropolitan Borough Council and Test Valley Borough Council.
• staff delivering services or making referrals to those services
• staff bidding to take part in projects

For individuals located in areas covered by local authorities participating in the project    

Your local authority will share individual-level data with both Xantura (a technology company that provides a data platform for your local authority) and Verian (a large independent research company), who are part of the CHI consortium (and will therefore process data under instruction from MHCLG).

Xantura, a data collection partner for the evaluation, will combine a range of data on all households from across the local authority to identify households that may be at higher risk of homelessness. Xantura will produce a pseudonymised list of residents identified at risk of homelessness and share it with Verian for randomisation and analysis.

Verian will randomly assign participants into the treatment (those who receive the intervention) or control group (those who do not receive the intervention), sending the randomisation outcome back to Xantura (still in pseudonymised form, with an ID number assigned). Xantura will then share this ID number with a random allocation back to the local authority, who will deliver the intervention to those assigned to the treatment group. Your local authority may also share your personal information with Verian to arrange an interview with you.

The following personal data will be processed about individuals for this trial:

Personal identifiers (provided by local authorities), for example:

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

These data are needed by Verian to be able to contact participants for interviews or focus groups.

Background data (provided by local authorities). The following list of background data that will be collected is not exhaustive, but some examples (some of which is special category data) of data that will be collected are:

• age / date of birth
• ethnicity
• nationality
• sexuality
• gender
• disability
• marital status
• number of dependent children
• mental health, employment, financial security and social connections
• substance misuse and health data
• previous experiences of homelessness or housing insecurity
• SHBE (Single Housing Benefit Extract)
• debt Information:
  • rent arrears or main housing association stock transferee
  • council tax arrears
  • Housing Benefits overpayment
  • H-CLIC (Homelessness Case Level Collection)
• discretionary housing payments
• housing association data (where available)
• housing register
• Universal Credit data
• sundry debt
• adults social care risk factors
• youth offending data (where available)
• children’s social care risk factors
• domestic violence (where available)

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, ethnicity it is important to know whether interventions are more or less successful for different groups (particularly useful to break down results by protected characteristics under the Equality Act 2010). Verian will also use this data to identify who will be invited to be interviewed for this project, to ensure we collect views from a diverse and representative group.

Outcome data (provided by local authorities and discussed during interviews), for example:

• housing and homelessness
• referrals to other services

For individuals who agree to participate in an interview

We will gather participants’ views and experiences regarding receiving telephone calls and interacting with support services. The interviews will be audio-recorded and stored securely. While the recordings may include personal data, they are not considered personal data themselves, as they do not directly identify participants. However, all raw data relating to interviews (notes and recordings) will be kept confidentially by Verian and will not be shared with other consortium members. Verian will only share aggregated and anonymised findings from interviews externally, meaning nobody will be able to find out what you said.

For staff delivering services or making referrals to services

We expect that this information will be shared with Verian by local authorities, so they may arrange an interview or focus group with you.

Personal identifiers, for example:

• name
• 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. Why we are legally allowed to process your data

How we are using your data

The reasons that we can 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 (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 this project, sensitive personal data known as ‘special category data’ will be processed (detailed in Section 3). 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.

5. Keeping your data

If you agree to us processing your personal data, 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 needs 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:

• MHCLG, CHI and consortium members (including Verian and Xantura) 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 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; and
• 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 should first contact dataprotection@communities.gov.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/