Guidance

Homelessness and rough sleeping: System-wide evaluation and Test and Learn programme: privacy notice

Updated 17 April 2024

Applies to England

1. The data controller

The Department for Levelling Up, Housing and Communities (DLUHC) is the “data controller”. This means that we are responsible for determining what personal information we collect about you and use, why and how (the ‘purpose and manner’).

2. Why we are collecting the data

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 it includes contact details, we will also tell you anything else that we may use it to contact you about and whether you can say no. If you do then say yes to us contacting you about other things, you can withdraw your agreement at any time.

In this instance we have commissioned the Centre for Homelessness Impact (CHI) to lead a consortium to assess the effectiveness of the homelessness and rough sleeping systems as a whole (known as the Systems-wide evaluation) and to establish the effectiveness of 8 projects testing different approaches to tackling homelessness and rough sleeping (known as the Test and Learn programme).

This privacy notice covers both elements of the work, although the Test and Learn programme involves sharing and processing of more personal data, so is the main focus of this document.

Systems-wide evaluation

Homelessness and rough sleeping can be viewed as a complex system affected by multiple, connected factors, interacting with each other, changing over time. Areas of influence include macro-economic policy, housing health and public attitudes. 

Whilst there are programmes and interventions in place to support people who are homeless, these can have unintended consequences. For instance, emergency housing may briefly reduce street homelessness but divert resources from prevention.  

Recognising this complexity the Systems-wide evaluation aims to enhance the evidence base on Homelessness and Rough Sleeping by understanding the impact and wider implications of different standalone programmes that seek to reduce homelessness. The evaluation will consider how these programmes influence, or are influenced, by other factors across the system.

Test and Learn Programme

Individuals personal information will be used only for one of the eight projects, but as the data protection implications are similar for all 8 trials, this privacy notice covers participants for all 8 projects.

The 8 trials are as follows:

1. Individual placement and support - removes conditions to starting work by helping people to access employment immediately with ongoing in-work support.

2. Outreach and health -  having a member of staff with health-related specialism in outreach teams to address the health needs of people sleeping rough.

3. Citadel volunteers – including 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.

4. Personalised budgets – providing financial support tied to a purpose to help individuals with experience of rough sleeping to exit homelessness.

5. Local connection – offering short-term accommodation and a supported voluntary reconnection to an area where the person has a connection or an area where they can get settled accommodation.

6. Care leavers - evaluating flexible funding offered to Local Authorities      to alleviate rough sleeping and other forms of homelessness among young people leaving the care system.

7. Accommodation and immigration advice for non UK nationals - Offering time-limited accommodation to enable non-UK nationals to engage with legal advice in order to resolve the immigration status.

8. Data to target housing and debt  - Using data on council tax debt, housing benefit, and social work data to identify residents at risk of homelessness and offer targeted support.

The aims of the study are to establish the effectiveness, and cost-effectiveness, of these schemes in reducing homelessness and rough sleeping. Trials that are shown to be successful can be rolled out across the country.

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).

For the Test and Learn programme, sensitive personal data known as ‘special category data’ will be processed (detailed below). Where we process special category data or data about criminal convictions, 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 – and paragraph 6 of Schedule 1 of the DPA 2018.

Systems-wide evaluation

The Systems-wide evaluation will mainly use aggregate level data (evidence on expenditure and activity relating to major programmes) with no privacy implications.

The evaluation will include an online survey of local authorities. A link to the survey will be sent to named contacts in each local authority. The email addresses of these individuals will therefore be shared with the CHI-led consortium organisation who will be administering the survey. The survey itself will not be collecting or processing any personal information.

Test and Learn

For the Test and Learn programme your personal details (name and contact details) will be shared by your Local Authority or by a third sector organisation (for example a homelessness charity), in the relevant project area, with IFF Research Ltd, the data collection partner that is part of the CHI led consortium. IFF Research will then allocate participants to either receive the project intervention or whether participants are allocated to a control group (these are groups individuals who will not receive the intervention. By comparing impacts on homelessness and rough sleeping is how we will know if the project intervention is successful     .

IFF Research will contact you to collect personal data relating to homelessness and factors that are related to causing homelessness (for example health or addiction problems).

IFF Research will then share your personal data with the evaluators that will be appointed to evaluate the project, and the delivery partners who will be implementing the intervention in each trial.

Data held by other public bodies such as Local Authorities or DWP (for example information about benefits) may also be used and shared with Evaluators.  The full list of personal data are summarised below.

All personal shared between members of the consortium will be shared via secure electronic systems.

The following personal data will be processed about individuals for the 8 trials. (The administrative and outcome data shared will depend on the aims of each trials).

Personal identifiers (provided by Local Authorities or third-sector organisations)

• Names
• Date of birth
• Telephone numbers, email address
• Postcode
• Gender
• National Insurance number
• NHS number

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

Background data (collected directly from the data subject 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)

• Age
• Ethnicity
• Nationality
• Sexuality
• Gender
• Criminal history
• Substance misuse and health data
• Previous experiences of homelessness or housing insecurity

These data are needed for a number of reasons: factors like substance misuse and poor physical or 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 breakdown results by protected characteristics under the 2010 Equality Act). 

Outcome data (provided by Local Authorities or third-sector organisations and directly from individuals - note as above)

• Engagement with and outcomes of referrals to services, including substance misuse, mental health
• Housing and homelessness
• Mental and physical health (including substance use)
• Employment and Income
• Interactions with the criminal justice system
• Immigration Status and case outcome

Administrative data and data linkage

Expected to include:

• DLUHC: Statutory homelessness applications and duties (at aggregate level)
• 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

All findings will be anonymised in any disseminated/published reports.

4. Sharing your data

Personal data collected during this study would not be shared with any other body outside the members of the CHI-led consortium or DLUHC, the data controller.

5. Keeping your data

We will only keep your personal information 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 secure your personal data for 3 months after the completion of the evaluation. DLUHC, the data controller, may keep your data securely stored for up to five years after the completion of the evaluation, after week this will be further reviewed.

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

(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 should first contact dataprotection@levellingup.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

ICO Website