Strategic insights tool for rough sleeping

The London Borough of Hounslow is committed to protecting and respecting your privacy. Through this Privacy Notice we have sought to be as transparent as possible and fully explain how your personal data is held and processed.

This privacy notice applies to information that our Housing Advice Service share with other local authorities, homelessness charities and service providers, along with London Councils and the GLA, who take part in determining this project’s overall purpose and development.

Homelessness in London, including rough sleeping, continues to rise. Addressing the homelessness crisis is a priority for all levels of government and for civil society. Collectively, London seeks to implement a data-informed policy to address homelessness, resulting in improved collective action that cuts across institutions, services, and sectors.

Local authorities are subject to a public duty to reduce or end rough sleeping in their areas, as identified, for example, in the Homeless Act 2002, and the Homelessness Reduction Act 2017. However, no single organisation is fully accountable for ending rough sleeping in a community.

A collaborative, strategic, data driven approach, with shared commitments, must be undertaken by partners to make rough sleeping rare, brief, and non-recurrent. London seeks to implement a data-informed policy, but this cannot be accomplished without improved collective action that cuts across institutions, services, and sectors.

This project consists of research and statistical work. The aim is not to change the delivery of support to a specific individual, but to inform and improve service delivery at a cohort, or population level. A key goal of the Strategic Insights Tool for Rough Sleeping (SITRS) is to better understand what happens to rough sleepers across their journeys into, during, and after they sleep rough, which will inform policy and service decisions.

Within the Strategic Insights Tool for Rough Sleeping, personal data on individuals is matched across data from multiple sources, and then aggregated trends and statistics are produced.

This notice tells you what to expect us to do with your personal information as part of this project.

If you have any questions about this privacy notice or any concerns about how we process your data, please contact the Hounslow Housing Advice team:

phone: 020 8583 3942
email: housingadvice@hounslow.gov.uk

The privacy notice will continue to be monitored and updated. You are advised to check this page from time to time.

What type of information we have

The information Hounslow Council holds about you is outlined in our Housing Solutions Privacy Notice.

For this project, data types processed are:

Full name
Social care information
Contact details (phone/email)
Employment
Date of birth
Age
Gender
National Insurance number
Housing information
Family / relationship information incl next of kin
Criminal (allegation or prosecution) information
Health / Medical information incl disability status
Referral / Assessment information
NHS number
Support network
Any unique reference number
Sex life or sexual orientation
Racial or ethnic origin

Due to the complexity of other organisations and council work in these areas, providing a prescriptive list of data fields to be shared is difficult.

We will only ask for personal information that is appropriate to enable us to deliver our services. In some cases, you can refuse to provide your details if you deem a request to be inappropriate. However, you should note that this may impact on our ability to provide some services to you.

How do we get your information

Specifically for Hounslow, see the same section of our Housing advice Privacy Notice.

Our lawful basis for processing your information

The GLA and London Councils are joint data controllers as they have influence over the Strategic Insights Tool for Rough Sleeping system’s design and processing. The Digital Economy Act supports data sharing between the GLA and boroughs and vice versa under Part 5, Cpt 1 s35.

Local authorities are subject to a public duty to reduce or end rough sleeping in their areas, as identified, for example, Part 7 of the Housing Act 1996, the Homeless Act 2002, and the Homelessness Reduction Act 2017. The Domestic Abuse Act 2021 amends Part 7 of the 1996 Act to strengthen the support available to victims of domestic abuse. The Act extends priority need to all eligible victims of domestic abuse who are homeless as a result of being a victim of domestic abuse.

For the local authorities, their original processing of the data matches the lawful basis for all parties as joint controllers for this project, which is Public Task for personal data, and substantial public interest 6 and 14 (Schedule 1, Part 2 of the DPA 2018 – ‘Statutory & government purposes’ and ‘safeguarding of children and of individuals at risk’), and research (Schedule 1, Part 2 DPA 2018 - ‘research) for special category data.

This is a research project and is considered to be ‘not incompatible’ to the original lawful basis for processing, for any of the bases used by the parties. Processing of data relating to criminal convictions and offences or related security measures for the parties’ original purposes, and this project, is in accordance with Schedule 1, Part 2, Section 6 of the Data Protection Act 2018.

Why we need your information (purposes of processing)

Local authorities, along with charities and service providers, are asked to share personal data of Housing Advice Service applicants in the Strategic Insights Tool for Rough Sleeping. The ambition is to develop an integrated rough sleeping data solution for local government and non-government service providers across London, to better understand client journeys, plan services, report trends, and manage performance.

The personal data we collect will be used for the following purposes:

To inform research into the journey of individuals experiencing homelessness, in order to identify trends and deliver more effective services
To identify monthly trends that looks at homelessness journeys across London, and potential areas for improvement
Information is also used in statistics and research to help find ways to end homelessness. Names and other information that could identify an individual are never included in research and statistical reports

Who your information may be shared with (internally and externally)

For this project, participating organisations are:

Other London Councils
Housing charities
Government and council approved housing providers
Department of Levelling Up, Housing and Communities
The GLA
London Councils

Participating organisations are considered joint data controllers. All parties will together determine the data used within the system and any future development of the system. The GLA will be responsible for letting and managing the contract to host, develop and maintain the SITRS system.

The processors or contractors on this project are Faculty Science and Homeless Link (post-February 2024).

Personal data will be processed and matched across data sources and then pulled into a merged database. Data pulled from this database into the user interface (front-end) to form the visualisations is aggregated and completely anonymised. No personal data is visible through the front-end. Authorised users will only be able to view: (1) individual level data that they contributed (because they are the one that uploaded it, it is not visible through the user interface) and (2) view linked information (in aggregate format) which has been de-identified. The reasons people enter rough sleeping are varied, so the treatments to address rough sleeping are equally as varied. This research project aims to better understand those reasons by mapping and connecting the continuum of rough sleeping. The aim is not to change the delivery of support to a specific individual, but service delivery may change to the cohort, or sub-cohorts, of people experiencing rough sleeping.

There will also be times when we are under a legal duty to share information. This includes, but is not limited to:

disclosure under a court order
sharing with the Ministry of Justice for inspection purposes
sharing with the police for the prevention or detection of crime
where there is an overriding public interest to prevent abuse or serious harm to others
disclosure to a Regulator if we identify a situation of potential misconduct or if the information is requested

We will strive to ensure that any personal data in our care will be kept safe and that where your information is disclosed to a third party working on our behalf, we will seek to ensure that they have sufficient systems and procedures in place to prevent the loss or damage of personal data.

How long we keep your information

Personal data retention in the project will be five years, to allow data matching over time. A key goal of the Strategic Insights Tool for Rough Sleeping is to better understand what happens to rough sleepers across their journeys into, during, and after they sleep rough, which will inform policy and service decisions.

The ‘trigger’ for the five-year retention period is based on an individual rather than on events. If an individual is still ‘live’ in the system, i.e. they have had any contact/interaction/event in the past five years, this data will be retained, but if there have been no contacts it will be deleted. There are some additional nuances with this in relation to accommodation types and whether there is an end date associated with them. For example, if an individual is marked as in ‘settled’ accommodation and there have been no further interactions in the last five years, even if there is no end date, we class this as a positive long-term outcome and consider the data to have reached the disposal point.

Your information will then be disposed of in the most secure manner possible.

Your data protection rights

The rights available to you depend on our reason for processing your information.

More information and how to make a request: Data protection - Your rights

Your right to make a complaint

The council tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.

If you want to make a complaint you can contact us on:

Complaints team
London Borough of Hounslow
Hounslow House
7 Bath Road
TW3 3EB

Data Protection Officer

The Council’s Data Protection Officer can be contacted by email at InformationGovernance@hounslow.gov.uk or at:

Information Governance Team
London Borough of Hounslow
Hounslow House
7 Bath Road
TW3 3EB

Information Commissioner’s Office

The Information Commissioner is the UK's independent body set up to uphold information rights.

If you would like to know more about your rights under the Data Protection law, and what you should expect, visit the Information Commissioner’s website.

If you have any concerns regarding any privacy practices or about exercising your Data Protection rights, you may contact the Information Commissioner’s Office:

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

Phone: 0303 123 1113 or 01625 545 745

Email: casework@ico.org.uk

A full list of what information we control and process and for what purposes is set out in our notification with the Information Commissioner's Register of Data Controllers. Our registration number is Z5761176. You can view our registration on the Information Commissioner's website.