H-CLIC homelessness research - data specific purposes

We are participating in a national homelessness research project called Homelessness Case Level Information Collection (H-CLIC). View the privacy information regarding this purpose below:

Purposes for which data held

The sharing of data gathered for H-CLIC is for research purposes only and aims to provide central government departments, local public services and delivery partners with valuable information about the cycle of homelessness and its impact on outcomes, as well as the impact and cost benefit of interventions and services targeted at reducing homelessness.

Nature, scope, context and purposes of processing

The project involves sharing personal identifiers and personal data between local authorities and MHCLG. The personal identifiers provided by local authorities will be processed by ONS (MHCLG’s trusted third party processor) to create an ONS identifier (ONS ID) that can be used to link together H-CLIC Data submissions over time and across local authority boundaries.

Who are the data subjects?

"The data subjects are residents of Enfield Known to Housing Services and their families. In the future it is hoped that the data can also be linked to other datasets, such as Rough Sleeping Questionnaire (RSQ), The Troubled Families Evaluation Dataset, and data from other Government Departments (OGDs), such as Ministry of Justice, Department for Education and Department for Work and Pensions/Her Majesty’s Revenue and Customs and health agencies (NHS Digital and Public Health England). The resulting dataset created for this project will be shared with ONS (in a de-identified form) to be made available to bona fide academics in the Secure Research Service (SRS).

ONS (as the data processor) will use the personal identifiers (referred to as H-CLIC PI) gathered from local authorities to create a look-up table of unique identifiers (ID numbers) to facilitate the matching of attribute data (including H-CLIC attribute data, the rough sleeping questionnaire and data from other government departments. The look-up table contains ID numbers only and no personal identifiers. The project and the look-up table have been designed to ensure the attribute data is pseudonymised (de-identified) at the earliest opportunity and staff analysing the attribute data do not know the identity of data subjects – organisational measures have been put in place to protect the anonymity of data subjects, including separation of roles for each organisation (MHCLG and ONS), separation of duties for staff and measures to ensure the identifiable data (H-CLIC PI data) is handled separately to any attribute data (for example, H-CLIC attribute data).

For this project, MHCLG and local authorities are independent data controllers and ONS is the trusted third-party data processor acting on behalf of MHCLG.

Data sharing will take place between local authorities and national public bodies and data sharing agreements will be agreed between MHCLG and each party. The data gathered for the project will be de-identified to allow use for research only. "

Is this sharing necessary?

Data sharing is necessary to observe the effectiveness of Homelessness Programmes and the Homelessness Reduction Act 2017 on a wide range of different outcomes that it aims to affect, spanning the remit of different Government Departments and to control for household and individual characteristics.;

Do you have explicit, written and freely given consent for each type of processing?

Not applicable

State when and how written consent is obtained

Not applicable

Under what legal basis are you processing?

The Homelessness Reduction Act 2017 (the 2017 Act) significantly reformed England’s homelessness legislation by placing duties on local authorities to intervene at earlier stages to prevent homelessness in their areas. It also requires housing authorities to provide homelessness services to all those affected, not just those who have ‘priority need’. The 2017 Act was fully in force by 3rd April 2018. Hence the legal basis will be GDPR Article 6 1(c) – legal requirement on the controller and 6 1(e) public task.

Where the personal data to be processed is special category data (sensitive personal data) it will be possible to rely on Article 9(2)(g) of the GDPR. MHCLG will rely on meeting the condition in Schedule 1, Part 2, paragraph 6 of the DPA 2018 in order to process special category personal data in accordance with section 10(3) of the DPA 2018.

Article 9(2)(g) allows for the processing of special category data where it is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject/individual.

A DPA has been signed between Enfield and the MHCLG for the quarterly on-going supply of H-CLIC personal identifiers and attribute data to the Ministry for Housing, Communities and Local Government. This data share will facilitate the linking of homelessness and other data sources to improve the evidence of the causes of homelessness as well as the factors associated with better outcomes.

Are any of the data subjects under 13?


If so, how are you obtaining parental consent for processing? If no consent, what is the legal basis?

Not required as covered by The Homelessness Reduction Act 2017 (the 2017 Act) hence legal basis is as above.

How long is the data retained for after processing?

Retention of Data follows national guidelines.

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