Supported Housing Needs Assessment - Privacy Notice
What this privacy notice is for
Our core data protection obligations and commitments are set out in the council's primary privacy notice:
This notice provides additional privacy information for:
- Individuals who currently use, have previously used, or may require supported housing services
- Residents participating in the Supported Housing Needs Assessment
- Supported housing providers and other stakeholders participating in consultation and engagement activities
- The Housing Strategy and Commissioning service area
Updating our privacy notices
We may update or revise our privacy notices at any time, so please refer to the version published on our website for the most up-to-date details.
What we use your information for
We collect and obtain your personal information for the following purposes:
- To carry out a Supported Housing Needs Assessment (SHNA) for Oldham borough.
- To understand the current and future need for supported housing across the borough.
- To inform the council's Supported Housing Strategy.
- To support the council in meeting its duties under the Supported Housing (Regulatory Oversight) Act 2023.
- To understand:
- The need for supported housing for different client groups
- The current supply of supported housing
- Gaps in provision and future demand
- The experiences of residents who use supported housing and support services
- Priorities for future planning and commissioning of services
- To undertake consultation, engagement, interviews, focus groups and surveys with residents, providers and stakeholders.
- To analyse findings and produce reports about supported housing needs within the borough.
- To use existing service information, in anonymised or pseudonymised form where appropriate, to help plan, commission and improve supported housing and support services.
What categories of personal information we use
Personal information can be anything that identifies and relates to a living person. This can include information that, when linked with other information, allows a person to be uniquely identified. For example, this could be your name and contact details.
The law treats some types of personal information as 'special' because the information requires more protection due to its sensitivity.
This information consists of:
- Racial or ethnic origin
- Sexuality and sexual life
- Religious or philosophical beliefs
- Trade union membership
- Political opinions
- Genetic and biometric data
- Physical or mental health
- Criminal convictions and offences
To carry out these purposes, we collect and obtain the following personal information:
| Category of personal data | Special or sensitive information |
|---|---|
| Name | No |
| Organisation (where applicable) | No |
| Email address | No |
| Telephone number | No |
| Age bands | No |
| Gender | No |
| Ethnicity | Yes |
| Disability information | Yes |
| Health-related information | Yes |
| Support needs | Yes (where relating to health or disability) |
| Accommodation type | No |
| Referral information | No |
| Assessment information | No |
| Outcomes and move-on information | No |
| Housing circumstances | No |
| Views, experiences and information provided through surveys, interviews, focus groups and consultation activities | May include special category data |
| Information relating to supported housing and support requirements | May include special category data |
Where data is shared with our research partner for analysis, direct identifiers such as names, addresses, telephone numbers and email addresses will be removed.
Most analysis is carried out using anonymised or pseudonymised data. Where pseudonymised information is used, direct identifiers are removed and replaced with a unique reference.
Information that could be used to re-identify an individual is retained by the council and is not shared with our research partner.
Where interviews or focus groups are recorded for note-taking purposes, recordings will only be made with participants' agreement and will be securely deleted once transcription and quality checks have been completed.
Legal basis for processing
The legal basis for processing and/or sharing your personal information is:
- UK GDPR Article 6(1)(e) - Public Task: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the council.
Where special category information is processed, the council relies upon:
- UK GDPR Article 9(2)(g) - Substantial Public Interest
- UK GDPR Article 9(2)(j) - Research and Statistical Purposes, together with the safeguards required by data protection legislation
Participation in interviews, focus groups and other engagement activities is voluntary.
However, the council's processing of personal information for the Supported Housing Needs Assessment is carried out under its public task responsibilities and does not rely on consent as the lawful basis for processing.
Choosing not to participate, or withdrawing from participation, will not affect any services or support you receive.
Information sharing and recipients
We may share personal information about you with the following organisations and types of organisations:
- Arc4 Limited: Appointed by Oldham Council as a specialist housing research organisation to undertake the Supported Housing Needs Assessment on behalf of the council. Where individuals agree to participate in interviews, focus groups or other engagement activities, their contact details may be shared with arc4 for the purpose of arranging participation. Arc4 acts as a data processor and processes information only on the council's instructions.
- Relevant Oldham Council services: Services involved in housing, support, commissioning and strategy functions where necessary for completion of the assessment.
- Partner organisations: Where necessary to complete the assessment and where there is an appropriate legal basis to do so.
Any reports produced as part of the assessment will use aggregated and anonymised information.
Additional disclosure controls may be applied where necessary to reduce the risk of individuals being identified from small numbers.
Individuals will not be identified in published reports.
Where we get your information from
As well as information collected directly from you, we also obtain or receive information from:
- Existing council systems and records relating to supported housing services
- Relevant council services involved in housing and support provision
- Partner organisations where there is a lawful basis for sharing information
- Supported housing providers participating in the assessment
Data transfers beyond the European Economic Area
Personal information is normally stored and processed within the United Kingdom or European Economic Area.
Where a transfer outside the United Kingdom or European Economic Area is required, appropriate safeguards in accordance with data protection legislation will be put in place.
Automated decisions
All the decisions we make about you involve human intervention.
Our Guide to Exercising Your Rights outlines the procedure to ask us for an automated decision to be reviewed by an appropriate officer.
Find out about your data protection rights
How long we keep your data
We will only keep your personal information for as long as the law specifies or, where the law does not specify this, for the length of time determined by our business requirements.
Information used for the Supported Housing Needs Assessment will be retained only for as long as necessary to complete the project and respond to any follow-up queries.
Personal data held by arc4 for the assessment will normally be retained for the duration of the project and for up to six months following completion before being securely deleted.
Audio recordings made during interviews or focus groups will be deleted once they have been transcribed and checked.
Where can I get advice?
More information on how to exercise your information rights can be found on our website:
Further information about how the council processes personal information can be found in our main privacy notice:
You can also make a complaint to the Information Commission if you are unhappy with how your personal information has been handled.