Guidance

Rough sleeping questionnaire: privacy notice

Updated 9 January 2025

Applies to England

You are invited to take part in research by the Ministry of Housing, Communities and Local Government (MHCLG). MHCLG is responsible for housing in England. You’re being asked to take part in this research because MHCLG funds some homelessness services.  We are inviting you to take part because you have used a homelessness service.

It is up to you whether you would like to take part. Before you decide, we would like you to understand why the research is being done, and what taking part involves. If you decide to take part, you may decline to answer any questions or withdraw from participating in the research at any time.

This privacy notice and information sheet will explain the research and help you to decide.  It also explains your rights under UK data protection legislation.

Please ask if you have any questions or if there is anything you don’t understand.

1. Who is conducting the research

The Ministry of Housing, Communities and Local Government (MHCLG) is the data controller. You can contact t MHCLG’s Data Protection Officer at dataprotection@communities.gov.uk.

MHCLG have commissioned Verian, an independent research agency to collect the data. You can contact Verian’s Data Protection Officer at compliance@veriangroup.com.

More contact information for MHCLG and Verian is available at the end of this privacy notice.

2. What personal data we are collecting and why  

MHCLG would like to find out:

1.     How well services are working for people who are homeless or sleeping rough.

2.     Which public services people use and what benefits they may get. This is so that we can understand the costs connected with homelessness and rough sleeping.

3.     How people came to sleep rough, and their circumstances.

For this, we want to collect information about your experiences of homelessness and health needs. If you agree, MHCLG will also work with other government departments to link your answers to other information on your use of public services and your benefits.

We will not share your answers with anyone else. None of your answers will affect the benefits you get, or services you use.

There will be no consequences if you reveal any potentially illegal acts in the questionnaire, such as drug taking, unless there is a risk of serious harm to yourself or others. 

For the purpose of this privacy notice, the definition of ‘personal data’ is information which relates to and can identify a living individual.

The following personal data is being collected for this purpose:

• Special Category data: Information about your ethnicity, nationality, religion, sexual orientation, mental and physical health, wellbeing, drug and alcohol use and use of healthcare services. This information is reported by you and is not compulsory.
• Criminal Offence  data: Experience of prison and recent criminal justice interactions. This information is reported by you and is not compulsory.
• Personal identifiers, including your name, date of birth, gender, postcode, NHS number and National Insurance number. This information is reported by you and is not compulsory.

The special category and criminal offence data will help researchers understand the experiences of people sleeping rough and if this varies for different groups. If you agree to data linking, personal identifiers will provide researchers with a way to match data across a range of administrative datasets.

Taking part in this questionnaire does not mean you need to take part in any other research.  You do not need to share any information that could identify you.

Your name will be removed before Verian share your survey responses are shared with MHCLG and the researchers looking at the information will not know whose information it is. You will not be identified in any research reports.

The questionnaire will typically take between 30-60 minutes, depending on your life experiences. Your answers will be kept confidential. However, if we feel you are at risk, or someone else is being put at risk, we will need to tell someone.  We will usually let you know if this is the case.

3. Why we can collect this information (legal basis for processing the data) 

The data protection legislation sets out when we are legally allowed to process your data. The legal basis that applies to this processing is Article 6(1) of the UK GDPR:

(e) 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 controller;

‘Special Category’ data is personal data deemed to be more sensitive by law, and so needs additional protection.

The processing of special category data meets the requirement of article 9(2) of the UK GDPR.

(g) processing is necessary for reasons of substantial public interest, on the basis of Domestic 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

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. This condition is met since the processing is necessary for exercising a function of a government department and is necessary for reasons of substantial public interest. An Appropriate Policy Document is in place in accordance to meet the condition in schedule 1, part 4.

4. Who we will share the data with

If you agree, MHCLG may share your personal identifiers with other government agencies, so that they can share information such as your benefits, any offending behaviour, and your health and health service use, with us.

This includes, but is not limited to:

• the Department for Work and Pensions (DWP) on any benefits you receive
• National Health Service Digital (NHS Digital) on your health and use of health care services
• the Office for Health Improvement and Disparities, and the Department of Health and Social Care on your use of any substance misuse services
• Ministry of Justice (MoJ) on any offending records
• Office for National Statistics (ONS) so that your survey responses can be linked to other government departments’ data. Also, so other government departments and research organisations can access your anonymised data (you cannot be identified)

MHCLG use all this information about you, and other people, to help us understand the experiences of people sleeping rough. It will help shape what services are available in future but will not affect any of the services or benefits you receive now.

MHCLG will receive your personal identifiers and share these with other government agencies who will then match their data to yours. MHCLG will hold your personal identifiers securely. Before any linked datasets are shared with MHCLG and analysed your personal identifiers, such as name and address, will be removed creating a ‘pseudonymised’ dataset.

Verian, who are working for us, will be collecting your information when they do the survey.

Your personal data may be collected, stored, transferred or processed by companies or third party service providers for research-related purposes, such as data processing within the UK and the EEA. They are all contractually bound to keep any information they collect and disclose to Verian or, Verian collects and discloses to them, confidential and must protect it with security standards and practices that are equivalent to Verian’s.

5. How long we will keep the personal data, or criteria used to determine the retention period for

Personal data will be retained only for such period as is appropriate for its intended and lawful use, in this case MHCLG hold the least amount of personal data possible and have measures in place to delete personal data or make them anonymous, where appropriate.

The law allows that information held for statistical purposes only, such as information from your questionnaire, may be kept for longer periods.  

Personal data that is no longer required will be disposed of in ways that ensure their confidential nature is not compromised.

Verian shall retain data for no longer than 12 months, unless otherwise required to do so by law.

As part of Verian’s Company Business Continuity plan and as required by ISO 27001, ISO 9001, ISO 20252 certifications where held, and in certain instances by law, our electronic systems are backed up and archived. These archives are retained for a defined period of time in a strictly controlled environment. Once expired, the data is deleted and the physical media destroyed to ensure the data is erased completely.

6. Accuracy

Verian take all reasonable steps to keep personal data in our possession or control, which is used on an ongoing basis, accurate, complete, current and relevant, based on the most recent information available to us by you and/or by our client. If you would like to update your personal data, please contact us using the details provided below.

Verian rely on you to help us keep your personal data accurate, complete and current by answering our questions honestly. You are responsible for ensuring that the Data Controller is notified of any changes to your personal data.

7. Your rights, e.g. access, rectification, erasure 

You have the following rights in relation to your personal data (MHCLG or Verian may not be required to comply if the data are being held for statistical purposes only):

• right to access your personal data
• right to rectify your personal data
• right to erase your data from our systems
• right to restrict processing of your personal data
• right to object to the processing of your personal data
• right not to be discriminated against for exercising any of the rights available to you under applicable data protection laws

To request access to personal data that MHCLG or Verian hold about you, you should submit your request in writing to the e-mail address or postal address shown below in ‘Complaints and more information’.

If you contact Verian using an email address or contact details which we do not hold a record of, you will also need to provide a copy of a valid government issued or official identification (such as a driving licence or passport).

If necessary, Verian will notify any other parties such as our suppliers or service providers to whom we have transferred your personal data of any changes that we make on your request. Note that while we communicate to these third parties, we are not responsible for the actions taken by these third parties to answer your request. You may be able to access your personal data held by these third parties and correct or amend it where it is inaccurate.

8. Sending data overseas

Your personal data will not be sent outside of the UK/EEA.

9. Automated decision making

We will not use your data for any automated decision making.

10. Storage, security and data management

MHCLG will store your personal data in a secure government IT system.

Verian have appropriate technological and organisational measures in place to protect your personal data and take all reasonable steps to ensure your personal data is processed securely. All information you provide us is stored on secure servers and environments. Unfortunately, no data transmission can be guaranteed to be 100% secure. As a result, whilst we strive to protect your personal data, we cannot ensure or warrant the security of any information you transmit to us or from our online products or services, and you do so at your own risk. Once we receive your transmission, we will take reasonable steps to ensure our systems are secure.

All Verian’s third-party contractors, site service providers and employees are contractually obliged to follow our policies and procedures regarding confidentiality, security and privacy.

Verian adheres to the following industry requirements:

• the UK GDPR, UK Data Protection Act 2018, the EU GDPR, and any subsequent legislation, which may be amended from time to time

• we follow the MRS and ESOMAR professional Codes of Conduct

• we hold Market Research Society (MRS) Company Partner Accreditation

11. Complaints and more information

When we ask you for information, we will keep to the law, including the Data Protection Act 2018 and UK General Data Protection Regulation.

If you want more information please ask whoever is helping you with this research. They will answer your questions or show you where to access further information. They will leave you with a thank you letter explaining how to contact us if you have any questions later.

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 data, you should first contact dataprotection@communities.gov.uk.

Alternatively, you can contact Verian by using the contact details below:

Email address: compliance@veriangroup.com

Postal address:

Compliance Officer
Verian Group UK Limited
4 Millbank
London
SW1P 3JA

Verian UK Companies House number: 13663077

Verian will investigate all complaints and attempt to resolve those that we find are justified. If necessary, we will amend our policies and procedures to ensure that other individuals do not experience the same problem.

If you have any questions or comments, you may contact Verian’s Data Protection Officer, please email compliance@veriangroup.com. If you are still not happy with how MHCLG or Verian handle and protect personal data, or for independent advice about data protection, privacy and data sharing, you have the right to contact the Data Protection Authority. This is the ICO and their contact details are:

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

Telephone: 0303 123 1113 or 01625 545 745

https://ico.org.uk/

12. Notification of material changes

Verian keep their privacy policy under regular review, and it may be amended from time to time. We will always have the most up-to-date policy on this web page. We will record when the policy was last revised. Date created: 06/12/2024 Last revised: 07/12/2024