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Rough Sleeping Services Privacy Notice

1. Council contact details

1.1.    West Northamptonshire Council
Registered Office:
One Angel Square
Angel Street
Northampton, NN1 1ED
Contact centre telephone: 0300 126 7000

The Data Controller is West Northamptonshire Council

ICO registration number: ZA896620

The Outreach Team can be contacted by email at [email protected].

1.2 Purpose of this privacy notice

This privacy notice sets out how West Northamptonshire Council collects, uses and protects personal information as part of its Rough Sleeping Services, including:

  • Outreach services
  • In reach support in emergency and temporary accommodation
  • Case management, assessment and support planning
  • Rough sleeping prevention work
  • Multi agency safeguarding and risk management
  • Duty to refer and homelessness prevention activities

Special Category Data:

We may also collect information necessary to safeguard vulnerable individuals or deliver support services, including:

  • Physical or mental health information
  • Substance or alcohol misuse information
  • Safeguarding concerns
  • Social Care information
  • Racial or ethnic origin (only where relevant to support needs)

1.3    This privacy notice should be read in conjunction with:

  • Corporate Privacy Notice
  • Data Protection Policy

2. Information that we hold

2.1. Types of data collected

The personal and special category data we collect varies based on the support required, and may include:

Personal Data:

  • Name
  • Address, location or rough sleeping site
  • Contact details (phone/email)
  • Age and date of birth
  • National Insurance number or other identifiers
  • Housing history and accommodation status
  • Details of support needs
  • Information provided by third parties (agencies, landlords, health services)
  • Images (photographs or CCTV footage where relevant to safety)

Special Category Data:

We may also collect information necessary to safeguard vulnerable individuals or deliver support services, including:

  • Physical or mental health information
  • Substance or alcohol misuse information
  • Safeguarding concerns
  • Social Care information
  • Racial or ethnic origin (only where relevant to support needs)
  • Immigration status (where relevant to eligibility)

We only collect the minimum information required to deliver our statutory and support services safely.

3. How and why your information is collected and used

3.1. How we collect this personal information.

Most of the information we process is provided directly by you through:

  • Outreach contact
  • In reach sessions in temporary or supported accommodation
  • Casework and support planning
  • Email, telephone or face to face discussions
  • Referrals from partner agencies (with lawful basis)
  • Duty to refer submissions
  • Multi agency meetings relating to your safety or wellbeing

3.2. Why we collect your information.

There are a number of reasons why we need to collect and use your personal information.

Much of what we do in Rough Sleeping Services is governed by legislation, set nationally, which requires us to provide various services across West Northamptonshire.

We collect your information to enable the Council to:

  • Provide support to people who are sleeping rough or at risk
  • Assess needs and create personalised support plans
  • Arrange access to accommodation
  • Coordinate support with other agencies
  • Prevent homelessness (statutory Homelessness Reduction Act duties)
  • Safeguard vulnerable individuals
  • Reduce risks to you and the wider community
  • Maintain accurate records of service delivery

3.3 Lawful processing

We rely on the following lawful bases under UK GDPR:

UK GDPR Article 6:

e. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority

UK GDPR Article 9:

g. Processing is necessary for reasons of substantial public interest (including safeguarding)

Our work is enabled by several legislative frameworks, including:

  • Housing Act 1996
  • Homelessness Reduction Act 2017
  • Care Act 2014
  • Domestic Abuse Act 2021
  • Crime and Disorder Act 1998
  • Data Protection Act 2018
  • UK General Data Protection Regulations

4. What we do with the information

4.1 How we use your personal information.

We use your information to:

  • Provide outreach and in reach rough sleeping support
  • Carry out needs assessments and risk assessments
  • Arrange accommodation or signpost to housing pathways
  • Provide or coordinate relevant support services
  • Contribute to multi agency working (with consent or lawful basis)
  • Make safeguarding referrals where required
  • Meet our statutory obligations to prevent and relieve homelessness

Your data will only be used for the purpose for which it was collected unless required by law.

4.2. Who we share your information with.

To deliver our rough sleeping services, we may share information with:

  • Housing providers and commissioned accommodation services
  • Health services (including mental health and substance misuse teams)
  • Social Care services
  • Northamptonshire Police (for safeguarding, welfare or public protection)
  • VCFSE organisations supporting you
  • North Northamptonshire Council (where cross boundary support is required)
  • Government departments such as MHCLG (for statutory reporting)

Information is shared on a need to know, lawful basis and only the minimum necessary is exchanged.

We do not sell or rent your information.

4.3 Automated Decision making

We do not use automated decision making for this processing. Automated decision-making is where decisions are made about you without any human influence on the outcome. These may affect your legal rights or have an impact on your circumstances, behavior or choices.

4.4 Data Profiling

There is no profiling undertaken in relation to this processing. Profiling is where parts of an individual’s personality, behavior, interests and habits are analysed to identify their preferences, make predictions or decisions about them.

4.5 Automated Processing including AI

The Outreach service does not use automated processing or Artificial Intelligence in respect of your personal data, though CoPilot is used to collate meeting notes which may include your name and circumstances.

Automated processing includes use of internal or external text generation tools to create case file notes and reports. Artificial Intelligence includes the use of software to complete tasks more usually undertaken by people.

5. How long we keep your information for and how we securely dispose of it after use

5.1 Retention

We retain your data only for as long as necessary and in line with the Council’s retention schedule.
Retention periods vary depending on:

  • Legal requirements
  • Type of service provided
  • Ongoing safeguarding or risk management needs

5.2 When information is no longer needed, it is securely destroyed in accordance with the Council's Retention Schedules.

Retention periods vary depending on:

  • Legal requirements
  • Type of service provided
  • Ongoing safeguarding or risk management needs

6. How we store your information

6.1. Physical (paper) records

Paper records (for example, from outreach forms) are transferred into secure digital systems as soon as possible and then shredded via the Council’s certified confidential waste process.

6.2 Electronic records

Digital records are held securely on the Council’s IT systems or approved cloud services located in the UK, EEA or countries with approved adequacy arrangements.

7. Your data protection rights

7.1. The law gives you a number of rights to control what personal information is used by us and how we can use it. Please see section 5 of the council’s the council's Privacy Policy for further information.

7.2. Please be aware that your rights may differ depending on the lawful basis for processing your personal data.

8. Who to contact

8.1. If you would like further information about how we use your personal information, or you wish to exercise one of your data rights or you wish to complain about the use of your personal information please contact the Data Protection Officer.

8.2. If you are still dissatisfied with how we have used your data once you have made a complaint through the council’s internal complaints procedure you have the right to complain to the ICO.

The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113

9 Changes to this Service Privacy Notice

9.1 Privacy notices are reviewed regularly and updated to reflect service changes or new legal requirements.

This privacy notice was last updated May 2026

The update reference number is: PNS/26/059/H

Last updated 28 May 2026