Rough Sleeping - Help and Outreach Privacy Notice
This privacy notice explains how Cheshire West and Chester Council uses personal information when providing support for people sleeping rough through the Streetlink service.
The service can be used by members of the public, partner organisations, or professionals to report concerns about someone sleeping rough, as well as by individuals who are themselves sleeping rough. Reports are passed to the Council’s commissioned outreach team, who aim to locate the individual, assess their needs, and offer appropriate support.
We receive personal data about you from third parties. This includes referrals from StreetLink, a national homelessness referral service, where a concern is raised about a person sleeping rough within the Council’s area. Once information is shared with the Council, we process it for the purposes of assessing need, offering support, and fulfilling our statutory responsibilities
This notice explains what information we collect, how we use it, who we may share it with, and how long we keep it.
What is Streetlink?
Streetlink is an online reporting service used by our Outreach team. It enables concerns to be raised about someone who is sleeping rough or preparing to sleep rough within the borough.
Reports are shared with the Council’s commissioned outreach team. While the team will try to locate the individual and offer support based on their needs, this may not always be possible. Any action taken will depend on the information available and the individual’s circumstances and wishes.
What information we collect, use, and why
When Streetlink is used, we collect personal information so that concerns about someone sleeping rough can be passed to outreach services and appropriate support can be offered. The type and amount of information collected will depend on the circumstances and on whether the information relates to:
- the person making the report, or
- the person who is sleeping rough or at risk of sleeping rough.
We only collect information that is relevant, necessary, and lawful to help us respond to the report and deliver outreach support. Information is grouped into personal data, special category data, and, in limited circumstances, criminal data.
Personal Data
If you are a member of the public or professional making a report, we may collect:
so we can clarify information if needed or provide updates where appropriate.
If the report relates to you and you are sleeping rough or at risk of sleeping rough, we may collect:
to help outreach workers identify and engage with you.
to help distinguish between individuals and identify eligibility for certain support.
such as where you are sleeping or spending time, to help outreach teams try to locate you.
to support follow‑up and engagement.
to understand your situation and identify appropriate housing or homelessness support.
to record actions taken, support offered, and outcomes, and to ensure continuity of support.
We do not require individuals sleeping rough to provide formal identification in order to receive support.
Special Category Data
In some cases, we may need to collect special category data where it is relevant to offering appropriate support. This may include:
where this affects your safety, wellbeing, or the type of support that may be appropriate.
where relevant to safeguarding or referral to specialist support services.
where this helps coordinate support with other services.
only where relevant, for example to monitor equality of access to services or to ensure support is culturally appropriate.
Special category data is only collected where necessary and is handled with additional safeguards.
Criminal Data
We do not routinely collect criminal data as part of the Streetlink service.
In limited circumstances, information relating to criminal matters may be recorded where:
- it is necessary to manage safeguarding concerns,
- there is a risk of harm to the individual or others, or
- information has been lawfully shared by another agency as part of a safeguarding or public protection process.
Any such information is recorded only where relevant and handled in accordance with data protection legislation.
Sources of Information
We receive information to support the Outreach service from a variety of sources, including StreetLink, a national homelessness referral service. The information we collect depends on the circumstances of each report and is only obtained where it is relevant, necessary, and lawful.
Information may be collected from the following sources:
Streetlink reports are often submitted by members of the public, voluntary organisations, outreach workers, or professionals who are concerned about someone sleeping rough. Information provided typically relates to the individual’s location, appearance, circumstances, and any immediate concerns about their safety or wellbeing.
Where possible, outreach workers will collect information directly from the individual during engagement on the street. This may include information about their circumstances, support needs, and wishes, and is used to help identify appropriate support.
We receive information from Council‑commissioned outreach providers who work directly with people sleeping rough. This may include engagement notes, support actions taken, and outcomes, to ensure continuity of support and avoid duplication.
In limited circumstances, information may be shared with or received from the police or other statutory bodies where this is necessary for safeguarding, public protection, or to manage risks to the individual or others.
Where appropriate, and usually with the individual’s knowledge, we may receive information from family members or carers to help us better understand the person’s circumstances and support needs.
We only collect information from these sources where it is necessary to assess concerns, offer support, or meet our legal and safeguarding duties. All information is handled in accordance with data protection legislation and council policies.
What is your personal information used for?
We use personal information to support people who are sleeping rough or at risk of sleeping rough, and to respond appropriately to concerns raised through the Streetlink service. Your information is used to:
To assess reports received, understand an individual’s circumstances, and enable outreach workers to try to locate the person and offer appropriate support.
To work with commissioned outreach providers, housing teams, health services, and other relevant partners to provide joined‑up and proportionate support.
To identify and manage safeguarding concerns, including risks to the individual or to others, and to take appropriate action where necessary.
To maintain accurate records of contacts, actions taken, support offered, and outcomes, ensuring continuity of support, accountability, and service oversight.
To review how the Street Support service is used, monitor performance and effectiveness, and improve how support is delivered.
To produce anonymised or aggregated statistics to help the Council understand levels of rough sleeping, plan services, and evidence outcomes to funders or government bodies.
To respond appropriately to enquiries, feedback, or complaints relating to a report or the operation of the service.
Personal information is only used where it is relevant, necessary, and lawful for the delivery and oversight of the Outreach service.
Who do we share your personal information with?
We only share personal information where it is necessary, lawful, and relevant to respond to a Streetlink report and to offer appropriate support. Information is shared on a need‑to‑know basis and only with organisations that are directly involved in outreach, safeguarding, or support.
Depending on the circumstances, we may share information with:
Organisations commissioned by Cheshire West and Chester Council to carry out rough sleeping outreach activities. Information is shared so that outreach workers can try to locate individuals, assess their needs, coordinate support, and record actions and outcomes.
Including supported housing providers or housing services within the Council, where this is necessary to help someone access accommodation or homelessness support.
Such as NHS services, GPs, mental health services, or substance misuse services, where information sharing is necessary to support an individual’s health, wellbeing, or safeguarding.
Where relevant, to enable referrals or coordinated support for individuals experiencing drug or alcohol dependency.
Where an individual requires support to understand their options, express their views, or make informed decisions about support.
Including safeguarding, adult social care, children’s services, or emergency housing teams, where this is required to deliver joined‑up support or fulfil statutory duties.
In limited circumstances, information may be shared with the police or other public authorities where this is necessary to manage safeguarding concerns, prevent serious harm, or comply with legal obligations. This sharing is proportionate and not routine.
We aim to work collaboratively with partner organisations to provide appropriate and coordinated support, while ensuring that personal information is handled securely and only shared where there is a clear and lawful purpose.
Data Processors
We use data processors to support the delivery and administration of the Outreach service. Data processors act on behalf of Cheshire West and Chester Council and only process personal information in accordance with our instructions and data protection legislation.
These include:
Forum Housing Association is a commissioned service provider delivering rough sleeping and homelessness support on behalf of the Council. It processes personal data as a data processor to support engagement with individuals, case management, and the delivery of agreed services, in line with the Council’s instructions.
Used to securely record Streetlink reports, engagement activity, actions taken, and outcomes, ensuring continuity of support and appropriate service oversight.
Used to receive and log reports or enquiries submitted by phone or online, and to pass information securely to relevant teams.
Used to host and protect systems that store personal information, including scanned documents and internal records.
All data processors are subject to contractual obligations requiring them to:
- process personal information only on the Council’s instructions;
- keep personal information secure;
- apply appropriate technical and organisational safeguards; and
- not use the information for their own purposes.
Data Controller
StreetLink is a separate data controller and is responsible for the personal data it collects when a referral is made. The Council becomes the data controller for any personal data received from StreetLink and is responsible for how that information is used once it is held by the Council. Further information about how StreetLink processes personal data is available in their privacy notice at: https://thestreetlink.org.uk/privacy-policy
Where personal data is processed by more than one organisation, your data protection rights apply separately to each data controller. Requests relating to personal data held by StreetLink should be made directly to StreetLink.
The Lawful Basis for Processing
The Outreach service is delivered by Cheshire West and Chester Council as part of its statutory and public protection functions. The Council does not rely on consent as a lawful basis for processing personal data under the UK GDPR.
Information is received from members of the public, partner organisations, and commissioned outreach providers about individuals who are sleeping rough or at risk of sleeping rough. Even where an individual chooses not to engage with outreach services, the Council records and processes limited information in order to respond to concerns, meet safeguarding duties, and evidence actions taken.
Personal Data
Personal data is processed under the following lawful bases in Article 6 of the UK GDPR:
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. This includes the Council’s statutory responsibilities relating to homelessness, safeguarding, and public protection.
UK GDPR Article 6(1)(c) – Legal Obligation
Processing is necessary to comply with legal obligations, including statutory safeguarding duties and public protection requirements.
The Council does not rely on UK GDPR Article 6(1)(a) (consent) for this processing.
Outreach workers seek an individual’s agreement to engage with support services or to share information with specific partners where appropriate. This agreement supports transparency and engagement and forms part of service delivery practice. It is not relied upon as consent under the UK GDPR and does not determine whether information is processed.
Special Category Data
Special category data is processed lawfully under Article 9 of the UK GDPR and the Data Protection Act 2018.
The Council relies on:
UK GDPR Article 9(2)(g) – Substantial Public Interest, supported by
Data Protection Act 2018, Schedule 1, Part 2, including:
- Paragraph 6 – Statutory and government purposes
- Paragraph 10 – Preventing or detecting unlawful acts
- Paragraph 16 – Support for individuals with a particular disability or medical condition
- Paragraph 18 – Safeguarding of children and individuals at risk
UK GDPR Article 9(2)(h) – Health or Social Care
Processing is necessary for the provision, coordination, and management of health or social care support, including referral to appropriate services.
Special category data is processed only where it is necessary, proportionate, and directly relevant to assessing concerns, safeguarding individuals, or coordinating support.
Legislation relied upon
The Council processes personal information for the Street Support service in accordance with its statutory duties, including:
- Housing Act 1996 – duties relating to homelessness and housing assistance
- Care Act 2014 – safeguarding and support for adults with care and support needs
- Children Act 1989 and Children Act 2004 – safeguarding and promoting the welfare of children and young people
- Local Government Act 1972 – powers and duties of local authorities
International Data Transfers
We ensure your personal information is protected if transferred outside the UK by using appropriate safeguards, including:
- Adequacy Decisions: Transferring data to countries with adequate data protection laws.
- Appropriate Safeguards: Using Standard Contractual Clauses (SCCs), Binding Corporate Rules (BCRs), or International Data Transfer Agreements (IDTAs).
- Derogations for Specific Situations: Relying on your explicit consent, performance of a contract, public interest, legal claims, or vital interests.
- Risk Assessments: Conducting risk assessments to ensure data protection standards are maintained.
- Technical and Organisational Measures: Implementing encryption, access controls, and regular audits to protect your data.
These measures ensure your personal information remains secure and your rights are upheld, even when transferred internationally.
Retention Period
Cheshire West and Chester Council retains personal information only for as long as it is necessary to deliver the Street Support service, meet safeguarding and statutory duties, and comply with legal and regulatory requirements. All information is retained in accordance with the Council’s Corporate Retention Schedule.
The retention periods applied to Street Support information are set out below.
Streetlink and rough sleeping case records (engagement and outreach activity)
Where a Streetlink report results in outreach activity, assessment, or ongoing engagement, records are retained for 7 years from the date the individual is no longer engaged with the service.
This aligns with the Council’s retention period for homelessness and housing support case records.
Reports with no direct engagement or follow‑up
Where a report is received but the individual is not located or does not engage with services, and no ongoing case is opened, the information is retained for 1 year from the date of the report.
Safeguarding‑related information (adults)
Where Streetlink information forms part of an adult safeguarding concern, records are retained for 7 years after the individual is no longer in receipt of services, or 25 years where the record relates to safeguarding legal issues or safeguarding reviews.
This reflects the Council’s adult safeguarding retention requirements.
Safeguarding‑related information (children)
Where Streetlink information relates to a child or young person, records are retained until the individual’s 25th birthday, or until their 75th birthday where the information forms part of a looked‑after child or care‑leaver record, in line with statutory safeguarding requirements.
Complaints and service‑related correspondence
Records relating to complaints about the Street Support service are retained as follows:
- Routine complaints: up to 3 years
- Complex complaints or Ombudsman involvement: 7 years
Monitoring, audit, and service oversight records
Records used for audit, quality assurance, or service monitoring are retained for 7 years.
Research, reporting, and anonymisation
Personal information used for statistical reporting, service planning, or performance monitoring is anonymised so that individuals are no longer identifiable. Working notes or draft materials containing personal information are securely destroyed once no longer required.
Anonymised information is retained without time limit, as it no longer constitutes personal data.
Your Rights
The UK GDPR provides you with a several rights to control what personal information is used by us and how it is used by us.
Further guidance about these rights can be accessed from the Information Commissioner’s Office (ICO) website
If you are not happy about the way your personal data is being used, or you require further information about how we process your personal data, you can contact Council’s Data Protection Team:-
- Online: Contact the DPO
- By post: Data Protection Officer, The Portal, Wellington Road, Ellesmere Port, CH65 0BA
You also have the right to complain to the Information Commissioner’s Office using the following details:
- Website: Information Commissioner's Office (ICO)
- Instant Message: Live Chat
- By post: The Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
- Telephone: 0303 123 1113