Privacy notice Supported Housing Needs Assessment

This privacy notice explains how we collect, use, store and share your personal information when carrying out our Supported Housing Needs Assessment. It also explains your rights under UK data protection legislation.

East Sussex County Council is the commissioning authority on behalf of the Sussex local authority partnership, which includes:

  • Adur District Council
  • Arun District Council
  • Brighton & Hove City Council
  • Chichester District Council
  • Crawley Borough Council
  • Eastbourne Borough Council
  • Hastings Borough Council
  • Horsham District Council
  • Lewes District Council
  • Mid Sussex District Council
  • Rother District Council
  • Wealden District Council
  • West Sussex County Council
  • Worthing Borough Council

This privacy notice covers both:

  • the commissioning of the Strategic Needs Assessment by East Sussex County Council on behalf of the partner authorities; and 
  • the processing of data by East Sussex County Council for the purposes of delivering the project.

Overview

The government has published statutory guidance requiring local authorities to undertake supported housing strategic needs assessments. These assessments cover all forms of supported housing, including:

  • supported housing for older people;
  • long-term supported housing; and
  • transitional supported housing.

The findings of the assessment will inform the development of local supported housing strategies across Sussex.

The assessment will:

  • map the current supply of supported housing;
  • describe the wider population who may require housing with care and support;
  • identify potential supported housing needs within that population;
  • estimate future net additional supported housing requirements; and
  • support future planning and commissioning decisions.

To undertake this work, the Sussex local authorities, including Arun District Council, have appointed Private Public Limited (PPL) and Cordis Bright Limited to carry out the Strategic Needs Assessment on their behalf.

Who we are

Arun District Council is the data controller for the personal information collected as part of the Supported Housing Needs Assessment. This means we are responsible for deciding how and why your personal information is processed.

Contact details:

Data Protection Officer
Arun District Council
1 Maltravers Road, Littlehampton West Sussex BN17 5LF
Email: data.protection@arun.gov.uk 
Telephone: 01903 737500

Why we collect your information

We collect personal information to:

  • assess current and future supported housing needs, demands and supply.
  • understand the accommodation and support requirements of residents.
  • plan, commission and improve supported housing services.
  • meet our statutory duties relating to housing, homelessness, social care and public health.
  • monitor outcomes and evaluate the effectiveness of services.

Participation in the assessment may be voluntary, however certain information may be required where it relates to statutory service provision.

What information we collect

To support the assessment, East Sussex County Council and partner authorities will share anonymised information with PPL and Cordis Bright.

Personal Information

  • gender
  • address or area of residence
  • date of birth or age range
  • household composition

Special Category Information

We may also collect information about:

  • physical or mental health conditions
  • disabilities
  • care and support needs
  • ethnic origin

Other Information

  • housing circumstances
  • risk factors affecting housing stability
  • experiences of homelessness
  • income and benefit information
  • support services currently received
  • future housing aspirations and needs
  • type of accommodation you live in or provide
  • name of landlord
  • category of landlord - e.g. Housing Association, registered charity etc
  • your rental obligations
  • your Housing Benefit assessment and award
  • broad geographical information, such as partial postcode or Middle Layer Super Output Area (MSOA);
  • financial information relating to the cost of placements and services.

No personally identifiable information will be shared as part of this process. The data provided to PPL and Cordis Bright will be anonymised and cannot be used to identify individuals. Neither organisation will undertake person-level matching or attempt to identify any individual from the information supplied.

Lawful basis for processing

We process your personal data in accordance with Article 6 of the UK General Data Protection Regulation (UK GDPR).

The lawful bases may include:

  • Article 6(1)(e) - Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority.
  • Article 6(1)(c) - Processing is necessary for compliance with a legal obligation.

Where special category data is processed, the additional condition under Article 9 UK GDPR may include:

  • Article 9(2)(g) - Processing necessary for reasons of substantial public interest.
  • Article 9(2)(h) - Processing necessary for the provision of health or social care and support services.

Processing is also carried out in accordance with relevant provisions of the Data Protection Act 2018.

How we use your information

The information will be used to produce the Sussex Supported Housing Strategic Needs Assessment, which will identify current and future supported housing needs and any gaps in existing provision. The assessment will provide the evidence base for the development of future supported housing strategies across Sussex.

The information will be used to:

  • identify current and projected levels of need for supported housing.
  • assess gaps in existing supported housing and support service provision.
  • support strategic housing, commissioning and investment decisions.
  • inform future planning and development of housing and support services.
  • produce reports, analysis and recommendations for partner authorities.

Published reports and outputs will use anonymised and/or aggregated information wherever possible to ensure that individuals cannot be identified. No reports will include information that could reasonably be used to identify a specific person.

We are committed to maintaining high standards in the way we collect, use and protect information. We follow best practice in records management and regularly monitor and review our information handling processes to ensure they remain effective and compliant.

All staff handling information are appropriately trained and are required to protect confidentiality and privacy in accordance with data protection legislation and organisational policies.

We will never sell your information or use it for direct marketing purposes.

Who we share information with

We process information for this project to comply with statutory duties placed on local authorities under the Supported Housing (Regulatory Oversight) Act 2023 (SHROA) and associated statutory guidance.

Section 2 of the Act requires local housing authorities in England to:

  • carry out a review of supported exempt accommodation within their area; and
  • publish a Supported Housing Strategy based on the findings of that review.

The Act also requires social services authorities to provide reasonable assistance to local housing authorities in carrying out these duties where these are separate organisations.

The processing of information for this project is also necessary to comply with the Local Supported Housing Strategy Statutory Guidance (February 2026), which requires local authorities to develop and publish supported housing strategies by March 2027.

The Strategic Needs Assessment will be undertaken in accordance with:

  • the Supported Housing (Regulatory Oversight) Act 2023;
  • Local Supported Housing Strategy Statutory Guidance (2026);
  • Local Government Association (LGA) Supported Housing Guidance (2025);
  • Housing Learning and Improvement Network (Housing LIN) good practice guidance and methodologies;
  • any forthcoming National Supported Housing Standards.

Special Category Data

Where special category data is processed, the condition relied upon under the Data Protection Act 2018 is:

  • Schedule 1, Part 2, Paragraph 8 - Equality of Opportunity or Treatment.

This processing supports the assessment of supported housing needs across different population groups and helps ensure equality of opportunity and treatment in the planning and provision of services.

PPL and Cordis Bright will only receive anonymised data. No personally identifiable information will be shared with either organisation.

Sharing Your Information

No personal data will be shared with other organisations, all data shared will be completed anonymised.

Information is only shared with organisations or individuals who have a legitimate need to know, where there is a lawful basis to do so, or where you have provided your consent.

Fraud Prevention and Public Accountability

In certain circumstances, we may use the information we hold to assist in the prevention and detection of crime and fraud, where permitted by law. We may also share information with organisations responsible for auditing, inspecting or administering public funds to ensure that public money is used appropriately and lawfully.

Our Commitment to Protecting Your Information

We are committed to maintaining high standards in the way we collect, use and protect information. We follow good practice in records management and regularly review our processes to ensure compliance with data protection legislation.

All staff handling information receive appropriate training and are required to safeguard confidentiality and privacy. We will never sell your personal information or use it for direct marketing purposes.

East Sussex County Council may share your information with trusted external organisations to process your data on our behalf.

Any organisation commissioned by the Council will be under contractual obligation to comply with data protection legislation.

How long we keep your information

PPL and Cordis Bright will hold anonymised data returns from June 2026 until March 2027. PPL and Cordis Bright Limited will share aggregate findings at the end of the project to support future reviews in line with the statutory guidance. Once each local authority has adopted their new supported housing strategy, PPL and Cordis Bright are required to delete their copy of the anonymous data.

Arun District Council is the data controller for information from its own systems.

East Sussex County Council commissioned the needs assessment on behalf of the partner authorities.

Under CN1 14 of East Sussex County Council's retention schedule anonymised processed data gathered from surveys and opinion polls can be kept for 6 years after the end of the survey.

Under PR1 5 of East Sussex County Council's retention schedule contracts where the contract is awarded and is under £499,999 pounds and or not under seal information can be kept for 6 years after the end of the contract.

How we protect your information

We take the security of your personal information seriously and have appropriate technical and organisational measures in place to protect it from unauthorised access, loss, misuse or disclosure.

Your rights

Under data protection legislation, you have the right:

  • to be informed why, where and how we use your information
  • to ask for access to your information
  • to ask for your information to be corrected if it is inaccurate or incomplete
  • to ask for your information to be deleted or removed where there is no need for us to continue processing it
  • to ask us to restrict the use of your information
  • to ask us to copy or transfer your information from one IT system to another in a safe and secure way, without impacting the quality of the information
  • to object to how your information is used
  • to challenge any decisions made without human intervention (automated decision making)

Find out more or complain

If you are unhappy with how we have handled your personal information, please contact our Data Protection Officer in the first instance data.protection@arun.gov.uk.

You also have the right to complain to the Information Commissioner's Office (ICO):

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

Telephone: 0303 123 1113
Website: www.ico.org.uk 

Changes to this privacy notice

We may update this privacy notice from time to time. The latest version will always be available on our website or upon request.

Version: 1.0