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Note: These use cases are a first draft, and in some cases are still under initial development. Whilst based on countless conversations with professionals and members of the public, they haven't yet been validated. Comments on the use cases are particularly welcome.
Use case:
Housing management - Awaab's Law
This use case highlights a need for diagnoses of specific conditions (respiratory) at an address level, to help social landlords prioritise work on a specific issue (damp and mould).
As
a Registered Social Landlord (RSL)
I need
to know which of my properties have residents with respiratory conditions (or other diagnoses which make them vulnerable to damp and mould)
so that
I can prioritise the work we need to do to comply with Awaab’s Law by the October deadline.
As
a Registered Social Landlord (RSL)
I need
to know which of my properties have residents with disabilities, sensory impairments or cognitive impairments that I may not be aware of
so that
I can complete Personal Emergency Evacuation Plans (PEEPs) for everyone who needs them
As
an Adult Social Care service manager
I need
to know the distribution of people with specific conditions in my area
so that
I can monitor whether there are areas of potential unmet need, and plan services accordingly
Priority information
Address
A unique lifelong identifier for any addressable location, which remains consistent throughout the property’s lifecycle from planning application to demolition. A parent/child structure allows for a “parent” UPRN for an overall building and separate “child” UPRNs for units in that building – flats, office units etc. Every UPRN is classified according to a detailed classification scheme, which distinguishes (for example) residential property from commercial property and sheltered accommodation from care/nursing homes.
The UPRN is a priority dataset for almost every use case, as it's the one piece of information that (in theory) can remain consistent across any record held by any organisation.
The UPRN is included in the MODS and ASC-CoRe data standards, and will be included in release 3 of the PRSB Core Information Standard.
Useful information
Background
Awaab’s Law was introduced in July 2023 as part of the Social Housing (Regulation) Act, as a response to the tragic death of Awaab Ishak. It requires social landlords to take action to address hazards in the home, initially focusing on damp and mould but then extending to other hazards over the next two years. It effectively inserts into social housing tenancy agreements a term that will require landlords to comply with new requirements, and if they fail to do so, tenants will be able to hold their landlords to account through the courts. The following requirements will be introduced, in a phased approach:
From October 2025 social landlords will be required to address damp and mould hazards that present a significant risk of harm to tenants within fixed timescales. From the same point in time, they will also have to address all emergency repairs, (whether they relate to damp and mould or not), as soon as possible and within no longer than 24 hours.
In 2026, requirements will expand to a wider range of hazards beyond damp and mould. The government has not yet fully determined which hazards will be included in this second phase, but expects it to include excess cold and excess heat, falls, structural collapse, fire, electrical and explosions, and hygiene hazards.
Then in 2027, the requirements of Awaab’s Law will expand to apply to the remaining hazards as defined by the Housing Health and Safety Rating System (HHSRS) but excluding overcrowding.
(Content adapted from the National Housing Federation)
This use case covers NHS data about respiratory diagnoses. A similar approach showing mobility impairment, sensory impairment and/or cognitive impairment could help social landlords prioritise Personal Emergency Evacuation Plans (PEEPs), or could help Adult Social Care services identify possible areas of unmet demand to help with forward planning and commissioning.
Further narrative
Lawful basis for processing
This is the first issue that would need to be resolved. Arguably the UPRN identifies the property but not the person (SAVVI and VIPER have both drawn on this approach).
If it's felt that the UPRN and high-level diagnosis would, between them, identify an individual, is there a legitimate means for the NHS to release the data under Art. 9 (2)(h) as contributing ot the person's health, and the social landlord to receive it under Art. 9 (2)(g) - substantial public interest on the basis of domestic law?
Essential requirements (internal):
Full list of our properties with UPRN
Stock condition survey data
Essential requirements (external):
List of UPRNs with a flag indicating whether a resident at that address (i.e. Main Address on the NHS Personal Demographics Service) has one of a number of specified conditions.
List of SNOMED-CT codes for all relevant diagnoses. This entry in SNOMED-CT covers respiratory conditions; RSLs may only need the flag to indicate the parent concept (50043002 | Disorder of respiratory system) rather than the specifics of the 55 child conditions.
Clinical advice on which diagnoses to include, the level of detail required to achieve the best result, and whether any specific co-morbidities increase risk.
Desirable:
Flag could indicate phenotypic sex and age band
Flag could indicate co-morbidities
Similar functionality would be useful for social care managers. The Client Level Data statutory return, which requires councils to report on people requesting and/or receiving care and support, asks for information about four conditions - hearing impairment, visual impairment, dementia and Autism Spectrum Disorder. (Links are to the relevant SNOMED-CT refsets.) It would be useful for planning purposes to see how many local residents are diagnosed with these conditions but nor receiving care and support.
Possible technical approach:
An Application Programming Interface (API) to submit UPRNs to the NHS's systems and call back the above data
Risks
Risk
NHS data holdings are incomplete
Mitigation
- This will always be a risk - people's conditions may not be correctly coded in SNOMED-CT, addresses may be out of date, NHS may not have captured UPRNs for every address.
- Proof of concept required to (a) verify technical feasibility and (b) validate the completeness and reliability of data.
- Data recipients would need to understand clearly that this cannot be relied upon as a definitive dataset.
Risk
NHS is unwilling to provide relevant data
Mitigation
- UPRN is not personal identifiable information; SAVVI and VIPER have both been able to share data on this basis.
- If there's any risk of an individual being identified, this processing may in any case qualify under GDPR Art. 6 (e) (Public Task) and Art. 9 (2)(h) (health and social care) - the NHS would be supplying it in direct support of the health needs of the individual. For Art. 9 (2)(h) to apply, however, the data recipient at the RSL would need to be under a codified professional obligation of secrecy.
Risk
Landlord doesn't hold UPRNs for all their properties
Mitigation
- Approach the Local Land and Property Gazetteer (LLPG) Custodian at all relevant local authorities to request UPRNs.
- Longer term, explore whether social rental properties can be coded in UPRN classifications.
- Explore alternative approaches to UPRN lookup for RSLs.
