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Understanding the concerns

Sharing and centralising address and street data along with departmental information can create valuable intelligence. For example, it can provide deep insights into current service utilisation, helping uncover metrics, patterns and trends which could help create more efficient, targeted and proactive services.

In a practical sense, this involves gathering departmental data along with the UPRN or USRN and joining the information together based on these identifiers, (or geographically using their location) to form a property or street-level view.

This is a well-established practice but one which is often subject to concern and apprehension by data owners on whether their data can be shared in this way, how it will be used, its purpose, if it is classed as personal data, how it will be stored and for how long.

Often these concerns can act as barriers to data sharing when in reality further clarification and assurance their data will be handled in the correct way may be needed. The Information Commissioner's Office (ICO) has specific guidance on this via the use of a data-sharing code of practice and associated agreements.

General Data Protection Regulation (GDPR)

The concerns are usually centred on whether the use of data is compliant with the "General Data Protection Regulation" which is implemented within the Data Protection Act 2018.

This places a strong emphasis on being responsible for following "data protection principles" especially where personal data is being used.

(source: https://www.gov.uk/data-protection)

A key resource providing in-depth guidance and advice on the above principles and other data-sharing topics is the Information Commissioners Office (ICO) website.

What is personal data?

One of the main considerations is knowing whether the data you are requesting or handling relates to an individual. If it does then it would be classed as personal information and the various data protection principles would need to be adhered to.

So what is personal data?

(Source: ICO website)

In most cases, if you are requesting or handling address or street data on its own, then it does not "directly" relate to an identified individual and is not personal data.

However, do keep in mind if requesting property or street data along with additional departmental information which relates to it, that it could "indirectly" identify an individual. It all depends on what additional attribution you are asking for and working with.

The ICO website has detailed guidance on what constitutes personal information. If the data you want to work with does contain personal data, then it simply means it needs to be treated sensitively as per the data protection principles.

The ICO data sharing code of practice

Personal data can be shared, but only in the right way

If the information you are requesting or handling does contain (directly or indirectly) personal data which relates to an individual, then it doesn't mean it cannot be shared.

Instead, it just needs to be shared and handled in a way which conforms to the various data protection principles:

  • Lawfulness, fairness and transparency

  • Purpose limitation

  • Data minimisation

  • Accuracy

  • Storage limitation

  • Integrity and confidentiality (security)

  • Accountability

Code of practice

The Information Commissioners Office (ICO) have published a data sharing code of practice. In their words:

You can find the code of practice below, which contains a whole wealth of guidance including; what to include in a data sharing agreement, when they are needed, how to address the data sharing principles, data sharing in the public sector and various templates.

https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/data-sharing/data-sharing-a-code-of-practice/

Further resources