Thank you for your interest in the SAVVI case study of how Wigan Council engaged with the SAVVI method to design how they will support vulnerable people.
Executive Summary
SAVVI, a Scalable Approach to Vulnerability via Interoperability, is a data project that aims to support early identification of vulnerable people and households, and to make smarter interventions and referrals. To do this, SAVVI defines an iterative model process that councils can use to ‘find, assess, and support’ people in need. SAVVI pulls together practical guidance, frameworks, standards, templates and resources in an online playbook to support every stage of the SAVVI model process.
This is a case study of how Wigan Council engaged with the SAVVI method, during 2023, to improve how they support vulnerable people in the event of a civil contingency emergency, such as in the event of a flood. The purpose of the document is to share the Wigan experience to inspire other councils looking to adopt a similar SAVVI-style approach to finding and supporting vulnerable people in their area. The case study is structured in sections that follow the stages of the SAVVI model process to enable readers to understand where each stage of the Wigan Here for You project maps to SAVVI.
This case study will be of particular interest to: civil contingencies teams, regional local resilience forums, and project teams who want to find and support people in need; data and digital teams who want to handle and share data to a reusable standard; Information Governance teams who want to ensure that data is being shared and reused legally, ethically, and transparently; and performance and BI teams who want to evidence that a project is effective in reducing hardship. ‘Here for You’ is Wigan Council’s project to develop a data driven approach that builds a picture of who is vulnerable, providing valuable intelligence as to who may need support in the event of a civil emergency. In particular, this new approach identifies the risk factors that can be used to find vulnerable people; regularly extracts those risk factors from various computer systems so that the data is up-to-date and emergency ready; and uses the council’s existing GIS system to link Risk Factors to properties. The Here for You case study refers to all six stages of the SAVVI model process, with a particular focus on: PURPOSE, ‘FIND’, and ‘ASSESS.
This case study shows how a clearly defined purpose for a SAVVI project can successfully drive design through the six stage model process. Moreover, establishing the clear purpose for the project at the outset provided a solid structure for the information governance work in the FIND stage, particularly when considering purpose compatibility and the need to find a lawful basis for the re-use of data. Establishing lawful, ethical and transparent data-use as part of the design process was foundational to project success, validating the need for the SAVVI IG Framework, and other practical IG tools that SAVVI has prototyped to support councils working on a vulnerability project.
Wigan council now has a more reliable and significantly improved capability to find people at risk with vulnerabilities in an emergency. The SAVVI model process and IG framework allows others to adapt Wigan’s learning and approach, and also allows Wigan council to apply this method to other vulnerability projects.
Introduction
This is a case study of how Wigan Council engaged with the SAVVI method, during 2022 and 2023, to design how they will support vulnerable people during a flood and other emergencies, via their ‘Here For You’ project. The project was the first stage in Wigan fulfilling its broad ambition to improve its approach to supporting vulnerable people.
Wigan Council's biggest challenge before the project was being able to develop a complete picture of who is vulnerable in their area because the information needed to assess the risk of vulnerability was held in several different datasets, all with their own definitions and usage rights. This made it challenging to assess the risk of vulnerability legally, ethically and transparently.
The purpose of this document is to share Wigan Council’s experience and to inspire other councils looking to adopt a similar SAVVI-style approach to finding and supporting vulnerable people in their area.
Supporting Vulnerable People in an Emergency
Wigan Council is a Category 1 Responder as defined by the . These responders need to be ready to identify residents who are most likely to be at risk in a wide range of emergencies, some of which come with a warning period, such as a storm that may cause flooding or property damage, while others require an immediate response, such as a terrorist incident, utility outage or the accidental release of a dangerous substance. The main objectives of the initial response by Category 1 Responders to emergencies are to:
Protect the health and safety of personnel. Safeguard the environment. Maintain or restore critical services. Information sharing during an emergency is necessary so that responders can make the right judgements. If responders have access to all the information they need, they can make the right decisions about how to plan and what to plan for. If they do not have timely access to all the information, their planning and decision making will not be as good and vulnerable people may not receive the support they need in a timely manner.
Some people may be less able to help themselves during an emergency. People who might be vulnerable will vary depending on the nature of the emergency, but plans should consider people
who may struggle with their mobility who may struggle with cognition and may need additional support to understand the situation. with a sensory disability. with other vulnerabilities and who live alone. Wigan Council holds and owns data about people, on various computer systems, which can identify vulnerabilities, and higher risk locations. While it is possible to interrogate these separate systems as an emergency is occurring, it is resource intensive in terms of staff time and frequently means that this information cannot be supplied to Incident Commanders in time for it to inform their decision making and planning.
Emergencies occur at any time and often outside of the normal working hours of most Council staff; so, a common experience for Wigan Council was having to arrange access to data, very quickly, during an emergency.
This typically elevated the risk of either using data inappropriately, e.g. sharing far more data than was strictly necessary, or delaying the response to the most vulnerable residents.
An alternative for Wigan Council was to use a less data-driven approach, for example approaching all residents in a flood area, much of which is unnecessary and, again, delayed, or reduced help to those who needed it the most.
This demonstrates that advance planning is essential because it allows ethical factors to be fully considered without the limitations of acting during an emergency period, and allows the council to consult and inform residents about the use of their data.
Planning the use of data well in advance of an emergency has enabled all of these activities, including the processing of personal data, to be designed and implemented legally, ethically and transparently.
Here for You - Wigan’s Data Led approach
Wigan have created a new approach that
identifies the Risk Factors that can be used to find vulnerable people regularly extracts those Risk Factors from various computer systems so that they are up-to-date and ready for use in an emergency uses the council’s existing GIS system to link Risk Factors to properties During an emergency, the geographic area affected by the incident can be plotted so that properties with Risk Factors can be presented visually on a map, and listed for use by responders.
Reuse of existing personal data in this way needs to be compliant with data protection, privacy and ethical considerations. Wigan have designed the solution to be GDPR compliant, including being secure, with restricted access and with an auditable trail of who accessed it and when.
The solution can be accessed 24/7 and provides the information within minutes to inform Incident Commanders, enabling targeted support to be offered to the most vulnerable residents during an emergency.
As phase one of the project, which is now complete, was to establish internal data reuse processes, no data sharing arrangements with other organisations were developed. During the next phase of the work, Wigan Council intends to form data sharing agreements with partners such as Health and Utility organisations, to acquire additional Risk Factors data.
How SAVVI supports the Wigan approach
About SAVVI
, standing for ‘a Scalable Approach to Vulnerability via Interoperability’, is a programme hosted by on behalf of the local public sector, and funded by the Department for Levelling Up, Housing and Communities’ (DLUHC)within the . SAVVI is proposing the , to promote how data can be used to improve early identification and smarter interventions, particularly where no single organisation has access to all the data and insight that can predict who may be struggling. Finding people or households who may be vulnerable requires that we are able to routinely bring existing data together, from many sources. The playbook includes
a to find, assess, and support vulnerable people and households; to support the common process, and promote interoperability; an to ensure that data is handled legally, ethically and transparently; The rationale for the SAVVI Playbook is that it can be applied to all vulnerability scenarios so that
investments in technologies and data sharing can be reused across initiatives; we are ready for the next emergency Phases of the SAVVI Process
The SAVVI Process is organised into six phases.
Establishing the Project Team
SAVVI recommends a project team structure that includes
vulnerability or operational subject matter experts data analysis and integration expertise information governance professionals.
Additionally, SAVVI recommends a governing group to sign-off key decisions and definitions that are set out in the SAVVI Playbook.
Wigan Council’s project team included:
members of the Civil Contingencies team who were able to specify the Risk Factors they wanted to use to prioritise residents at highest risk in different emergencies representatives of the Joint Intelligence Unit who were able to identify the required sources of data the council’s information governance manager and policy officer, who could ensure the project complied with its information governance policies and processes, and a technical support analyst and information developer to design data movement processes The project team was overseen by Wigan Council’s Director of Public Health, Strategic Lawyer (and data protection officer) and the Joint Intelligence Unit service manager. Additional governance was provided by the council’s Caldicott Guardian.
Applying SAVVI to the Wigan ‘Here for You’ project.
PURPOSE - setting up a Vulnerability Initiative
This is the first phase of the SAVVI process. During this phase, the vulnerabilities are defined, together with the ‘purpose’ that gives the organisation the remit to address them.
Defining the Vulnerabilities
The SAVVI Concept Model defines ‘Vulnerability’ as
Wigan defined three Vulnerabilities that are in scope of the ‘Here for You’ project.
Defining the Purpose
An organisation needs to demonstrate that it has a remit to address vulnerabilities. This becomes important when data that was collected for an original purpose, is to be re-used for this new purpose. This is best expressed as powers and/or duties that define the Purpose.
The SAVVI Concept Model defines ‘Purpose’ as
Wigan defined one Purpose as
Purpose
Civil Contingencies - Preventing and Mitigating harm to people and households during an emergency.
Powers and Duties
The requires that a Local Authority will (d)maintain plans for the purpose of ensuring that if an emergency occurs or is likely to occur the person or body is able to perform his or its functions so far as necessary or desirable for the purpose of—
(i)preventing the emergency,
(ii)reducing, controlling or mitigating its effects, or
(iii)taking other action in connection with it,
See -
FIND - using data to find people who may be at risk
The FIND phase defines a set of Risk Factors and how they can be used to find people who may be vulnerable.
Defining Risk Factors
The SAVVI Concept Model defines ‘Risk Factor’ as
Wigan defined 15 Risk Factors
Defining how Risk Factors are applied
The SAVVI Concept Model defines ‘Risk Policy’ as
Wigan defined a Risk Policy that covers the three Vulnerabilities and how they are categorised. Categories can be used to prioritise a response. Wigan have chosen to have two categories of Risk
The SAVVI process highlights that the choice of Risk Factors needs to be supported by some evidence that demonstrates that they are effective in finding people at risk. This becomes important when arranging for data sharing so that the data controller can be assured that their data is necessary to make the Risk Policy work.
Wigan set their evidence as - The evidence for the use of these Risk Factors was generated via a retrospective review of the response to previous emergencies, including flooding during Storm Christoff in 2021. The Risk Factors included in this risk model are those that the operational team found would have been most indicative of Needs and priority.
Defining How Risk Factors are Accessed
SAVVI sets out a Data Flow Map, to show where Risk Factor data can be drawn from.
Rather than refer to specific computer systems, or suppliers, SAVVI uses a more generic ‘Information Type’ so that other organisations can re-use parts of the map.
The SAVVI Concept Model defines ‘Information Type’ as
Wigan defined their Data Flow Map as
So far, Wigan are reusing their own data, but this approach will also map out data controlled by other organisations.
ASSESS - listening, to understand needs and circumstances
The ASSESS phase sets out how people on a Risk Index are then assessed to understand their Needs.
At Wigan, this assessment is carried out by the council via the Health Protection and Civil contingencies Service.
Defining Needs
The SAVVI Concept Model defines ‘Need’ as
Wigan defined 5 Needs for which they can arrange support offers.
SUPPORT - addressing needs by offering support
The SUPPORT phase sets out how people with one or more Needs could then be supported with a Service or Intervention, which might be referrals to other organisations.
Define Services
The SAVVI Concept Model defines Service as
A selection of the Services Wigan can deliver or refer to is listed below.
REPORT - monitoring outcomes over a caseload
The REPORT phase uses many of the definitions already set out. With this language in place, a multi-agency dashboard and outcomes framework could be put in place to answer questions such as
How many cases, for each risk category, are on the Risk Index? What Needs have been determined? What Services have been used? What Outcomes have been achieved? Defining Outcomes
The SAVVI Concept Model defines ‘Outcome’ as;
Wigan have not reached this part of the SAVVI process. We suggest that outcomes could be recorded such as;
IMPROVE - reviewing data to get better results
As a SAVVI Vulnerability Initiative is run, data is collected conforming to the SAVVI Concept Model. This data can be analysed to consider questions such as
How can the Risk Policy be improved to improve the hit-rate of finding people that do need help. What Risk Factors did people have who were not on the Risk Index, but did need help. What Services are effective in contributing to good Outcomes when addressing which Needs
Since implementing the ‘Here for You’ approach, Wigan have not yet had an emergency incident. When they do, they will have collected data that could be analysed to help them to improve the effectiveness of the data-led approach.
Using Data Lawfully, Ethically and Transparently
The SAVVI Playbook includes an with steps to ensure that data is used, and reused, legally, ethically, and transparently. The SAVVI IG Framework refers to existing codes and guidance including ...
The framework defines some key steps and assessments to take, which are then referred to in a Data Protection Impact Assessment (DPIA).
The re-use of existing data as the source of Risk Factors
Each of the Risk Factors were considered , by looking at the ‘Information Types’ that they are derived from.
Purpose Compatibility
The Data Flow Map has demonstrated that the Purposes for which the Risk Factor data was originally recorded, is different to the Civil contingencies Purpose. ICO guidance is that …
Developing data reuse propositions
As the revised purpose is not ‘compatible’, Wigan needed to establish the ‘Lawful Basis’ for its reuse for Civil Contingencies.
The SAVVI Information Governance Framework sets out how to define a for each Information Type, and specify the proposed GDPR Lawful Basis where applicable, one or more Legal Gateways where required further Conditions for Processing
The Purpose for the new data use had already been set out in the Purpose phase. The new lawful basis for the new use was determined to be “Legal Obligation”.
The Data Flow map had documented each of the data sources, and the lawful basis on which personal data was originally collected. A legal gateway is needed to enable the existing data to be reused for the new purpose. The legal gateway for all the data was determined to be
Data Ethics
Having established that data reuse is lawful, the SAVVI IG Framework proposes that a further assessment should be done to assess the ethical reuse of data. The framework points to the UK Government’s , which requires that the processing of Personal Data demonstrates
Wigan considered ethical factors and the impact on individuals by balancing
the council’s responsibilities to respond during an emergency on the basis that without intervention there are potential risks to life. the Human Rights Act 1998 which sets out responsibilities for public authorities to take positive steps to protect rights when lives are in danger.