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Supporting Vulnerable People During an Emergency at Wigan Council

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
Civil Contingencies Act 2004
⁠
. 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:
Warn and inform.
Save and protect life.
Relieve suffering.
Prevent escalation.
Protect the health and safety of personnel.
Safeguard the environment.
Protect property.
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

⁠
SAVVI
⁠
, standing for ‘a Scalable Approach to Vulnerability via Interoperability’, is a programme hosted by
Tameside Council
⁠
on behalf of the local public sector, and funded by the Department for Levelling Up, Housing and Communities’ (DLUHC)
⁠
within the
Local Digital Fund
⁠
.
SAVVI is proposing the
SAVVI Playbook
⁠
, 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
common process
⁠
to find, assess, and support vulnerable people and households;
⁠
data standards
⁠
to support the common process, and promote interoperability;
an
Information Governance Framework
⁠
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.
1
⁠
Untitled.jpg
⁠
⁠
PURPOSE - setting up a Vulnerability Initiative
FIND - using data to find people who may be at risk
ASSESS - listening, to understand needs and circumstances
SUPPORT - addressing needs by offering support
REPORT - monitoring outcomes over a caseload
IMPROVE - reviewing data to get better results
There are no rows in this table
⁠

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
1
Vulnerability
The increased risk of a poor outcome
There are no rows in this table
⁠
Wigan defined three Vulnerabilities that are in scope of the ‘Here for You’ project.
1
Vulnerability
Description
2
Being unsafe during Adverse Weather
Risk of harm caused by Adverse Weather such as
high winds
flooding
… which might require evacuation or support at home. The risk could be higher for those with
mobility issues
physical and mental health conditions
sensory impairment
type of accommodation
living alone
3
Being unsafe during a Utility Outage
Risk of harm during a utilities outage such as
electric
water
sewerage
… which might require support at home. The risk could be higher for those with
dependency on equipment
physical and mental health conditions
living alone
4
Being unsafe during an Environmental or Terrorist threat
Risk of harm caused by an Environmental or Terrorist threat such as
pollution
unexploded bomb
toxic agent
… which might require evacuation. The risk could be higher for those with
mobility issues
physical and mental health conditions
sensory impairment
living alone
There are no rows in this table
⁠

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
1
Purpose
The remit that an Organisation has to carry out an initiative covering one or more VULNERABILITYs.
There are no rows in this table
⁠

Wigan defined one Purpose as
Purpose
Civil Contingencies - Preventing and Mitigating harm to people and households during an emergency.
Powers and Duties
The
Civil Contingencies Act 2004
⁠
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 -
⁠
https://www.legislation.gov.uk/ukpga/2004/36/section/2
⁠
⁠

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
1
Risk Factor
A single fact about a Person or Household that can be combined with others to categorise the risk of a VULNERABILITY , and predict NEEDs
There are no rows in this table
⁠
Wigan defined 15 Risk Factors
1
Risk Factor
Definition.
2
Sight Impaired
A person who has a sight impairment.
3
Receives homecare
A person who is in receipt of domiciliary social care.
4
Hearing impaired
A person who has a hearing impairment.
5
Health Condition
A person known to have a health condition.
6
Care Home resident
A person who is a care home resident.
7
ASD diagnosis
A person known to have been diagnosed with an Autistic Spectrum Disorder.
8
Mental Health diagnosis
A person who is known to have been diagnosed with a mental health condition.
9
Disability
A person known to have a disability.
10
Assistive Technology service
A person who receives an assistive technology service.
11
Single person-household Council Tax discount
A household that receives the single person-household discount to their Council Tax.
12
Assisted refuse collections
A household that is in receipt of the assisted refuse collections service delivered by a local authority.
13
Sheltered Housing
A household that lives in Sheltered Housing.
14
Blue Badge
A person who has been granted a Blue Badge.
15
Mobility issue
A person who has mobility issues.
16
High-rise building
A household that lives in a high-rise building.
There are no rows in this table
⁠

Defining how Risk Factors are applied

The SAVVI Concept Model defines ‘Risk Policy’ as
1
Risk Policy
The Rules by which RISK_FACTORs will be used to prioritise VULNERABILITY risk and predict NEEDs.
There are no rows in this table
⁠
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
At Risk
At Risk and Living Alone
1
Being unsafe during Adverse Weather
ANY of the following Risk Factors:
Assistive Technology service
Receives homecare
Disability
Assisted refuse collections
Blue Badge
Mobility issue
Health Condition
Mental Health diagnosis
ASD diagnosis
Sight Impaired
Hearing impaired
Care Home resident
Sheltered Housing
High-rise building
AND ANY of the following Risk Factors:
Single person-household Council Tax discount
At Risk and Living Alone
2
ANY of the following Risk Factors:
Assistive Technology service
Receives homecare
Disability
Assisted refuse collections
Blue Badge
Mobility issue
Health Condition
Mental Health diagnosis
ASD diagnosis
Sight Impaired
Hearing impaired
Care Home resident
Sheltered Housing
High-rise building
AND NONE of the following Risk Factors:
Single person-household Council Tax discount
At Risk
3
Being unsafe during a Utility outage
ANY of the following Risk Factors:
Assistive Technology service
Health Condition
ASD diagnosis
Mental Health diagnosis
Disability
Hearing impaired
Sight Impaired
Receives homecare
AND ANY of the following Risk Factors
Single person-household Council Tax discount
At Risk and Living Alone
4
ANY of the following Risk Factors:
Assistive Technology service
Health Condition
ASD diagnosis
Mental Health diagnosis
Disability
Hearing impaired
Sight Impaired
Receives homecare
AND NONE of the following Risk Factors
Single person-household Council Tax discount
At Risk
5
Being unsafe during an Environmental or Terrorist threat
ANY of the following Risk Factors:
Assistive Technology service
Receives homecare
Disability
Assisted refuse collections
Blue Badge
Mobility issue
Health Condition
Mental Health diagnosis
ASD diagnosis
Sight Impaired
Hearing impaired
AND ANY of the following Risk Factors
Single person-household Council Tax discount
At Risk and Living Alone
6
ANY of the following Risk Factors:
Assistive Technology service
Receives homecare
Disability
Assisted refuse collections
Blue Badge
Mobility issue
Health Condition
Mental Health diagnosis
ASD diagnosis
Sight Impaired
Hearing impaired
AND NONE of the following Risk Factors
Single person-household Council Tax discount
At Risk
There are no rows in this table
⁠
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
1
Information Type
A generic description of a dataset that one or many organisations may hold, collected for a single PURPOSE.
There are no rows in this table
⁠
Wigan defined their Data Flow Map as
1
Local Authority
Adult Social Care
Health and Social Care Act 2008
Sight Impaired
Receives homecare
Hearing impaired
Health Condition
Care Home resident
ASD diagnosis
Mental Health diagnosis
Assistive Technology service
Mobility issue
2
Local Authority
Social Housing
Housing Act 1985
Disability
Sheltered Housing
High-rise building
3
Local Authority
Council Tax
The Council Tax (Administration and Enforcement) Regulations 1992
Single person-household Council Tax discount
4
Local Authority
Environmental Protection Services
Environmental Protection Act 1990
Assisted refuse collections
5
Local Authority
Mobility services
Disabled Persons' Parking Badges Act 2013
Blue Badge
There are no rows in this table
⁠
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
1
Need
A requirement of a Person or Household that can be addressed.
There are no rows in this table
⁠
Wigan defined 5 Needs for which they can arrange support offers.
1
Need
Definition
2
Enhanced communication
Enhanced communications during an emergency, targeted at those who might otherwise be unable to receive messages given to the general population.
3
Support to evacuate
Support to evacuate, for example to evacuate to a place of safety during an emergency.
4
Support to remain safe at home
Support to remain safe at home during an emergency.
5
Support to protect property
Support, above and beyond that which would be offered to the general population, to protect property from damage, such as placing sandbags over doorways or moving items to the 1st floor elevation or higher.
6
Post-incident support with property damage
Support, above and beyond that which would be offered to the general population, to restore their domestic dwelling from damage to avoid being vulnerable following an emergency.
There are no rows in this table
⁠

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
1
Service
The ability for a Delivery Organisation to carry out one or more predetermined methods designed to deliver an OUTCOME.
There are no rows in this table
⁠
A selection of the Services Wigan can deliver or refer to is listed below.
1
Rescue to a place of safety
Support to evacuate
Fire and rescue service
2
Ambulance transport
Support to evacuate
Ambulance service
3
Bariatric ambulance transport
Support to evacuate
Ambulance service
4
Temporary power supply
Support to remain safe at home
Utilities supplier
5
Medicines delivery
Support to remain safe at home
Pharmacy
There are no rows in this table
⁠

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;
1
Outcome
A possible result that can be achieved by addressing the NEEDs of a Person or Household.
There are no rows in this table
⁠
Wigan have not reached this part of the SAVVI process. We suggest that outcomes could be recorded such as;
1
Outcome
Definition
2
Evacuated to safety
A person or household is now in a place of safety during a civil emergency that necessitates evacuation from their home.
3
Property protected
A domestic dwelling and its contents are protected from damage during an emergency for a household that would otherwise be vulnerable.
4
Post-incident resolution
Property damage caused during an emergency has been resolved or mitigated for a household that would otherwise be vulnerable.
5
Welfare via communications
A person with additional communication needs has made appropriate decisions to safeguard their welfare during an emergency, having received enhanced communications.
6
Safe at home
A person or household remains safe in their home throughout an emergency.
There are no rows in this table
⁠

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
Information Governance Framework
⁠
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 ICO Data Sharing Code of Practice
⁠
⁠
⁠
ICO UK GDPR guidance and resources
⁠
⁠
⁠
Data Protection Act 2018
⁠
⁠
⁠
Government Data Quality Framework
⁠
⁠
⁠
Digital Economy Act 2017 - Code of Practice
⁠
⁠
⁠
GOV.UK Data Ethics Framework
⁠
⁠
⁠
Algorithmic Transparency Standard
⁠
⁠
⁠
ICO Lawful basis interactive guidance tool
⁠
⁠
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 …
1
You can only use the personal data for a new purpose if either
this is compatible with your original purpose,
you get consent, or
you have a clear obligation or function set out in law.
There are no rows in this table
⁠

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
Data Reuse Proposition
⁠
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
1
In Part 1 of the Civil Contingencies Act 2004, Local Authorities in England are defined as “Category 1 Responders”, which gives them a duty to maintain plans for the purpose of ensuring that if an emergency occurs or is likely to occur they able to perform their 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,
Given the law requires this planning, the three purposes listed above are interpreted as implied statutory powers in the Information Commissioner’s Office Lawfulness guidance.
There are no rows in this table
⁠

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
Data Ethics Framework
⁠
, which requires that the processing of Personal Data demonstrates
Accountability
Fairness
Transparency

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.
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