Decision details

To enter into a Deed of Variation of Cheltenham Borough Council’s contract with North and West Gloucestershire Citizens Advice Limited to enable personal data to be shared with the Council for data reporting purposes.

Cheltenham Borough Council (CBC) currently commissions North and West Gloucestershire Citizens Advice Limited (Citizens Advice) to provide debt and welfare benefits advice, financial inclusion support, and housing rights advice. Some of the outcomes achieved by Citizens Advice are reportable homelessness prevention outcomes which CBC could report to the Ministry of Housing, Communities and Local Government (MHCLG) as part of our quarterly statistical homelessness reporting requirements.

In order for CBC to report these outcomes to MHCLG, it is necessary for CBC’s Housing Options Service to verify that this data has not already been captured elsewhere by the Housing Options Team as part of their own homelessness prevention outcomes. This will therefore mean cross-referencing personal data, such as names, dates of birth, etc.

The decision to enter into a Deed of Variation to CBC’s contract with Citizens’ Advice will ensure that there is a contractual agreement in place for this personal data to be shared between the two organisations in order for the data to be verified as a new outcome, before CBC reports these outcomes to MHCLG.

Not to vary CBC’s contract with Citizens Advice. This is rejected for the reasons set out above – i.e. it is in CBC’s interests to report to MHCLG on all the homelessness prevention outcomes it is achieving, whether these are delivered in-house through our Housing Options Service, or commissioned through our debt, welfare benefits and housing rights advice services.

A Data Impact Assessment (DIA) was completed jointly in May 2026 with Officers from CBC’s Governance Team as part of CBC’s preparatory work ahead of re-tendering our advice contract, which is scheduled to begin from 1st April 2027. Given that the data to be shared under the existing contract is exactly the same as that which is planned for our future advice contract, the DIA is equally relevant for this variation to our current contract with Citizens Advice.