Review of the Private Rented Sector: Volume 4: Bringing Private Sector empty houses into use

6 DATA COLLECTION

6.1 This chapter examines methods to find out about empty private homes at local authority level and the pivotal role of data collection, particularly the Council Tax Register ( CTR) but also other methods ¹⁷ . It is important to note that although the discussion is predicated on establishing a reliable evidence-base on empty private homes as the foundation block for strategy implementation, it is quite possible there will be local authorities who will proceed no further if the outcome of data collection is the conclusion there is a minor or negligible problem that merits no further policy priority.

The Council Tax Register

6.2 The case study analysis highlighted the fundamental importance of data collection to taking action on empty private homes. From a local authority perspective, without at least a reliable estimate of the numbers, the impact and scale of empty private homes cannot be gauged nor an accurate assessment made, of whether they merit any priority for resources and intervention. Without knowledge of location (addresses) it cannot be guaranteed that any supply boost would equate with the location of known housing need. Without knowledge of ownership, targeting owners to offer support or serve enforcement notices cannot be initiated.

6.3 Local authorities rely heavily on the CTR for all these purposes - but, as a revenue collection mechanism, it has intrinsic limitations as a database. It is a large data-set but it is not tenure-marked and it has access constraints. It is also dependent on owners seeking discounts to register empty homes and then to notify the local authority again once they are reoccupied. However, with time and effort, CT data can be refined, cleaned and supplemented by other collection methods.

6.4 To derive the number of private sector homes from the CT register, local authorities must deduct own-stock voids (from internal data or the Scottish Government web site ¹⁸ ) and estimates of RSL voids ¹⁹ to give a residual number equating (approximately) to the number of empty private sector homes. Empty homes which are uninhabitable and subject to closing orders are not liable to CT and are therefore not counted on the CTR. However, these are likely to be few in number and may be identified by cross-reference to lists of BTS housing kept by the local authority. .

6.5 The City of Edinburgh Council exemplified the use of CT data. Housing staff were given addresses from the CT team of every empty property on the CT list and then used local knowledge to remove housing association properties so that private empty homes could be isolated. The resultant information was used to locate areas of empty private housing and, amongst other purposes, to target a mail-shot to owners on how to bring their properties into use.

Use of Council Tax data to identify individual properties

6.6 Survey results and telephone interviews highlighted the constraints that the Data Protection Act 1998 has had on access to CT data for identifying empty private homes. Recent guidance in 2007 from the Information Commissioners Office ( ICO ²⁰ ), whilst not specifically mentioning empty homes, suggested CT data may be used by a local authority for legitimate reasons if it did not result in unfairness or unwarranted detriment to owners. However, a local authority should take its own legal opinion.

6.7 In terms of access to CT data for individual property targeting, different practices operated. Edinburgh, Highland and Manchester Councils were able to obtain address lists from the CTR but these were supplied without owners' names. Correspondence with individual owners was either issued directly by their Finance Department or printed labels for mass mailings were supplied to housing staff. Electronic lists were not handed over. In Newcastle, staff were able to draw on specific rights of access under local government and town planning legislation, provided the data was kept within the Council. Newcastle went further in data use by cross-checking CTR data with Housing Benefit data.

6.8 In other authorities only data by postcode area totals was released. This is helpful in indicating where the greatest number of empty homes occurs but less so for practical project development, particularly in rural areas, where physical survey may be very difficult. In an urban area, postcode area outputs could be less of a problem as street surveys would be possible. Although CT teams were wary of the release of owners' names even to housing colleagues, the Land Register is an alternative public source.

Other data-collection methods

6.9 A wide variety of other methods were used to generate additional empty private homes data to address the limitations of CT data:

Street surveys by local authority staff in urban areas ( e.g. and all described in Annex 2, Islington, Manchester, North London and Newcastle - the last employing evening visits in high student population areas).

• Links with private sector stock condition surveys ( e.g. Islington Council).
• Land Registry to confirm ownership.
• Companies House records to trace names and addresses of directors.
• A joint survey carried out with landowners' representatives ( e.g.CNPA working with the SRPBA and the National Farmers Union Scotland).
• Information from the Planning Service when an application for conversion or change-of-use of an empty home is refused ( e.g. South Oxford).
• Housing benefit data ( e.g. Newcastle).
• Letters to neighbours asking if they know who owners are ( e.g. Newcastle).
• Notifications of empty private homes by staff in other departments.
• Notifications of properties subject to a police Closure Order due to drugs raids ( e.g. Islington).
• Publicity campaigns ( e.g. North London Empty Property Initiative and Kent's No Use Empty' initiative ²¹ ) (See also Annex 2).

Conclusion

6.10 The evidence shows that data gathering to establish the extent of empty homes is a major task in itself but a necessary element in developing a suitable strategic approach that requires time, skills and access to local knowledge to establish reliable empty private home statistics (discussed further in the next chapter).

6.11 The CTR is the prime data source but it has a number of limitations. However, local authorities can pursue other methods to supplement CT data such as awareness-raising campaigns and resource-intensive street surveys in areas where there is a perceived issue. Beyond the collection of "hard" data there is the need, as highlighted in Chapter 3, for knowledge of the reasons owners - landlords and others - leave their property lying empty for long periods. The issue of working with owners is discussed in Chapter 8.

6.12 Like many property-related local authority functions including planning, environmental health and other aspects of private sector housing work, empty homes work is made more difficult by the lack of a comprehensive property register recording ownership and tenure details. However, it is not possible to assess the costs of establishing such a property database against the savings that might be accrued to many local authority service departments.

6.13 An additional conclusion that can be drawn as a consequence of the difficulties inherent in data collection is that prevention is better than cure. There is a strong argument to be made that local authorities should be organised and proactive to making contact with owners of empty homes as soon as possible after they apply for an empty homes discount. This will not just allow information about the location of the property to be captured but, just as importantly, may establish the owner's perspective (assuming a response is forthcoming) on the question of why the house is empty and whether assistance is required to allow it to be reoccupied. Although there is no guarantee such homes would become long-term "empties", this preventative approach would seem to present an "easy win" by identifying properties which are likely to be in better repair condition than those that have been empty for a long period and most likely to have deteriorated into a poor state with high repair or upgrading costs.