This article examines how much ethnicity information Enfield Council supplied about the people who rely on its housing and homelessness services. In each dataset supplied in the Council’s two responses to our Freedom of Information request, between a fifth and three-fifths of records had no usable ethnicity data, and no equality analysis was supplied in either response.
Missing ethnicity data makes it harder to identify unequal outcomes and assess whether different communities are being treated fairly. It does not prove unfair treatment, and the Council may hold other relevant evidence that the request did not capture.
The article covers how much ethnicity data is missing in each dataset, how categories differ between teams, what other information the Council said it does not hold, why this matters under the Equality Act 2010, and what we are asking the Council to do.
The Evidence We Drew On
This article draws on one Freedom of Information request to Enfield Council, “Housing: Allocations, Accommodations, Evictions and Equality”, which two Council teams answered separately.
| Reference | Answered by | Request received | Response sent | Working days | Content used |
| 101002224018 | Housing Assessments and Allocations | 21 April 2026 | 14 May 2026 | 16 | Register applicants and lettings by ethnicity, 2023/24 to 2025/26 |
| 101002221808 | Housing Advisory Service | 21 April 2026 | 19 May 2026 | 19 | Homelessness approaches, relief and main duty, and temporary accommodation by ethnicity |
Both responses arrived within the 20-working-day limit set by the Freedom of Information Act 2000.
All percentages in this article are our own calculations from the Council’s figures.
In this article, “no usable ethnicity data” includes blank entries and responses recorded as “don’t know” or “refused”. These categories have different causes and should also be reported separately: a refusal is an applicant’s legitimate choice, while a blank entry may reflect how a form was completed or recorded.
Ethnicity Is Missing in Every Dataset Supplied
In each dataset supplied in these two FOI responses, at least a fifth of records had no usable ethnicity data. The gaps were largest for households owed the main housing duty and for temporary accommodation placements.
| Dataset | Period | Records | Blank or not provided | Don’t know or refused | No usable ethnicity |
| Housing Needs Register applicants | Financial year 2025/26 | 7,910 | 1,837 | 228 | 26.1% |
| Lettings | Financial year 2025/26 | 548 | 100 | 37 | 25.0% |
| Homelessness approaches | Financial year 2024/25 | 4,844 | 896 | 78 | 20.1% |
| Households owed the relief duty | Calendar year 2025 | 3,450 | 1,191 | 205 | 40.5% |
| Households owed the main duty | Calendar year 2025 | 3,442 | 1,467 | 336 | 52.4% |
| Temporary accommodation placements | Financial year 2024/25 | 1,591 | 885 | 71 | 60.1% |
| Households in temporary accommodation | Snapshot, May 2026 | 3,120 | 953 | 248 | 38.5% |
The datasets use different periods because the two teams supplied them that way: financial years for the register, lettings, approaches and placements, the calendar year 2025 for the relief and main duties, and a single date for the temporary accommodation snapshot.
The definition of the register figures remains unclear. The Council did not say whether they represent a snapshot or all applications active during the year. Temporary accommodation placement figures include internal transfers, so they count placement events rather than unique households.
Some Gaps Are Closing, Others Are Not
The housing register has improved. Records without a usable ethnicity fell from 39.0% in 2023/24 to 26.1% in 2025/26. Homelessness approaches improved too, from 26.2% in 2022/23 to 20.1% in 2024/25.
Other gaps have barely moved. Records without ethnicity stayed at about a quarter of lettings in each of the three years, and at about 60% of temporary accommodation placements in each of the three years.
Different Teams Record Ethnicity Differently
The two replies used different category lists. The allocations team used labels such as “Black/ African/Caribbean/Black British: African”, while the Housing Advisory Service used “Black or Black British – African”, and only the homelessness data separates Kurdish, Turkish and Turkish Cypriot households.
The allocations data also contains overlapping or merged entries, such as both “Arabic” and “Other ethnic group: Arab”, values such as “Mixed Other|Any other Mixed/Multiple ethnic background”, and four register records marked “#N/A” in 2023/24. Different labels do not by themselves mean records cannot be compared, but consistent mapping between systems would make it easier to compare outcomes across stages, while keeping useful detail such as the Kurdish, Turkish and Turkish Cypriot categories.
Information the Council Said It Does Not Hold or Did Not Supply
The Council told us it does not hold several pieces of information needed to explain differences between communities:
- lettings by household type, priority band and homelessness duty
- whether permanent lettings were made inside or outside Enfield
- reports or analyses of why households lose their homes
It also did not supply the ethnicity of households placed outside the borough, or any breakdown of temporary accommodation by type.
The reason for approaching was also blank for 826 homelessness approaches in 2024/25, about one in six.
No Equality Analysis Was Supplied in Either FOI Response
Asked for equality monitoring reports, equality impact assessments or internal analyses from the last three years, the allocations team said the only information it held within the scope of the question was the data it had sent. The Housing Advisory Service marked the question “see attached”, but its attachment contained only data tables.
No analysis of outcomes by ethnicity was supplied in either FOI response. That does not mean none exists anywhere in the Council, but if it does, it should be published.
Why Missing Data Matters in Law
Under section 149 of the Equality Act 2010, the Public Sector Equality Duty, Enfield Council must have due regard to the need to eliminate discrimination and advance equality of opportunity between people of different races, among other characteristics. The law does not require any particular form of monitoring.
The courts have, however, made clear that due regard must be exercised with rigour, and that a public body may need to gather relevant information to meet the duty (R (Bracking) v Secretary of State for Work and Pensions [2013] EWCA Civ 1345). Where a council cannot tell which communities are owed a duty, placed in temporary accommodation or housed, it is hard to see how it can assess whether its policies affect them differently.
On the evidence supplied to us, this raises a serious question about whether the Council has the information it needs to meet the duty in its housing services. It does not show that the duty has been breached.
A standalone equality impact assessment is not itself a legal requirement under the general Public Sector Equality Duty, and government guidance says there is no prescribed process for showing due regard (Government Equalities Office, 2023). The Council must nevertheless give proper consideration to the relevant equality implications of its decisions.
Why the Gaps Exist
Giving your ethnicity is voluntary, and both teams told us so. That is right: no one should be forced to disclose it. But voluntary questions can still produce more complete data when people understand why they are asked and trust how the answers are used.
The responses do not establish why information is missing. Possible explanations include voluntary non-disclosure, incomplete forms, recording practices and differences between systems. The Council should investigate and publish the reasons.
What We Are Asking Enfield Council to Do
We are asking for six practical steps.
- Explain to every applicant, in plain language and community languages, why ethnicity is asked and how it is used, while keeping disclosure voluntary.
- Map ethnicity categories consistently across the register, lettings, homelessness and temporary accommodation systems, while keeping useful detail such as the Kurdish, Turkish and Turkish Cypriot categories.
- Publish blank entries and refusals separately at each stage every year, and set targets to reduce blank entries through better recording and explanation, while respecting applicants’ decisions not to disclose.
- Record priority band, household type and homelessness duty for every letting, so outcomes can be analysed fairly.
- Carry out and publish an equality analysis of allocations and temporary accommodation each year, with small numbers suppressed to protect identities.
- Publish any equality impact assessment of the allocation scheme and placement policy, or explain what equality analysis informed them.
Opportunities: Better Data Is Within Reach
The register shows improvement is possible: the share of records without ethnicity fell by 13 percentage points in two years. The Council should explain what contributed to this improvement and whether those lessons could help other services.
Community organisations can help. Applicants may be more willing to answer equality questions when someone they trust explains why they matter, and organisations working with diaspora communities can carry that message in the languages people speak.
Where This Is Heading
Councils already report the ethnicity of homeless applicants to government in their quarterly homelessness returns, so better local recording would also improve national statistics. As more councils publish local equality data on housing, councils that cannot will find it harder to show their services are fair.
For Enfield, the immediate test is whether its next homelessness strategy commits to measurable equality monitoring. Without that, the gaps in this article are likely to remain.
Conclusion: Gaps Leave Equality Questions Unanswered
In the datasets Enfield Council supplied, a fifth to three-fifths of records had no usable ethnicity data, categories differed between teams, some outcome data was not held, and no equality analysis was supplied. None of this proves unfair treatment. But missing ethnicity data makes it harder to identify unequal outcomes and assess whether different communities are being treated fairly.
We will share this analysis with the Council and local councillors and ask for the steps above. If you work with residents who have used Enfield’s housing services, we would like to hear how equality questions are asked in practice.
If you found this article useful, please share it with others working for fair housing in Enfield.
Frequently Asked Questions
Does Enfield Council record the ethnicity of housing applicants?
Yes, but disclosure is voluntary, and many records have none. In 2025/26, 26.1% of housing register records had no usable ethnicity, and in 2025, 52.4% of households owed the main housing duty had none.
Do I have to tell the Council my ethnicity?
No. Giving your ethnicity is voluntary on both housing register and homelessness applications. The Council collects it for equality monitoring.
Why does missing ethnicity data matter?
Missing ethnicity data makes it harder to identify unequal outcomes and assess whether different communities are being treated fairly, both for the Council and for residents scrutinising it.
Does the law require councils to collect ethnicity data?
The Equality Act 2010 does not require a particular form of monitoring. But councils must have due regard to equality of opportunity, and the courts have said this can require them to gather relevant information.
Has Enfield Council carried out an equality impact assessment of housing allocations?
No equality impact assessment was supplied in these responses. The allocations team said the only information held within the scope of the question was the data provided.
References
Enfield Council (2026a) Response to FOI 101002224018: Housing: Allocations, Accommodations, Evictions and Equality. Request received 21 April 2026. Email from Housing Assessments and Allocations to Diversity Rights, 14 May 2026.
Enfield Council (2026b) Response to FOI 101002221808: Housing: Allocations, Accommodations, Evictions and Equality. Request received 21 April 2026. Email from the Housing Advisory Service to Diversity Rights, 19 May 2026.
Government Equalities Office (2023) Public Sector Equality Duty: guidance for public authorities. Available at: https://www.gov.uk/government/publications/public-sector-equality-duty-guidance-for-public-authorities/public-sector-equality-duty-guidance-for-public-authorities (Accessed: 18 October 2026).
Equality Act 2010, section 149. Available at: https://www.legislation.gov.uk/ukpga/2010/15/section/149 (Accessed: 18 October 2026).
R (Bracking) v Secretary of State for Work and Pensions [2013] EWCA Civ 1345.
Oct 18, 2026
Disclaimer
This article is based on information supplied by Enfield Council under the Freedom of Information Act 2000, accurate to the best of our knowledge at the date of publication. Percentages are our own calculations from the Council’s figures. This article discusses the law in general terms for public information and campaigning purposes and does not constitute legal advice.