Leeds City Council and the alcohol licensing data matrix 

The challenge: 

Within Leeds, there are some areas which have high levels of deprivation, as well as high levels of alcohol related harm and alcohol related anti-social behaviour (ASB). In some cases, this was leading to street drinking and domestic abuse. The council was particularly concerned about the impact this was having on local residents and wanted to take action through the licensing process to support residents. However, council officers were finding it difficult to access crime data, due to low reporting of crime in areas of high deprivation. As such, it was difficult to justify introducing a cumulative impact assessment, which is an evidence based tool that councils can use to limit the density of alcohol licensed premises where they are negatively affecting the licensing objectives under the Licensing Act 2003 (one of which is the prevention of crime and disorder). 

The solution: 

Directors of Public Health were made a responsible authority under the Licensing Act in 2011. Public health teams have access to numerous key data sources which are not easily accessible to other responsible authorities. This data can be used to inform the licensing process by identifying potentially harmful applications and providing the evidence base to support decisions on alcohol licences. 

Therefore Leeds’ licensing and public health teams worked together to develop an alcohol licensing data matrix. This matrix demonstrates where a locality is at risk of health harms from licensing activity by ranking localities against each other through comparing different data sets. The data sets are:  

• deprivation score 
• alcohol specific admission all ages - any hospital 
• alcohol related admission all ages - any hospital 
• population 16 and under 
• audit-C scoring >7 more - increasing risk: GP recorded (this is an alcohol harm assessment tool that GP’s use)  
• looked after children 
• young people Not in Education Employment or Training (NEET) 
• youth offences
• percentage who did not achieve grade 9-5 in English and Maths in Leeds schools 
• alcohol licensing - Off licensed premises density
• alcohol licensing - On licensed premises density
• alcohol related anti-social behaviour
• alcohol flagged total crime - Excluding violent crime
• alcohol flagged violent crime
• drunk and disorderly or over prescribed limit 
• clients who use alcohol services 
• licensing risk scores.

In 2021, Leeds updated the matrix and it is now based on a larger area, known as a Middle Layer Super Output Area (MSOA).  A MSOA is a tool often used in public health, and is a geographic area designed to improve the reporting of small area statistics in England and Wales. The minimum population is 5,000 and the mean is 7,200. The Organisation Data Service publish files created on their behalf by the Office for National Statistics, which link postcodes to the Middle Layer Super Output Area. This enables the matrix user to input a postcode, for this to be linked to a MSOA and the data for that MSOA to be ranked against all other areas in Leeds. 

By entering the postcode for the premises seeking a licence, the matrix displays the ranking of this MSOA against the data sets listed above, as well as providing an overall ranking against all 107 MSOA areas in Leeds.  

Crucially, the datasets are weighted according to their relevance to the licensing objectives. For example, the datasets related to alcohol related crime, anti-social behaviour, and off licence density are given greater consideration in the licensing process than the datasets such as deprivation, because of their closer alignment to the licensing objectives, which are: the prevention of crime and disorder, public safety, the prevention of public nuisance and the protection of children from harm. 

The impact: 

The information provided by the matrix allows licensing subcommittees to consider the application in the context of the local areas and the problems being experienced by the population. This has helped committee members to make reasoned decisions based on quantitative data, as well as other anecdotal evidence which may be received through the licensing process. This is particularly helpful when the committee decides to refuse an application.  

The matrix has also assisted the council with their cumulative impact assessments, which have been referenced in their 2023 statement of licensing policy. For example, in the Armley area of Leeds, the matrix was instrumental in establishing an off licence only CIA to tackle a significant problem of off licence saturation and street drinking in the area. Without the matrix, the council would have had to rely on crime statistics alone, which is problematic as the Armley area tends to have lower than average reporting of crime incidents, and therefore the licensing authority would be less able to tackle this issue. The matrix has also assisted licensing officers with representations they may wish to make against a particular licence application. 

Crucially, the matrix is easy to use and displays the data in a simple format. This means it is a helpful tool for officers within the council, elected members, and external partners such as the police. It has also been used by colleagues in the public health team to help target which GP surgeries should offer liver treatment services. 

Lessons learned: 

A multiagency, partnership approach is essential if the council wants to refuse a licence application due to concerns about its impact on the licensing objectives. Whilst the data provided by the matrix is useful, it only gives a broad picture and is often not enough on its own. Committee members still need to hear from local residents and businesses about what it is like to live and work in the area, as well as from the neighbourhood policing team about alcohol related disorder in the area. Representations from ward members are also key and can help to provide specific, local information which the matrix cannot.  

More widely, to address alcohol related harms more robustly, it would help if the Licensing Act 2003 was amended to include health as a licensing objective.