ReferKent privacy notice
We keep this privacy notice under regular review and it was last updated in April 2024.
This notice explains what personal data (information) we hold about you and how we collect, use and may share information about you. We are required to give you this information under data protection law.
Who we are
Kent County Council (KCC) collects, uses and is responsible for collecting certain personal information about you. When we do so we are regulated under the General Data Protection Regulation (‘UK GDPR’) and the Data Protection Act 2018. We are responsible as ‘controller’ of that personal information for the purposes of those laws. Our Data Protection Officer is Benjamin Watts.
KCC’s ReferKent platform is an online referral platform that aims to mitigate the action of signposting. It helps people get the support and guidance they need in a timely way, to alleviate hardship. It allows a direct referral to be made to a network of organisations who have onboarded to the ReferKent platform. So that the referral can be made, personal information is collected by KCC and its ReferKent partner organisation’s and shared.
The personal information we collect and use
Information collected by us
Information collected by us:
Through a referral being made on your behalf, we collect the following personal information when you provide it to us:
- Your name, post code, telephone number and/or email address.
- A reason why your referral is being made.
We also collect the following ‘special category data’ (personal data which is more sensitive and is treated with extra care and protection) when you provide it to us:
- Information about health conditions or disabilities that may be relevant to your circumstances or the support you require.
- Information about racial or ethnic origin is collected for equality monitoring and evaluation purposes only.
- Information about gender is collected for equality monitoring and evaluation purposes only.
- Other relevant information about your current circumstances and why you require a referral.
Collecting and sharing your personal information
In the course of making a referral we, along with ReferKent partners, will collect information form you this will be shared between us and the third parties who make and receive referrals through the ReferKent platform.
View the list of organisations who can make and receive referrals through ReferKent.
We routinely share:
- your name, form of contact (for example, telephone number, email address or address), type of issue (from a drop-down selection), a brief description of the reasons for requiring a referral, which may include sensitive personal data (such as health data) depending on the nature of the referral.
with:
- partner agencies, such as volunteer organisations and statutory organisations (for example, district councils, borough councils, housing associations, Department for Work and Pensions (DWP)) who may receive your referral and provide support
- external providers including Viccari Wheele Ltd (referral software).
We have a data sharing agreement in place with agencies who process your data on our behalf.
We will share personal information with our legal and professional advisers in the event of a dispute, complaint, or claim. We rely on Article 9(2)(f) where the processing of special category data is necessary for the establishment, exercise, or defence of legal claims or whenever courts are acting in their judicial capacity.
How we use your personal information
We use your personal information to:
- create a secure record of the referral that is being made on your behalf
- fully understand your needs about your current circumstances and why you require the support the referral is made for
- hold your referral on a UK based secure referral platform that works in accordance with UK GDPR
- analyse the service that we are providing through anonymised statistical reports output by our computer systems.
The sharing of information facilitates a joined-up approach with partner agencies, to provide you with the best possible advice and support.
Reasons we can collect and use your personal information
When we collect your personal data, we rely on:
- public task Article 6(1)(e) as our lawful basis to collect and use your personal data
- substantial public interest Article 9(2)(g) as the lawful basis on which we collect and use your special categories of personal data
- the ‘equality of the opportunity or treatment purpose’ condition from Schedule 1 of the Data Protection Act (‘DPA’) 18
- Article 9(2)(g) condition in the Data Protection Act 2018 to process your special category data.
As we have a statutory basis for collecting your personal data, we do not need to ask for your permission to collect and share it, however we will only ever share your data on a basis of need, in line with legislation and will always work transparently with you.
If you do not provide your data, it will limit the effectiveness of the services and support that we and our parent organisations are able to offer.
How long your personal data will be kept
For the purpose of referring individuals through ReferKent, personal information will be anonymised after six months from the date of the referral being made. Please see the ReferKent retention period AS4.12.17 in our retention schedule for more information.
We will hold your personal information for 6 months. Please see ReferKent retention period AS4.12.17 in our retention schedule for more information.
Your rights
Under the UK GDPR you have rights which you can exercise free of charge which allow you to:
- know what we are doing with your information and why we are doing it
- ask to see what information we hold about you (subject access request)
- ask us to correct any mistakes in the information we hold about you
- object to direct marketing
- make a complaint to the Information Commissioners Office
- withdraw consent at any time (if applicable)
Depending on our reason for using your information you may also be entitled to:
- ask us to delete information we hold about you
- have your information transferred electronically to yourself or to another organisation
- object to decisions being made that significantly affect you
- object to how we are using your information
- stop us using your information in certain ways
We will always seek to comply with your request however we may be required to hold or use your information to comply with legal duties. Please note, your request may delay or prevent us delivering a service to you.
For further information about your rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the United Kingdom General Data Protection Regulation.
If you would like to exercise a right, please contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk.
Your right to withdraw your consent
Where we rely on your consent to process your personal information, you can withdraw your consent to our use of your data at any time. To do this you can email the ReferKent team at referkent@kent.gov.uk who will ensure that your data has been withdrawn on the platform.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Contact
Please contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.
You can contact our Data Protection Officer, Benjamin Watts, at dpo@kent.gov.uk.
UK GDPR also gives you right to lodge a complaint with Information Commissioner, who may be contacted via the Information Commissioner's website or call 03031 231113.
Read our corporate privacy statement.