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Sanctuary Access for Eligible Residents (SAFER) privacy notice for parents and carers

We keep this privacy notice under regular review and it was last updated on 10 October 2023.

Kent County Council respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

Who we are

Kent County Council (KCC) collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the United Kingdom General Data Protection Regulation (‘UK GDPR’) and the Data Protection Act 2018. We are responsible as ‘controller’ of that personal information. Our Data Protection Officer is Benjamin Watts.

The SAFER Scheme is KCC's sanctuary offer to victims and survivors of domestic abuse. Sanctuary is where security elements and adaptations are made to properties to improve safety and enable victims and survivors to remain in their own home, with an offer of support, where it is safe to do so and where the perpetrator does not live.

The SAFER Scheme comprises of 3 elements:

  1. A single point of access - to receive, triage and refer on applications to service providers. This is delivered by Victim Support.
  2. Property security measures - delivering a property assessment, supply and installation of security measures to homes. This is delivered by 24-7 Locks Ltd.
  3. Package of support - providing specialist domestic abuse support to survivors (adults and children) residing in the household. This is delivered by different providers across the county - Oasis Domestic Abuse Support, Clarion Housing Group, Look Ahead Care and Support and Project Salus.

The personal information we collect and use

Information collected by us

In the course of relevant activities, we collect the following personal information when you provide it to us:

  • Name, gender, date of birth, address, contact details, number of occupants in the household and their ages (including children), tenure status, property type.
  • Referrer details (name, email, job title and organisation).
  • Information about your current circumstances.
  • If you have had previous sanctuary measures applied to your house (including information around who and when these were installed).
  • Level of risk of harm (as measured by the Domestic Abuse, Stalking and Honour Based Violence (DASH) form or similar).
  • Details of applied security measures.
  • Date of onward referral (to property security and support providers).
  • Any information you give us in response to a survey request from us about your views on the service.

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:

  • Ethnicity.
  • Declaration of a disability.
  • Declaration of co-occurring condition (mental health or substance use needs).

The above ‘special category data’ is collected only for equality monitoring and anonymised for any reporting purposes.

How we use your personal information

We use your personal information to:

  • create a secure and comprehensive record of your application by uploading the information to a record management system and maintain a comprehensive record of all the work completed under the SAFER Scheme.
    • Name, gender, date of birth, address, contact details, number of occupants in the household and their ages, tenure status, property type, referrer details, information about your current circumstances, previous sanctuary measures, level of risk of harm, details of applied security measures, date of onward referral.
  • make contact to progress your application for the SAFER Scheme.
    • Name, contact details, referrer details
  • understand your circumstances and conduct an assessment to deliver a SAFER Scheme, tailored to your households needs and level of risk.
    • Number of occupants in the household and their ages, property type, information about your current circumstances, previous sanctuary measures, level of risk of harm.
  • liaise with organisations and support providers on your behalf.
    • Number of occupants in the household and their ages, information about your current circumstances, level of risk of harm, applied security measures, date of onward referral.
  • investigate and process complaints and compliments regarding the services we have provided.
    • Name, address, contact details, information about your current circumstances, level of risk of harm, details of applied security measures, date of onward referral, Any information you give us in response to a survey request from us about your views on the service
  • create reports for equality monitoring, statistical research, analysis and evaluation of the service. All services provided by KCC are ultimately funded by public money, and so these services must always be thoroughly evaluated to ensure they are achieving positive outcomes for people, and the money is well spent. These reports will be anonymised, and therefore individuals will not be identifiable.

The sharing of information facilitates a joined-up approach with partner agencies, to provide you with the best possible support and customer experience.

How long your personal data will be kept

As per the KCC data retention schedule and in line with domestic abuse data set retention, data for the SAFER scheme will be held for 5 years for information processed at the single point of access, information held by the security provider and data collected for the support element of the scheme. Code reference: AS6.1.5 (RL2) - domestic abuse data.

Who we share your personal information with

We will routinely share your personal information listed in the ‘personal information we collect and use’ section with the agencies who deliver the 3 elements of the SAFER Scheme, all are signatories to the Kent and Medway Information Sharing Agreement (the KMISA) and a record of processing is kept for this sharing. The agencies are:

  • Victim Support
  • 24-7 Locks Ltd
  • Oasis Domestic Abuse Support
  • Clarion Housing Group
  • Look Ahead Care and Support
  • Project Salus.

We will share personal information with law enforcement or other authorities if required by applicable law or in connection with legal proceedings.

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.

Reasons we can collect and use your personal information

When we collect your personal data, we rely on the following as the lawful basis on which we collect and use your personal and special categories of personal data:

  • Article 6(1)(a) The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Article 9(2)(a) The data subject has given their explicit consent for one or more specified purposes.

We take the following appropriate safeguards in respect of your special category and/or criminal convictions data when relying on the conditions above:

  • this policy is retained throughout the time we use of your data and for 6 months after we cease to use it.
  • we have a Retention Schedule which explains how long data is retained.
  • we maintain a record of our processing in our ‘Record of Processing Activities’ and record in it any reasons for deviating from the periods in our Retention Schedule.

The provision of personal information is required from you to enable us to make contact, understand your circumstances and conduct an assessment to deliver a SAFER Scheme, tailored to your households needs and level of risk.

As we have a statutory basis for collecting your personal data if you do not provide your personal data, we may not be able to provide the SAFER Scheme service to your household.

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.

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.