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Sleep Well Kent (Bed Poverty) privacy notice

Kent County Council (KCC) 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 collects, uses and is responsible for certain personal information about you. When we collect and use data, 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 any personal information we store. Our Data Protection Officer is Benjamin Watts.

The Financial Hardship Programme delivers schemes and projects to support Kent residents in, or at risk of, financial hardship. The Sleep Well Kent Project is funded from the Residential workstream to support children aged 4-16 years-of-age. The scheme provides them with a suitable bed for individual use, due to the absence of such items caused by financial hardship. The applicants can be referred into the scheme through a professional who has a supporting relationship with the child and/or household.

The personal information we collect and use

In the course of delivering support to you through the Sleep Well Kent Project, we will collect the following personal information when you provide it to us, or when you are referred to us by an agency you are already involved with:

Personal data of adults over 18 years of age:

  • Personal details (such as name, date of birth, address and contact details, NI number and/or carer home office/port number).
  • Personal details and contact details of the person whom you are associated with (if applicable such as, spouse, those living in the same household and the number of children in your care).
  • Organisation name and contact details that you are associated with (if applicable, such as your GP practice, your district or borough council and parish or town council).
  • Financial information such as household income, savings and information related to any support from other services and/or any benefits you are receiving.
  • Information about your current circumstances and why you require assistance (including the bed sharing status of any children in the household).
  • Information about the goods and services you require support with.
  • Information related to our relationship with you (such as agreements, correspondence and meeting notes).

Personal data of children under 18 years of age:

  • Personal details (such as name, date of birth, address and contact details).
  • Personal details and contact details of the person whom you are associated with (if applicable, such as parent/carer, or those living in the same household).
  • Organisation name and contact details that you are associated with (if applicable, such as your school or college, GP practice, your district or borough council and parish or town council).
  • Information about your current circumstances and why you require assistance.
  • Information about the goods and services you require support with, including weather you. currently have access to a bed and if this access is shared access.

Special categories of data

  • Information about your racial or ethnic origin is collected for equality monitoring and evaluation purposes only.
  • Information about health conditions or disabilities that may be relevant to your circumstances or the support you require.
  • Information about your gender is collected for equality monitoring and evaluation purposes only.

We may also obtain personal information from other sources which include:

  • organisations who referred to us on your behalf, including through the ReferKent system.
  • any other services you are receiving support from.
  • commissioned providers and suppliers.

How we use your personal information

We use your personal information to:

  • assess eligibility for support in scope of the Sleep Well Kent Project (including children’s data). The information we use to assess your eligibility is as follows:
    • Financial information such as household income, savings and information related to any support from other services and/or any benefits you are receiving.
  • create a secure and comprehensive record of all the work that we do with and for you:
    • Name, date of birth, address, telephone number, email address and details of other household members (including children, parents/carers).
    • Your NI number OR home office number OR port number.
    • Name and details of supporting organisations or professionals applying on your behalf.
  • fully understand your needs, we collect the following information about:
    • your current circumstances and why you require assistance.
    • the goods and services you require support with.
  • equality monitoring only:
    • Information about your racial or ethnic origin, relevant disabilities, and gender.
  • liaise with agencies, companies, and charities on your behalf:
    • Relevant personal information held on our systems.
  • keep you safe from harm:
    • Information about any health and safety concerns that may be relevant.
    • Respond to enquiries and comments of any concerns.
  • process complaints and compliments regarding the services we have provided.
    • Details contained in your referral records and correspondence received.
  • request and arrange delivery of any awarded provision:
    • Information about your requirements.
    • Delivery address, name, telephone number.
  • evaluate, impact assess, and quality assure the services we provide:
    • Anonymised statistical reports output by our computer systems.
    • Investigate claims of misuse.
    • Create a secure and comprehensive record of your application to the scheme.
    • Investigate claims of the project’s misuse, including spot checks for data accuracy.

Reasons we can collect and use your personal information

When we collect your personal data for the purposes described above, we rely on:

  • the lawful basis of public task in Article 6(1) (e) in General Data Protection Regulation (GDPR): processing is “necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller”.

In this case the authority to process referrals is vested in Kent County Council by Children Act 1989 Section 17 Sub-section (1) Clause (a) and (b) and Care Act 2014 Section 1, Sub-section (1), (2) Clause (b), (c), (f) and (g).

When we collect your ‘special categories of personal data’, (such as health and disability, race and ethnicity, ) we rely on the following legal basis:

  • Article 9(2)(g) – Reasons of substantial public interests. We rely on the ‘equality of opportunity or treatment purpose’ condition from Schedule 1 of the Data Protection Act 2018 when relying on Article 9(2)(g) to process your special category data.

We take the following appropriate safeguards in respect of your special category data when relying on the conditions above. We have:

  • an Appropriate Policy for Lawful Processing which explains how the data protection principles are secured when using special category information. This policy is retained throughout the time we use your data and for six months after we cease to use it
  • 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 for any reasons deviating from the periods in our retention schedule.

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 work transparently with you at all times.

If you do not provide your data, it will limit the effectiveness of the services and support that we are able to offer you.

How long your personal data will be kept

We will only keep the personal data that supports your application for as long as it is needed for the purposes of delivering the project and for audit purposes.

Details of all financial transactions on our accounts are held in line with legislative requirements for the current financial year plus 6 further financial years.

Information collected to support the implementation of the Sleep Well Kent (Bed Poverty) Project where application is unsuccessful will be kept for 12 months from the date of the application being rejected, after which the data is securely disposed of. We are re-examining unsuccessful applications if eligibility criteria changes.

Information collected to support the implementation of the Sleep Well Kent (Bed Poverty) Project where application is successful will be kept for 6 years from the date of the application being approved, after which the data is securely disposed of.

See the Sleep Well Kent (Bed Poverty) Project retention period AS4.12.22 and AS4.12.23 in our retention schedule for more information.

For the purpose of referring individuals through the ReferKent system, personal information will be anonymised after six months from the date of the referral being made. See ReferKent retention period AS4.12.17 in our retention schedule for more information.

Who we share your personal information with

In the course of providing and administering your application for support, depending on your circumstances we will collect information from, or share it with the following third parties:

  • Teams within KCC working to improve outcomes for people (such as Social Services, Invicta Audit and Counter Fraud);
  • Other supporting professionals who are supporting your application
  • Other local authorities or councils (such as borough, city, district, parish and town councils)
  • External providers including Cantium Business Solutions Ltd (software support), Agilisys LTD (Kent County Council’s contact centre provider).
  • Commissioned providers such as TFS
  • Partner agencies, such as volunteer organisations and statutory organisations.
  • Commissioned suppliers to conduct evaluation, impact assessments and quality assurance on the service we provide.

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

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 you 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. 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, 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

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.