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Staying in touch and supporting young people privacy notice

We keep this privacy notice under regular review and it was last updated in August 2021.

This notice explains what personal data (information) we hold about you, how we collect, how we 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 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 (DPA 2018). We are responsible as ‘controller’ of that personal information. Our Data Protection Officer is Benjamin Watts.

The Adolescent Service in Early Help, and The Education People work together collaboratively with schools, colleges, and other settings, to ensure we know the education, employment and training that young people are receiving post-16. This includes young people who are educated at home. We do this so we can identify those who are NEET (Not in Education, Employment or Training) and offer them appropriate and timely support. We also work with schools to identify those pupils pre-16 who may be at risk of becoming NEET when they are post-16. We work in an integrated way with other children’s services teams in KCC and with partner organisations to ensure we deliver the best possible outcomes for children, young people and families in Kent.

Personal information we collect and use

Information collected by us

In the course of tracking the destinations of young people post-16 and providing support to reduce those who are NEET, we collect the following personal information when you and/or your parent/carer and/or your education provider provide it to us:

  • personal information (such as name, address, contact details, date of birth, gender)
  • special category characteristics (such as ethnicity and disability)
  • details of your intended post-16 destination
  • details of any offers of post-16 education or training that have been made to you
  • details of your current, next or most recent education, employment or training destination
  • reasons for requiring further support (such as what is working well and what you are worried about)
  • details of events and services that you access through us

We also obtain personal information from other sources as follows:

  • attendance and exclusion information (such as sessions attended, number of absences, reasons, details to support statutory processes), pupil characteristics, prior attainment data, and unique pupil number, from your school or college
  • KentChoices, our post-16 online application system that The Education People run on our behalf (for more information read the KentChoices privacy notice).
  • involvement with other KCC children’s services teams from our existing records where this may be relevant to the support you receive
  • other local authorities, if you have moved in or out of area
  • National Apprenticeship Service
  • Department for Work and Pensions (DWP).

How we use your personal information

We use your personal information to:

  • undertake our statutory duties around education and training of pupils aged 16+, to support and reduce those not in Education, Employment or Training (NEET)
  • comply with the law regarding data sharing
  • support you to decide what to do after you leave school
  • enable integrated working with other teams and organisations to ensure you receive the right support at the right time
  • plan and provide the most appropriate level of support to you
  • support you to access relevant support, advice, services and groups
  • evaluate and quality assure the services we provide
  • inform future service provision and the commissioning of services
  • analyse service provision and effectiveness, and model patterns of service involvement to support future service delivery planning, view the Pupil Information privacy notice for more details.

How long your personal information will be kept

We will hold your personal information securely and retain it from the child /young person’s date of birth until they reach the age of 25, after which the information is made inaccessible to system users or securely destroyed.

Reasons we can collect and use your personal information

We collect and use your personal information to carry out tasks under our legal obligations, and to carry out tasks in the public interest. We rely on the following legal bases under UK GDPR:

  • Article (6)(1)(c) - Legal obligation: the processing is necessary to comply with the law
  • Article (6)(1)(e) - Public task: the processing is necessary to perform a task in the public interest or for official functions (task or function has a clear basis in law)

When we collect or share special category personal data, we rely upon the following legal bases under UK GDPR:

  • Article 9(2)(f) - Legal claims or judicial acts
  • Article 9(2)(g) - Reasons of substantial public interest. We rely on the ‘safeguarding of children and of individuals at risk’, and ‘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.
  • Article 9(2)(h) - Health or social care
  • Article 9(2)(j) - Archiving, research, and statistics

These legal bases are underpinned by acts of legislation that dictate what actions can and should be taken by local authorities, including: The Education Act 1996, The Localism Act 2011.

Who we share your personal information with

  • teams within KCC working to improve outcomes for children and young people
  • commissioned providers of local authority services (such as youth services, NEET support, mental health services and education services, including The Education People)
  • schools, colleges or training providers that you have attended or may attend in future
  • partner organisations signed up to the Kent and Medway Information Sharing Agreement, where necessary, which may include health visitors, midwives, district councils, housing providers, Police, school nurses, doctors and mental health workers
  • The Department of Education
  • Ofsted (in the event of a local authority inspection of children’s services)

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

KCC has a legal responsibility under section 507B of the Education Act 1996 to track all young people up to the age of 19 (and young adults with learning difficulties or disabilities up to the age of 25). The purpose of collecting this information is to assist the planning of education and training for young people and the support services they require.  We will inform schools and colleges of your current activity once you have left that school or college and we will also work with them to ensure we hold accurate records about what you are doing after you leave school. This is in relation to education, training, employment with training you may be undertaking and whether you are NEET (not in Education, Employment or Training). Some of this information is then shared with the DfE who use the information to plan at a national level.

This information enables KCC to provide and arrange:

  • post-16 education and training provision
  • youth support services
  • careers advice and guidance.

In addition, the DfE advises that schools collect and maintain accurate destination data for each pupil for at least three years after they school, so that they can assess their success in supporting their pupils take up education or training which offer good long term prospects.  To do this your school or college will seek your consent separately.

The Children and Young People (CYP) Integrated Dataset

The CYP Dataset is owned and managed by KCC and contains personal data and special category information about children attending KCC schools, and matches additional personal data from multiple data sources within KCC to the pupils.

The aim of the dataset is to allow statistical analysis and research to:

  • support and inform council transformation by ensuring the holistic characteristics and needs of the child population are fully understood
  • provide appropriate levels of insight, evidence and evaluation in order to embed knowledge and understanding of children and young people’s needs and issues into service programmes and projects, including the commissioning of new services
  • inform future service delivery planning and integrated working in order to improve outcomes for children and young people.

KCC has robust processes in place to ensure the confidentiality of our data is maintained and there are stringent controls in place regarding access and use of the data. The child-level dataset is not shared outside of KCC. All personal data is stored in secured electronic files with restricted access. Only pseudonymised data is used for analysis. Outputs and analysis take the form of aggregated data, and are for the purpose of KCC teams and partners working to improve outcomes for children and young people.

Your rights

Under 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 Commissioner's 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 Information Commissioner's Office (ICO) on individuals’ rights under the UK GDPR.

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.

Who to 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, or write to: Data Protection Officer, Sessions House, Maidstone, Kent ME14 1XQ.

UK GDPR also gives you right to lodge a complaint with the Information Commissioner's website or call 03031 231113.

Read our corporate privacy statement.