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The Hardelot Centre privacy notice

We keep this privacy notice under regular review and was last updated on 13 May 2024.

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

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 Hardelot Centre provides residential school trips in France.

The personal information we collect and use

Information collected by us

In the course of providing school trips we collect the following personal information when you provide it to us:

  • contact details for the school and trip leader, and names of accompanying staff.
  • name of pupils and their year group.
  • contact details provided by the customer when completing the online enquiry form.

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:

  • to provide catering, we will require information on allergies and dietary requirements (including religious diets). The school may also provide us with relevant medical information for pupils that are attending the centre.

How we use your personal information

We use your personal information to:

  • provide accommodation and meals on site.
  • book external activities and transport
  • contact customers requesting information about our services.

Reasons we can collect and use your personal information

We rely on Article 6 (1) (b) Contract - processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

We rely on Article 9 (2) (g) Substantial Public Interest – processing is necessary for reasons of substantial public interest

We rely on the ‘statutory and government purposes’ and ‘safeguarding of children and individuals at risk’ conditions from Schedule 1 of the Data Protection Act 2018 when relying on Article (9) (2) (g) to process your special category data.

We have an appropriate policy document in place:

  • this policy is retained throughout the time we use 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 allergy information is required from you to enable us to provide catering services. We cannot provide catering services without this information. Health information that may be provided by the school will be treated confidentially and will be used to ensure pupil and staff safety whilst on site.

How long your personal data will be kept

We will hold your personal information for:

  • children’s data will be kept for 1 month after the conclusion of the trip.
  • contact details for the school and trip leader will be kept for 3 years.

Who we share your personal information with

We routinely share:

  • the trip leader and school name with French activity providers.
  • the participants' names to transport providers when booking a French coach.
  • anonymised dietary requirements to restaurants when booking a French restaurant.

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.

We transfer your data to the following countries or organisations outside the UK:

As the centre is based in France, we will be processing your information in France but all information will remain on KCC equipment and servers. France has an adequacy decision issued by the Secretary of State, a copy of which can be obtained by visiting the ICO website.

Your rights

Under the UK GDPR you have a number of rights which you can access 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
  • 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.

Depending on our reason for using your information you may also be entitled to:

  • object to how we are using your information
  • 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
  • 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.

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.

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.

For further information read our privacy statement.