Early help and preventative services privacy notice

We keep this privacy notice under regular review and was last updated in December 2022.

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 (DPA 2018). We are responsible as ‘controller’ of that personal information. Our Data Protection Officer is Benjamin Watts.

Early Help and Preventative Services, part of Integrated Children's Services, comprises a range of services that offer universal, additional, intensive and specialist support to children, young people and families. This support is offered in our open access Children’s Centres and Youth Hubs, our Early Help Units, Youth Justice Units, Pupil Referral Units, and Inclusion and Attendance services, and may be provided face-to-face or virtually. 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 providing advice and support for a child, young person and their family we collect the following personal information when you provide it to us:

  • personal information (such as name, address, contact details, date of birth gender)
  • special category characteristics (such as ethnicity and disability)
  • reasons for support (such as what is working well and what you are worried about)
  • assessment and plan information (such as further details of your issues and challenges, and how we are going to work together to bring about the changes you want to see)
  • details of events and services that you access through us
  • recordings of phone calls to the Front Door service.

We also obtain personal information from the following other sources:

  • details of any criminal offences (such as youth offending, domestic abuse, young person missing from home, crime and anti-social behaviour) from the Police
  • details of victims of youth crime from the Police (where consent has been given)
  • attendance and exclusion information (such as sessions attended, number of absences, reasons, details to support statutory processes), pupil characteristics, and unique pupil number, from your child’s school
  • involvement with other KCC children’s services teams from our existing records
  • details of adults out of work or at risk of financial exclusion or young people at risk of worklessness from Department of Work and Pensions
  • Information about your additional requirements from midwives and health visitors
  • housing information from district and borough councils

How we use your personal information

We use your personal information to:

  • 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 and your family
  • support you to access relevant support and advice services and groups
  • undertake our statutory youth justice duties, to support young people within the criminal justice system and reduce youth offending (and involve victims of crime in restorative approaches as requested)
  • undertake our statutory duties around compulsory school attendance
  • undertake our statutory duties around education and training of pupils aged 16+, to support and reduce those not in Education, Employment or Training (NEET)
  • undertake our statutory duties to refer families as required to local housing authorities to reduce homelessness
  • fulfil the requirements of the national Troubled Families Programme, through an outcomes framework which describes the range of support we offer in Early Help and the difference that support can make
  • evaluate and quality assure the services we provide, including seeking your feedback on the services you and your family have received
  • analyse service provision and effectiveness, and model patterns of service involvement to support future service delivery planning (see the Pupil Information privacy notice for more details)
  • inform future service provision and the commissioning of services
  • register your family at your local Open Access Children’s Centre/Youth Hub so that additional support can be accessed easily
  • inform you about forthcoming events/activities in Children’s Centres or Youth Hubs in relation to the services we provide to you
  • register your family with the Speech and Language Service if attending the Cygnet Parenting Programme
  • inform/register education settings for forthcoming events, activities, and support materials where applicable.

Reasons we can collect and use your personal information

When we collect or share your personal data, we rely on the following legal bases:

  • Article(6)(1)(c) - legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations)
  • Article (6)(1)(e) – public interests: 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).

If we need to collect special category (sensitive) personal information, we rely upon:

  • 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)(f) - Legal claims or judicial acts

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
  • Crime and Disorder Act, 1998
  • Police and Criminal Evidence Act, 1984 (PACE)
  • The Localism Act, 2011
  • Homelessness Reduction Act, 2017
  • Part 5 of the Digital Economy Act 2017.

How long your personal data 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.

Recording of incoming phone calls to Front Door are retained from the date of call + 3 months, after which the information is securely destroyed.

Who we share your personal information with

  • Teams within Kent County Council working to improve outcomes for children and young people
  • Commissioned providers of local authority services (such as family support services, youth services, young carers support, NEET support, mental health services and education services)
  • Schools
  • 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
  • Government Departments including the Department of Education, Department of Work and Pensions, Ministry of Justice, Ministry of Housing, Department of Levelling Up, Housing and Communities
  • Ofsted and Her Majesty's Inspectorate of Probation (HMIP) (in the event of a local authority inspection of children’s services or youth justice services)

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

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 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 Commissioners Office (ICO) on individuals’ rights under 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.

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.

The UK GDPR also gives you right to lodge a complaint with the Information Commissioner, who may be contacted online or by telephone on 03031 231113.

Read our corporate privacy statement.