Household Support Fund privacy notice

We keep this privacy notice under regular review and was last updated on 6th November 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

This notice is for applications to the Household Support Fund.

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 for the purposes of those laws. Our Data Protection Officer is Benjamin Watts.

Our Household Support Fund (HSF) helps people who are having serious difficulties managing their income due to the increases in cost of living. We offer our help in the form of a one-off award and wherever possible we want to help direct you to additional initiatives, both locally and nationally and other sources of support and advice.

Personal information we collect and use

Information collected by us

While working with you, we will collect the following personal information when you provide it to us:

Personal data

your name, gender, address, telephone number, email address, date of birth and details of other household members (including children)
your National Insurance Number
financial information such as income, benefits and work status
purchase receipts and payslips
supporting organisations or professionals applying on your behalf
information about your current circumstances and why you require assistance
information about the goods and services you require support with.

Special categories of personal data

information about benefits received because of health conditions or disabilities.

Collecting and sharing your personal information

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

borough councils, housing associations and landlords
Department for Work and Pensions (DWP)
HM Revenue & Customs
external providers including Firmstep LTD (case management software), Cantium Business Solutions Ltd (software support), Agilisys LTD (Kent County Council’s contact centre provider), Money and Pensions Service (MaPS) to access the Money Adviser Network (MAN) (this is a service to refer individuals to debt agencies so that they can obtain free financial advice)
internal services such as Social Services, Invicta Audit and Counter Fraud
partner agencies, such as volunteer organisations and statutory organisations
other supporting professionals who are supporting your application
additional providers such as Wonde and Blackhawk for the administration of awarded goods.

Each organisation listed above will ensure they have the relevant agreements in place to be able to process your personal information.

We will share your personal data with the National Fraud Initiative, which is administered by the Cabinet Office, for the purposes of assisting the prevention and detection of fraud.

Any personal data that is supplied as evidence to support applications can be completed either by :

securely using the application platform (Firmstep)
using free alternative secure email (encrypted)
tracked secure postal deliveries
via non secure email (using personal email accounts)

We will share your personal data with the Kent Intelligence Network (KIN) to detect, prevent and deter fraud and corruption affecting Kent authorities’ public services. View the KIN privacy notice for more information.

Any personal data that is supplied as evidence to support applications can be completed either by:

securely using the application platform (Firmstep)
using free alternative secure email (encrypted)
tracked secure postal deliveries.

This data sharing enables us to verify the information provided when processing your application, arrange or provide the support needed and to reduce the risks of fraud.

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.

How we use your personal information

We use your personal information to:

create a secure and comprehensive record of all the work that we do with and for you:
- your name, address, telephone number, email address, date of birth and details of any other household members (including children)
- National Insurance Number
- organisations supporting your application and circumstances
fully understand your needs:
- information about you and your circumstances
- information about your requirements
equality monitoring only:
- information such as racial or ethnic origin, religious or philosophical beliefs, your sexual orientation
process your application for emergency welfare assistance and support to reduce hardship and to come to an appropriate decision based on the information provided throughout the application process:
- your name, address, telephone number and date of birth
- National Insurance Number
- organisations and supporting professional involvement
- circumstances of crisis
- information about any health conditions or disabilities that may apply to you, including your mental health
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
process complaints and compliments regarding the services we have provided
- details contained in your HSF records and correspondence received
request and arrange delivery of any awarded provision:
- name, address, telephone number
- information about your requirements
analyse the service that we are providing:
- anonymised statistical reports output by our computer systems
Investigate claims of HSF misuse.

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

As part of the process of applying for support through HSF, the application form will compare answers you provide against the eligibility criteria listed on the HSF webpage. Applications which do not meet these eligibility criteria may be screened out (declined) and redirected to a webpage containing information about other forms of support which might be suitable. We will not hold any data from applicants that are unable to progress an application through to submission.

Should an applicant be unable to progress their application and feel they meet the criteria for an award through HSF funding, an appeal can be made using the appeal process outlined on the Household Support Fund webpage. All appeals are completed by human processing.

Applications submitted to the scheme will be subject to human processing. Further eligibility checks will be completed, and the information provided verified, prior to a decision being reached.

How long your personal data will be kept

Records will be retained for no longer than 6+ current financial years from the date of application before the records and all data we have in it is permanently deleted from its secure storage.

For the purpose of referring individuals to MaPS for the MAN service, a consent log will be retained for no longer than 1+ current financial year from the date of application before the records and all data we have in it is permanently deleted from its secure storage (as per KCCs Retention Schedule record AS4.12.17).

Reasons we can collect and use your personal information

When we collect your personal data, we rely on:

Article 6(1)(e) - 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 as the lawful basis on which we collect and use your personal data.

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

Article (9)(2)(g) - processing is necessary for reasons of substantial public interest (Statutory and government purposes).

We rely on the health or social care purpose conditions from Schedule 1 of the Data Protection Act 2018 when relying on Article(9)(2)(h) 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.

Your rights

Under 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

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
in the instance of being referred to MaPS for the MAN service, you will be entitled to withdraw your consent to the referral at any time by contacting the KSAS team. The withdrawal of consent would not affect the lawfulness of the processing that took place before its withdrawal.

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 GDPR.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used/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.

GDPR also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted on 0303 123 111.

Read our corporate privacy statement.