Kara Project privacy notice
We keep this privacy notice under regular review and was last updated on 19 April 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.
Please be aware the KARA Service will close on 30 April 2023. You should have been contacted with further information regarding the closure and what this will mean for you. if you have not received a phone call or letter regarding these changes and would like to speak to someone, please contact firstname.lastname@example.org. If you are a resident that is eligible for Care Act care and support, you will still be able to receive support from the KARA Service. Please note that there may be a change of provider for the KARA service when the Technology Enabled Care Service launches in September 2023. If you are a resident and do not have eligible needs for care and support under the Care Act, you can have the device collected, factory reset the device and keep it for personal use, or take out a private subscription with Alcove to continue the KARA service.
Who we are
Kent County Council 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 Kara project is a 3 year project where KCC is working with Alcove Limited to provide a service designed to support you during and after the COVID-19 (coronavirus) pandemic. The project will provide you with technology, in the form of a care phone, that enables you to make and receive voice and video calls. The purpose of the project is to ensure you continue to receive the care and support you need whilst mitigating the impact COVID-19 (coronavirus) is having on support services within the county.
Personal information we collect and use
Over the course of the Kara Project, Kent County Council may collect the following personal information when you provide it to us:
- personal information, for example your social care ID, name, address, telephone number, date of birth, gender
- contact details for members of your family and support network
- any information you give us in response to a survey request from us about your views on the service / devices (where applicable).
In the course of working with you, we collect the following personal information when you provide it to us:
- your racial or ethnic origin, religious or philosophical beliefs, collected only for equality monitoring and anonymised for any reporting purposes
- your sexual orientation, collected only for equality monitoring and anonymised for any reporting purposes
- any health conditions or disabilities that may apply to you
- you and your circumstances
- any health and safety concerns that may be relevant
- your needs and wishes.
Collecting and sharing your personal data
In the course of working with you for the Kara Project, Alcove will continue to supply the information on the usage of the devices to KCC. This will enable us to monitor the effectiveness of the devices and how they are being used across different areas of the county.
Alcove will provide summary data at the individual level through the report to KCC on the following:
- names of clients (provided by KCC initially)
- total number of inbound and outbound calls; by provider, responder (e.g. friend, family member), and concierge
- average duration of calls; by provider, responders, concierge
- the number of audio and video calls.
KCC and Alcove will not at any point have access to or record the content of any calls, either telephone or video.
Alcove receives alerts from your device for certain situations which may prompt investigating to ensure your wellbeing (e.g. not answering when called). These alerts and the associated data will be shared with your family members if they have elected to be the primary person to check on you and resolve any alerts triggered. You will be asked to verify that you consent to the identified family member taking on this role, and have this information shared with them.
Evaluating the service
All services provided by KCC are ultimately funded by public money, and so these services must always be thoroughly evaluated to ensure they are achieving positive outcomes for people, and the money is well spent.
The summary data will be used for evaluation purposes only by our Analytics team. This data is required by them to provide an evaluation of the impact of this service during the crisis. The key metrics for use of the device are the number of inbound/outbound calls and the average duration of these calls made by the user. This is separated into; provider, responder, and concierge as these are different types of use of the device. In addition, the number of audio versus video calls is needed as a major benefit of the service is the ability to make video calls which is expected to significantly reduce social isolation for service users. This data is therefore necessary for the evaluation of the service. Only overall volumes and averages will be collected, and data will not show specific individuals to whom calls were made, only what type of role they hold on the service users’ support network (e.g. provider, responder, concierge). Any reports resulting from this data will only present aggregated (total) data. Individuals will not be identifiable in any reports.
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 data
Once you are enrolled on to the Kara Project, KCC will limit the sharing of information with Alcove to the following details:
- phone number
- email address of client (if applicable)
- address (including post code)
- care provider that is currently delivering care and support services to you (if applicable).
Due to the coronavirus pandemic, we want to minimise the face-to-face contact where possible, therefore the devices will be posted to you with a set of instructions on what to do next.
We also use your personal information to:
- create a secure and comprehensive record of all of the work that we do with and for you in the Kara Project:
- your name, address, telephone number, date of birth
- contact details for members of your family and support network
- process complaints and compliments regarding the services we have provided
- analyse the service that we are providing through the Kara Project:
- statistical reports output by our computer systems and data provided by Alcove Ltd. The reports will be anonymised, and therefore Individuals will not be identifiable in any reports.
How long will your personal data be kept
As part of the Kara project, your records will be maintained by Alcove for the duration of the contract (3 years) or until you are no longer using this service.
We will only hold your personal information for as long as necessary. To work out how long we need to keep your information for we use our retention schedule (See section MN10.1.02 for project documents and AS1 – 6 (excluding AS2.1, AS2.2, AS4.4, AS4.5, AS4.9, AS4.10, AS4.11, AS4.12.15, AS4.12.16, AS4.13, AS5.2, AS6.1) which provides a breakdown of the retention periods relied on by Adult Services. The criteria for determining retention periods are statutory or other industry requirements, legal liability or other legal requirements and best business practice.
Reasons we collect and use your personal information
When we collect your personal data, we rely on the following legal bases:
- Article 6(1)(c) - processing is necessary for compliance with a legal obligation to which the controller is subject.
- 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.
When we collect your ‘special categories of personal data’, we rely on the following legal bases:
- Article (9)(2)(h) - processing is necessary for the provision of health or social care or treatment or the management of health or social care systems and services.
- Article 9(2)(j) - processing is necessary for statistical purposes (which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject).
We rely on the health or social care purposes condition from Schedule 1 of the Data Protection Act 2018 when relying on Article(9)(2)(h) and Article 9(2)(j) 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.
- 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 for any reasons deviating from the periods in our Retention Schedule.
NHS and care services
We have processes in place for considering requests for data disclosures for purposes beyond direct care which is consistent with national data opt-out policy. Our organisation is compliant with the national data opt-out policy.
To find out more about the NHS’ wider use of confidential personal information and to register your choice to opt out if you do not want your data to be used in this way, visit the NHS website. If you do choose to opt out, you can still consent to your data being used for specific purposes.
Under the UK GDPR you have rights which you can exercise free of charge that 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
- make a complaint to the Information Commissioners 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.
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 email@example.com.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, 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.
Please contact the Information Resilience and Transparency Team at firstname.lastname@example.org 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 email@example.com.
The United Kingdom General Data Protection Regulation also gives you the right to lodge a complaint with the Information Commissioner who may also be contacted by telephone on 0303 123 1113.
Read our corporate privacy statement.