KCC Channel Panel privacy notice
We keep this privacy notice under regular review and it was last updated on 9 September 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.
KCC has statutory duties under section 36 to 41 of the Counter-Terrorism and Security Act 2015 to provide support for people vulnerable to being drawn into any form of terrorism. Channel is a programme which focuses on providing support at an early stage to people who are identified as being vulnerable to being drawn into terrorism. The programme uses a multi-agency approach to protect vulnerable people by:
- identifying individuals at risk
- assessing the nature and extent of that risk
- developing the most appropriate support plan for the individuals concerned.
Personal information we collect and use
Information collected by us
In the course of delivering our responsibilities under the Channel programme, we collect the following personal information about you, either when you provide it to us or from another member of the Kent Channel Panel:
- date of birth
- contact details
- relevant family member and associate details
- first language
- criminal records and conviction data
We also collect the following special category personal data:
- relevant medical information (if applicable)
- religious beliefs (if applicable)
- relevant Social Care information
We recognise that personal information concerning criminal convictions and offences is not special category personal data but is a very sensitive type of personal information which can only be shared in narrow circumstances.
How we use your personal information
We use your personal information to provide tailored support at an early stage to you, with the aim of preventing you from being drawn into terrorism.
How long your personal data will be kept
We will hold your personal information for 7 years (please see KCC’s Retention Schedule (PDF, 1.1 MB) (AS3.1.1)). After this period the information will be reviewed, and only retained where there is an ongoing requirement to retain for a statutory or legal purpose. Following this your personal information will be securely destroyed.
Reasons we can collect and use your personal information
We collect and use your personal information to carry out tasks in the public interest. We rely on the following legal bases under UK GDPR:
- 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)(g) - Reasons of substantial public interest. We rely on the ‘preventing or detecting unlawful acts’ purpose condition from Schedule 1 of the Data Protection Act 2018 when relying on Article 9(2)(g) to process your special category data.
We rely on the preventing or detecting unlawful acts condition from Schedule 1 of the Data Protection Act 2018 to process your criminal records and convictions data.
We take the following appropriate safeguards in respect of your special category and criminal convictions data when relying on the conditions above:
- we have an Appropriate Policy Document which explains how the data protection principles are secured when using special category and criminal records and conviction 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.
Who we share your personal information with
As part of the Channel process, personal information is shared securely and only where strictly necessary. Relevant information will be sought from other agencies as appropriate to inform our assessment. Where there is a need this will be discussed at a multi-agency panel to consider whether intervention support should be offered. The information will only be shared with relevant agencies. This may include:
- health agencies
- Home Office, immigration
- district local authorities
- other relevant agencies.
Each organisation listed above will ensure they have the relevant agreements in place to be able to process your personal information.
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.
Under the 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
- 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
- where we have relied upon consent, withdraw your consent at any time
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. We will liaise with the Home Office regarding your request, as information is jointly controlled with the Home Office. Please note: your request may delay or prevent us from supporting 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 firstname.lastname@example.org.
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 email@example.com 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 firstname.lastname@example.org.
Read our corporate privacy statement.