Kent School Public Health Service privacy notice

We keep this privacy notice under regular review and it was last updated on 21 May 2026.

We respect your privacy and are 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.

View an easy read version of the Kent School Public Health Service privacy notice (PDF, 630.8 KB).

Who are we

We collect, use and are 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.

We commission Kent Community Health NHS Foundation Trust (KCHFT) to deliver the Kent School Public Health Service (which includes Hearing and Vision screening Year R and Health Development Reviews in Years R, 6 and 9).

The service also provides the National Children Measurement Programme NCMP Year R, covered by a separate privacy policy.

The Kent School Public Health Service delivers a comprehensive, evidence-based public health nursing service for children and young people from reception to 19 years across Kent, in line with the Healthy Child Programme. The service promotes child health and development, reduces health inequalities, and ensures early identification of health or developmental needs.

KCHFT are also considered a data controller in respect of some of the information collected and processed as part of delivering the Kent School Public Health Service.

Our Data Protection Officer is Benjamin Watts.

The personal information we collect and use

Information collected by us

In the course of delivering the School Public Health Service, we collect personal information when you provide it to us. We collect:

• child’s personal details (such as name, address, postcode, date of birth and gender)
• parent or carer’s personal details (such as name, address, postcode, date of birth) and contact details (email, telephone and mobile)
• personal details belonging to professionals who are taking part in training programmes delivered by the School Public Health Service (name, job role, email address)
• photographs, audio and video recordings (where required).

We also collect special category data (personal data which is more sensitive and is treated with extra care and protection) when you provide it to us. We collect relevant health information, including:

• race or ethnicity and cultural background
• religious or philosophical beliefs
• sexual orientation or sex life (where relevant for care)
• relevant health information of professionals who are taking part in training programmes, to ensure training is delivered in an accessible way.

We will also collect data which is not classed as special category data but will be treated with extra care, when you provide it to us. We collect:

• personal identifiers (including the child and parent or carer’s NHS number or other identification numbers, such as, RIO identifier)
• family history relevant to child health and wellbeing
• details of the child and/or parent or carer’s GP
• details of any relevant legal representative
• relevant personal circumstances, including:
  • looked after status (if the child and or young person is a child in need, subject to a Child Protection Plan, care experienced for example)
  • unaccompanied asylum seeking child or young person
  • young carers status
  • domestic abuse (including whether the perpetrator is still living with the child or young person); or experiencing financial hardship
  • safeguarding information, including social care involvement, domestic abuse concerns, substance use, or other risk factors.

We also obtain personal information from other sources, including:

• other NHS systems such as Child Health Information Service (CHIs)
• Kent and Medway Care Record (KMCR)
• social care teams, if there are any safeguarding concerns.

How we use your personal information

We use your personal information to:

• deliver school health services under the Healthy Child Programme
• assess your child’s or family needs
• safeguard children and support family resilience
• monitor service performance and inform public health planning
• fulfil statutory obligations under the Children Act and public health duties
• use the Kent and Medway Care Record (KMCR) to help inform the support we provide to you and your child, and to help us improve services. To find out more about how your data is used in the Kent and Medway Care Record, read the KMCR privacy notice.
• help plan and improve mental health services and policies for children and young people in the UK by sharing data with the national Community Services Dataset, held by NHS Digital (part of NHS England).

Reasons we can collect and use your personal information

When we collect and use your personal data, we rely on the following legal bases:

• 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.
• Article 6(1)(c) - processing is necessary for compliance with a legal obligation to which the controller is subject, as follows:
  • The Children Act 1989 and 2004.
  • The Health and Social Care Act 2012.
  • The NHS Act 2006.

When we collect or share your special category personal data (such as health information) we rely upon the following legal bases under UK GDPR:

• To comply with statutory safeguarding duties: 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, Part 2 of the Data Protection Act 2018 when relying on Article(9)(2)(g) to process your special category data.
• For delivery of the service: 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. We rely on the ‘health or social care purpose’ condition from Schedule 1, Part 1 of the Data Protection Act 2018 when relying on Article(9)(2)(h) to process your special category data.
• For public health monitoring and reporting under statutory obligations: Article (9)(2)(i) - Necessary for reasons of public interest in the area of public health. We rely on the ‘public health’ condition from the Data Protection Act 2018 when relying on Article (9)(2)(i) to process your special category data.

Criminal Offence Data

We may process criminal offence data where necessary to protect children and comply with statutory safeguarding duties. This includes information related to criminal convictions or offences that may affect the safety and wellbeing of a child or family.

Lawful basis for processing criminal offence data are:

• UK GDPR Article 10
• Processing is carried out under substantial public interest for safeguarding children and individuals at risk (Schedule 1, Part 2, Paragraph 18 of the DPA 2018).

These conditions ensure that processing is proportionate, respects data protection rights, and includes suitable measures to safeguard the fundamental rights and interests of data subjects.

We take the following appropriate safeguards in respect of your special category and/or criminal offence data when relying on the conditions above.

• We have an Appropriate Policy Document (our Adult Social Care and Health Directorate) in place when using your special category and/or criminal records data.
• 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.

Who we share your personal information with

In the course of delivering the Kent School Public Health Service, we may collect information from, or share it with, third parties including:

• our teams working to improve outcomes for children and young people, such as our Integrated Children’s Services and Kent Family Hubs
• commissioned providers of local authority services
• schools
• partner organisations signed up to the Kent and Medway Information Sharing Agreement, where necessary, which may include:
  • GPs
  • health visitors
  • safeguarding teams
  • schools
  • housing providers
  • police
  • doctors
  • mental health workers.
• Department for Education and other government departments as required
• Kent Community Health NHS Foundation Trust (as data processor)
• other organisations involved in safeguarding or supporting families
• NHS England, as part of submitting data to the national Community Services Dataset.

We have a data processing agreement in place with KCHFT who process your data on our behalf to deliver the School Public Health Service. For more information about how KCHFT handles your data, read the KCHFT privacy notice.

Where information is shared with other organisations for safeguarding or continuity of care, this is done under the Kent and Medway Information Sharing Agreement (KMISA).

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

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.

Transferring your information outside of the UK

KCHFT uses RingCentral as part of processing your personal data, which may involve transferring or storing data in the UK/EU/EEA, Switzerland and the US. This means that we may transfer your data outside of the UK to the EU, EEA, Switzerland or the United States (US) for processing. This is based on an adequacy decision by the Secretary of State/safeguards prescribed by the UK GDPR and Standard Contractual Clauses.

For further information about international transfers visit the Information Commissioner's website.

Your rights

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 (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. However, 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, 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

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.

Read our corporate privacy statement.