Kent Support and Assistance Service (KSAS) privacy notice
This notice explains what personal data (information) we hold about you, how we collect, how we use and may share information about you. We are required to give you this information under data protection law.
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 General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws. Our Data Protection Officer is Benjamin Watts.
Our Kent Support and Assistance Service (KSAS) helps people who are having serious difficulties managing their income due to a crisis or if they are facing exceptional pressures because of an emergency. We offer our help for a short time only and where there are no other means of support available. Wherever possible we want to help you stay in (or move back into) your local community.
Personal information we collect and use
Information collected by us
In the course of working with you, we will collect the following personal information when you provide it to us:
- 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 your racial or ethnic origin, religious or philosophical belief and your sexual orientation is collected for equality monitoring purposes only
- information about health conditions or disabilities that may be relevant to your circumstances or the support you require.
Collecting and sharing your personal information
In the course of 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 Tesco PLC, ASDA Stores Limited, West Kent Housing Association, Argos LTD for the administration of awarded goods. We will opt out of any future marketing on behalf of the applicant.
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.
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.
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 KSAS 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 KSAS misuse
The sharing of information facilitates a joined-up approach with partner agencies, to provide you with the best possible care and support.
How long your personal data will be kept
Records will be retained for no longer than 6+ 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.
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:
- 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:
- processing is necessary for reasons of substantial public interest
- safeguarding of children and of individuals at risk
- monitoring equality of opportunity or treatment
- processing is necessary for the provision of health or social care or treatment or the management of health or social care systems and services
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.
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.
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, 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 03031 231113.
Read our corporate privacy statement.