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Refugee Resettlement Programme privacy notice

We keep this privacy notice under regular review and it was last updated on 10 March 2025.

Kent County Council (KCC) 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 to inform you of the information KCC, your district council (housing authority) and The Refugee Council hold on you and your family and how we will handle this and any additional information we receive. For the purposes of this document the three organisations are referred to as the ‘Three Support Bodies'.

Who we are

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.

The information the Three Support Bodies hold, collect and use about you is regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (and in the United Kingdom) and the Three Support Bodies are responsible with KCC as ‘Data Controller’ and The Refugee Council and your district council (housing authority) as ‘Data Processors’ of that personal information for the purposes of those laws.

This privacy notice and Data Sharing Consent Form covers the following Resettlement Schemes as enacted by the UK Government:

  • United Kingdom Resettlement Scheme.
  • Afghan Resettlement Programme.

Personal information we collect and use

Before you arrived in the United Kingdom, the British Government passed information regarding you and your family to KCC. KCC then shared this information with your district council and The Refugee Council.

The information that we shared includes the following categories of personal data:

  • full name, address, date of birth, details of dependent children
  • relevant ID numbers, refugee status, arrival date in the UK
  • details of close relatives including those registered with the UNHCR
  • education levels, languages spoken and level of literacy
  • previous occupations, training received and skills
  • medical information on any current health conditions
  • the reasons for you leaving your country of origin, what you have been doing since and your reasons for needing to be resettled in the UK

How we use your personal information

The basis for sharing this information prior to your arrival in the UK was that it was considered to be in your vital interests to process the information and also the processing was considered to be necessary to safeguard you and your family as individuals at risk. The shared information was used so that we could decide if we were able to house you in this area and also to prepare a support plan and package for your arrival.

Before you arrived in the UK, KCC also needed to share some of your information with other departments within our organisations and external agencies in order to make sure all your needs would be met. This included for the purposes of setting up your home, education, benefits, social care, adult education and other as necessary. We only share the minimum information required in these cases for you to be provided with a service.

In addition, we have shared information on your medical needs with the National Health Service in order for you to be allocated a GP and other specialist help as necessary. The basis for sharing this information was the same as that given above.

Information obtained and held since your arrival in the UK

Now that you are here in the UK the Three Support Bodies will be providing you with resettlement support under the specific resettlement scheme you have been resettled under. In the course of that work we will also gather additional information about you and your family. This will include things like any schools/colleges attended, any work or training undertaken, benefits claimed, referrals to other specialist agencies and other issues which might arise. The Three Support Bodies would like to be able to share relevant information that we collect individually about you and any children that you may have between ourselves so that we can ensure that you are receiving the best possible package of support.

It is important to note that if you are referred to any specialist agencies (for example for medical treatment, counselling etc.) the Three Support Bodies will not be provided with details of your treatment or what has been discussed, unless you would like us to have that information in order to assist you.

Special Category Data

Please note that some of the data the Three Support Bodies hold on you is referred to as Special Category Data, that is, data relating to:

  • your health
  • race
  • ethnic origin
  • religious or philosophical beliefs
  • political opinions
  • trade union membership
  • biometric data used to identify you
  • genetic data
  • data related to your sexuality.

We will normally seek your express consent before sharing this data between ourselves or with any other person and organisation as part of the process for seeking support and services from those other organisations. However, there may be circumstances where we are obliged to supply that information by law or there is a compelling legal reason for sharing that information without your express consent, for example in a medical emergency.

Reasons we can collect and use your personal information

When Three Support Bodies collect or share your personal data, we rely on the following legal bases:

  • Article 6 (1) (e) of the General Data Protection Regulation (GDPR) (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 much of your personal data. If we feel that Article 6(1)(e) does not give us the right to use your data in certain circumstances, we will speak to you about this before doing so.

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

  • Article 9 (2) (g) of the GDPR (processing is necessary for reasons of substantial public interest (for government purposes)
  • Article 9 (h) health/social care (to enable you to access relevant services)
  • Article 9 (i) public health (to ensure public health in maintained and care provided to those who require it)

as the lawful basis on which we collect and use your special categories of personal data.

If we feel that that Article 9(2)(g) does not give us the right to use your data in certain circumstances, we will speak to you about this before doing so.

Please note that you may withdraw your consent at any time, but that may lead the Three Support Bodies to provide you with a reduced level of service and in certain circumstances to no service at all.

We take the following appropriate safeguards in respect of your special category data when relying on the condition 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.

We will also recognise your rights established under UK case law collectively known as the Common Law Duty of Confidentiality. The duty of confidentiality is not a written Act of Parliament, it is “common” law. This means that it has been established over a period of time through the courts. It recognises that some information has a quality of confidence, which means that the individual or organisation that provided the information has an expectation that it will not be shared with or disclosed to others. NHS England had confirmed approval of the Section 251 application to the Confidentiality Advisory Group (CAG).

How long your personal data will be kept

The Three Support Bodies will hold your personal information for four years under the Afghan Resettlement Programme and six years under the United Kingdom Resettlement Programmes.

At the end of your support period, we will retain the information in line with Government instructions and our data retention policies at the time before your information is securely destroyed.

Who we share your personal information with

At regular intervals (and sometimes in addition outside these times) KCC has to provide information to the British Government about how your resettlement is progressing and to ensure you are receiving the right support under the resettlement schemes.

In addition, KCC (on behalf of itself and your district council) has to monitor the support that you are provided with by The Refugee Council and needs to be given regular updates on you and your family’s situation by The Refugee Council. Further, on occasion you may be visited by KCC or your district council and the information obtained during these visits may help to provide you with a better service if it can be shared with each other and The Refugee Council.

With your consent, the Three Support Bodies will also share relevant parts of the information we hold with other agencies if this is necessary to arrange further services and support for you and your family. This may include the Department of Work and Pensions (DWP - Jobcentre Plus), His Majesty’s Revenue and Customs (HMRC), utility providers, specialist agencies or departments within our organisations, charities providing extra help and others as appropriate. Sometimes these services will be sought at your request and at other times, we will make arrangements to fulfil our own legal obligations to you.

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.

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. 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.

Objecting to data sharing

You have the right to object of sharing personal data. You should therefore contact the the Three Support Bodies involved in your care. An objection to sharing your information will mean that your data will not be shared for any kind of support. We ask you to think carefully before making this decision as this may delay or prevent us delivering a service to you.

If you chose to object, the right is not absolute, and we may continue to use the data if we can demonstrate compelling legitimate grounds.

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.

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.

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.