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Supervised Toothbrushing Programme privacy notice for schools and early years providers

We keep this privacy notice under regular review and was last updated on 25 March 2026.

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.

View an easy read version of the Supervised Toothbrushing Programme privacy notice (PDF, 590.8 KB).

Who we are

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.

We are responsible as ‘controller’ of that personal information. Our Data Protection Officer is Benjamin Watts.

We deliver the Supervised Toothbrushing Programme. This programme will offer opportunity for children aged 3 to 5 years and in Reception in targeted early years settings and schools to participate in daily supervised toothbrushing at their early years settings or provider, or school, in order to protect and improve their oral health.

A key contact from the eligible settings will be asked if they give permission (called a ‘common law consent’) to be contacted on behalf their setting, to register the organisations interest to participate in the supervised toothbrushing programme and to share their details with the distributor of supervised toothbrushing resources, Kent County Supplies (KCS), to take place during the year from September 2025.

Parents and carers who have a child aged 3 to 5 years in participating early years settings or a child in Reception in participating schools, will be asked by their setting if they give permission (called a ‘common law consent’) for their child to take part in the supervised toothbrushing programme. The key contact in participating settings will be asked to provide numbers of children with consent to participate in the programme. Settings will also discuss any adaptations to resources to enable children in their setting with need to participate. This will be used to generate supervised toothbrushing resource orders with KCS, who will be distributing resources to participating settings.

The key contact will also be asked if they give consent for their organisation’s details to be shared with Kent Community Health NHS Foundation Trust (KCHFT), who will be contacting settings to carry out a brief dental examination with participating children this year and every two years to record the number of decayed, filled, or missing teeth that they may have as part of a cohort study, so we can explore the impact of taking part in daily supervised toothbrushing at school. This will be carried out by the KCHFT dental team. The team will also arrange to carry out quality assurance visits at each participating setting on our behalf. This will record observations of the supervised toothbrushing session against a quality standards checklist, the outcomes of which will be shared with us.

We will also ask the key contact if they wish to be contacted to complete a pre and follow-up feedback survey. Settings will ask parents and carers if they wish to complete a pre and follow-up survey. This will help us to understand how helpful you think it has been for your setting to take part in this project.

The personal information we collect and use

Information collected by us

If you give permission for your child to take part in daily supervised toothbrushing, the setting will collect personal information when you provide it to them. The setting will collect your:

  • child’s personal details, for example, name
  • personal details (as the child’s parent or carer), for example, name.

The setting will share an anonymous pre and follow-up feedback survey during the course of the year. This will include questions around toothbrushing habits at home.

The setting may also collect ‘special category data’ (personal data which is more sensitive and is treated with extra care and protection) when you provide it to them. The setting will collect:

  • information about any allergies or health needs that your child may have that are relevant to them taking part in daily toothbrushing at their early years setting or school.

If you give permission to be contacted on behalf of your organisation, we will collect personal information when you provide it to us. We will collect your key contact’s personal details, for example:

  • name
  • work email address
  • the organisation’s address and name.

Your email address will only be used to contact you to follow up your interest form, arrange delivery of the supervised toothbrushing resources by KCS, send a pre and follow-up feedback survey during the course of the year and to be contacted by KCHFT to explore interest in dental examination cohort study and arrange a quality assurance visit to the setting. The outcome of the quality assurance visit will be recorded against a quality standards checklist and shared with us. This includes standards related to how well infection prevention control is being implemented.

How we use your personal information

We use your personal information to:

  • register your interest in the project
  • deliver your supervised toothbrushing resources
  • protect and improve a child’s oral health
  • quality assure supervised toothbrushing activity
  • seek feedback on the helpfulness of the project
  • understand the impact of this project for children, parents and carers.

Reasons we can collect and use your personal information

To administer the Supervised Toothbrushing Programme, 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.

For collecting the key contact email address to issue an interest form, resources, pre and follow-up survey, we rely on the following legal bases:

  • Article (6)(1)(a) - consent - the individual has given clear consent to process their personal data for a specific purpose).

When we collect your ‘special categories of personal data’, we rely on the following legal bases:

  • Article (9)(2)(i) - processing is necessary for public health.

We rely on the public health condition in the Data Protection Act 2018 to process your special category data.

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

  • 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.

How long your personal data will be kept

We will hold your email address, when you provide it to us, for 1 year, after which time this information will be securely destroyed.

Who we share your personal information with

In the course of working with you, we may collect information from, or share it with, some of the following third parties (non-exhaustive list):

  • Kent Community Health Foundation Trust (KCHFT) will be conducting a brief dental examination project on KCC’s behalf. KCHFT will be seeking settings participating in the supervised toothbrushing programme to take part in the dental examination cohort study and will manage this separately to this programme. KCHFT will contact settings via the key contact and the key contact will invite children participating in supervised toothbrushing to give consent to take part in the cohort study. KCHFT will provide a limited, de-identified data set with Kent Public Health Observatory (part of KCC) who will be analysing the study results. A link to the full privacy notice is here LINK
  • Kent County Supplies (KCS) will be distributing supervised toothbrushing resources to settings participating in the supervised toothbrushing programme on our behalf. KCS will require key contact details and the settings address to deliver goods including toothbrushes, toothpaste requested on behalf of the setting. KCS will take a photograph of the package at the delivery site and provide us with a delivery note to confirm delivery of the requested resources.

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 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. 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, contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk .

Your right to withdraw your consent

Where we rely on your consent to process your personal information (register your interest for organisation participation, pre and follow-up feedback survey, sharing organisation details for KCHFT dental examination project initial contact, quality assurance visit and KCS distribution of supervised toothbrushing resources), you can withdraw your consent to our use of your data at any time.

To do this, email oralhealth@kent.gov.uk . Let us know in your email which part of processing you want to withdraw your consent to.

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.