Technology Enabled Care privacy notice
We keep this privacy notice under regular review and it was last updated on 31 May 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 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 (GDPR’) and the Data Protection Act 2018. We are responsible as ‘controller’ of that personal information. Our Data Protection Officer is Benjamin Watts and contact details are set out below.
Technology Enabled Care Service (TECS) is a project within Adult Social Care and Health that is designed to procure innovative digital Assistive Technology, with the aim that this technology will support you to live independently.
The personal information we collect and use
Information collected by us
In the course of working with you we collect the following personal information when you provide it to us:
- Personal information including name, sex, telephone number, NHS number, date of birth, age.
- Contact details for members of your family and support network.
We may also collect the following ‘special category data’ (personal data which is more sensitive and is treated with extra care and protection as defined in UK GDPR) when you provide it to us:
- Information about health conditions, disabilities or carers responsibilities that may apply to you.
- Information about you and your circumstances.
- Information about relevant health and safety concerns.
- Information about your needs and wishes.
We will only collect the data listed above that is applicable to the type of care and support that we will be providing you with. This may include, for example, housing type and set up, mobility, disability and/or health condition e.g. hearing impairment, type of care required etc.
How we use your personal information
We use your personal information to:
- create a secure and comprehensive record of all of the work that we do with and for you using the following information:
- your name, address, telephone number, date of birth, age, NHS number, sex, and
- contact details for members of your family and support network in case of an emergency
- fully understand your needs using the following information:
- information about health conditions, disabilities or carers responsibilities that may apply to you
- information about you and your circumstances
- information about relevant health and safety concerns
- information about your needs and wishes.
- process complaints and compliments regarding the services we have provided; such details as name, telephone number along with your health condition and if the technology provided made an improvement to your day-to-day needs.
- analyse the service that we are providing:
- statistical reports output by our computer systems (using pseudonymised information (unique identifier will be used).
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.
When we collect your ‘special categories of personal data’, (such as health etc) we rely on the following legal bases:
- Article (9)(2)(g) - processing is necessary for reasons of substantial public interest (statutory etc and government purposes).
- 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 of the Data Protection Act 2018 when relying on Article(9)(2)(h) to process your special category data.
We take the following appropriate safeguards in respect of your special category data when relying on the conditions 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.
How long your personal data will be kept
We will hold your personal information for:
- We will only hold your personal information for as long as necessary. To work out how long we need to keep your information for we use our retention schedule (see sections MN10.1.04 to MN10.1.08 (excluding MN10.1.07) which provides a breakdown of the retention periods relied on by Adult Services for the TECs project).
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):
- Other IT Service providers including Chiptech, Vayyar, Howz, Orcha, EasyLink and many others (details of which can be provided upon written request).
- Family members or members of support network.
Each external organisation listed above will ensure they have the relevant agreements in place to be able to process your personal information.
This data sharing enables us to personalise your care and ensure that you are receiving the best support possible.
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 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 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.
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, please contact the Information Resilience and Transparency Team at firstname.lastname@example.org.
Your right to withdraw your consent
Where we rely on your consent to process your personal information, you can withdraw your consent to our use of your data at any time.
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
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.
Read our corporate privacy statement.