Technology Enhanced Lives privacy notice

We keep this privacy notice under regular review and it was last updated on 22 May 2024.

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.

An easy read alternative is available to view.

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 Enhanced Lives Services (TELS) 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.

As a society, we are adopting digitally enabled solutions in many aspects of our lives; with extraordinary innovations emerging to support people to live independently. For example, technology, such as wearables, smart voice interaction, mobile applications, tablet devices and sensory communication can offer so much more, as a preventive tool to defer the need for or to avoid more intensive forms of care.

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.
  • you and your circumstances.
  • relevant health and safety concerns.
  • 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, for example a hearing impairment, type of care required.

How we use your personal information

We use your personal information to:

  • create a secure and comprehensive record of all the work 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 about:
    • health conditions, disabilities or carers responsibilities that may apply to you
    • you and your circumstances
    • relevant health and safety concerns
    • 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)(a) - the individual has given clear consent for you to process their personal data for a specific purpose.
  • 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)(a) – the individual has given explicit consent to the processing of those personal data for one or more specified purposes
  • 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 only hold your personal information for as long as necessary.

We use the following retention periods:

Retention LabelRetention Period DescriptionRetention
AS4.14.01Project documentation created that may not result in a contractLast action on the project, plus 6 years
AS4.14.02Project files relating to research undertaken to test the viability of the projectEnd of operational use
AS4.14.03Correspondence relating to the programme which does not merit inclusion on the project filesLast action on project, plus 1 year
AS4.14.04Project documentation created where the creator is not the project manager or designated record keeperLife of Project
AS4.14.05Records relating to clients with a physical impairmentDate of last contact, plus 5 years, or 2 years from date of death
AS4.14.06Records relating to clients with a learning impairmentDate of last contact, plus 5 years, or 2 years from date of death
AS4.14.07Records relating to clients with a sensory impairmentDate of last contact, plus 6 years or date of death, plus 2 years
AS4.14.08Records relating to clients who have contact with the Occupational Therapy BureauDate of last contact, plus 2 years
AS4.14.09Records relating to clients with mental illness including Guardianship recordsDate of last contact, plus 20 years or date of death, plus 8 years
AS4.14.10Client records created by the Deprivation of Liberty Service (DOLS)Date of last contact, plus 6 years. Paper copies destroyed on routine basis (every 6 months)
AS4.14.11Records used by the Kent Enablement at Home teams held in clients' homes (including risk assessments)Archived for 7 years once contact ceases
AS4.14.12Records relating to safeguardingHeld for 5 years at area level. Transferred to Records Management Service for 10 years from date of last contact
AS4.14.13Physical client records created by the Hospital TeamsReturned to local area office when contact has ceased, to be included with the main client record.
AS4.14.14Records relating to older personsDate of last contact, plus 3 years or date of death, plus 2 years.

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):

  • PA Consulting, Red Alert Telecare Limited, Appello Careline Limited, and Xantura Limited
  • Other service providers including:
    • Oysta Technology Limited
    • Brain-In-Hand Limited
    • Just Checking Limited
    • Howz Limited
    • Zintouch UK Limited
    • iLogs Healthcare
    • ChipTech International Limited
    • Alcove Limited 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. All of the parties listed are also approved partners of supporting and delivering the TELS project and are fundamental to its ongoing and future success.

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.

Your rights

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 data.protection@kent.gov.uk.

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.

You can do this by either phoning or emailing Adult Social Care and Health at 03000 414955 or tels@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

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.

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.