Independent Travel Training privacy notice

We keep this privacy notice under regular review and it was last updated in October 2025.

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.

View an easy read version of this privacy notice (PDF, 310.1 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 (DPA). We are responsible as ‘controller’ of that personal information. Our Data Protection Officer is Benjamin Watts.

The Independent Travel training programme helps young people (up to 24 years old) with special educational needs and/or disabilities learn how to travel to school or college by public transport.

Personal information we collect and use

Information collected by us

In the course of providing and arranging training, we collect the following personal information when you provide it to us:

• Child or young person’s details (name, address, date of birth).
• Parental details (name, address, date of birth).
• Contact details (email address, telephone number).
• Details of school, college or provision attended.
• Whether the child or young person is eligible for Local Authority funded home to school transport.

We also collect the following special category data (personal data which is more sensitive and is treated with extra care and protection) when you provide it to us:

• Health data (details of Special Educational Needs and Disabilities, any relevant allergies and any relevant phobias).
• Details of Education, Health and Care Plans (EHCP).

We also obtain personal information from other sources as follows:

• Schools
• Other KCC teams (Home to School transport teams, Early Help and Children’s Social Care)

How we use your personal information

We use your personal information to:

• arrange and deliver training which is tailored to each child or young person’s personal circumstances
• make decisions around eligibility for travel training (these decisions are not automated and will be made by a human member of staff, based on each individual child or young person’s circumstances)
• make arrangements with current transport providers (such as, local authority-funded taxi services)
• evaluate and quality assure the services we provide
• analyse service provision and effectiveness, and model patterns of service involvement to support future service delivery planning.

Reasons we can collect and use your personal information

We collect and use your personal information to carry out tasks as a public authority. We rely on the following lawful bases under UK GDPR:

• Article (6)(1)(e) - Public task: the processing is necessary to perform a task in the public interest or for official functions (task or function has a clear basis in law).

When we collect or share special category personal data, we rely upon the following lawful bases under UK GDPR:

• Article 9(2)(g) - Reasons of substantial public interest. We rely on the ‘statutory and government purposes’ purpose condition from Schedule 1 of the Data Protection Act 2018 when relying on Article 9(2)(g) 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 a Appropriate Policy Document in place when using your special category and/or criminal records data.
• This policy is retained throughout the time we use your data and for 6 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 any reasons for deviating from the periods in our Retention Schedule.

The provision of personal information is required from you to enable us to provide a tailored training service.

As we have a statutory basis for collecting personal data, if you do not provide the relevant and necessary information, we may not be able to provide a service which is personalised and relevant.

How long your personal data will be kept

We will hold personal information until the child or young person reaches the age of 25 years old, after which the information is made inaccessible to system users or securely destroyed.

Who we share your personal information with

We may share your personal information with the following third parties or in the following ways:

• Teams within KCC working to improve outcomes for children and young people.
• Commissioned providers of local authority services.
• Schools.
• Partner organisations signed up to the Kent and Medway Information Sharing Agreement, where necessary, which may include health visitors, midwives, housing providers, Police, school nurses, doctors, and mental health workers.
• Department for Education and other government departments as required.

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 Commissioners 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. 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 Commissioners Office (ICO) on individuals’ rights under UK GDPR.

If you would like to exercise a right, contact the Information Resilience and Transparency Team at data.protection@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.

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, through email or post at:

The UK GDPR also gives you right to lodge a complaint with the Information Commissioner who may be contacted on 03031 231113.

Read our corporate privacy statement.