Kent and Medway Designated Keyworker Early Adopter Programme privacy notice

We keep this privacy notice under regular review and was last updated in August 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 (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 (DPA 2018). We are responsible as ‘controller’ of that personal information. Our Data Protection Officer is Benjamin Watts.

The Kent and Medway Designated Keyworker Early Adopter (KM-DKW) Programme aims to prevent unnecessary educational exclusions and hospital/institutional admissions for children and young people (CYP) with complex care needs (e.g., learning disabilities, autism spectrum conditions (ASCs) and/or challenging behaviour).

Where admission is inevitable, the Designated Keyworker (DKW) will perform an integral role, ensuring discharge plans are developed and in place, and that length of stay is for the shortest time possible.

The keyworking function is an important regional/national response to ensuring CYP and their families get the right support at the right time and that local systems are responsive to meeting their needs in a holistic and joined up way.

Personal information we collect and use

Information collected by us

In order to execute the support and advocacy function of the KM-DKW Programme, we collect the following personal information about you:

  • Personal information (such as name, address, contact details, date of birth)
  • Special category characteristics (such as ethnicity, disability, mental health status, and sexual orientation)
  • Personal identifiers (including NHS numbers and identification numbers)
  • Criminal offence data where necessary.

In addition, we obtain personal information from other sources as follows:

  • Social services
  • Schools, colleges, or other training facilities
  • Health.

How we use your personal information

We use your personal information to:

  • identify the need for involvement of the KM-DKW Programme team and its resources in your care and/or support
  • give an understanding of your health, education and social care support needs and provision
  • inform service commissioning that would improve your social, mental, physical, and emotional wellbeing
  • aggregate data and intelligence to inform health, social care, and education risk management of CYP population including prevention of CYP deaths.

Reasons we can collect and use your personal information

We collect and use your personal information to carry out tasks in the public interest.  We rely on the following legal 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 legal bases under UK GDPR:

  • Article 9(2)(g) - Reasons of substantial public interest. We rely on the statutory and government purposes, and Support for individuals with a particular disability or medical condition purposes 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 an Appropriate Policy Document which explains how our procedures ensure compliance with data protection principles when processing special category data and explains policies regarding the retention and erasure of that 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 in it any reasons for deviating from the periods in our Retention Schedule.

The provision of personal and special category data is required from you to enable us to learn more about your social care, education and health history which will help us provide dynamic person-centered support that is driven by your needs.

As we have a statutory basis for collecting your personal data, if you do not provide personal and special category of data and consent to us using the data, we would not be able to support you in a personalised way.

How long your personal data will be kept

We will hold your personal information securely and retain it from the child /young person’s date of birth until they reach the age of 25 (if we continue to support you until then) for a further 6 years if we stop supporting you at age 18, after which the information is made inaccessible to system users or securely destroyed.

Who we share your personal information with

We routinely share:

  • personal data with social care providers, education providers, Kent and Medway Clinical Commissioning Group, Kent PACT (parent carer forum)
  • data processors working on behalf of KCC as well as other organisations receiving the information legitimately for their own purposes (e.g., our third-party IT suppliers, NHS Providers such as GPs and hospitals etc.).

This data sharing enables third parties to provide the appropriate care and support in the right manner and at the right time to you.

We have a data sharing agreement in place with all the care and support providers listed above. Kent and Medway Clinical Commissioning Group is a signatory to the Kent and Medway Information Sharing Agreement (the KMISA) and a record of processing is kept for this sharing. We have a data processing agreement in place with Kent PACT who process your data on our behalf.

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:

  • object to how we are using your information
  • 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
  • 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 UK GDPR.

If you would like to exercise a right, please contact the Information Resilience and Transparency Team at

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 emailing

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, 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.


Please contact your school's headteacher 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.

UK GDPR also gives you right to lodge a complaint with the Information Commissioner who may be contacted via the Information Commissioner's website or call 03031 231113.