Social prescribing service privacy notice for referrals

This notice explains what personal data (information) we hold about you, how we collect, how we use and may share information about you.  We are required to give you this information under data protection law.

Who are we?

We are Kent County Council (KCC). KCC collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the Data Protection Act 2018 and we are responsible as ‘controller’ of that personal information for the purposes of that law.

Our Social Prescribing service is about promoting a wide range of social activities and healthy lifestyle interventions as an alternative to prescribing medication. Referrals will be made to a Community Connector worker who then spends time with an individual and connects them to activities which are typically provided by voluntary and community sector organisations. Examples include volunteering, arts, sports, peer learning, gardening, welfare/financial advice, befriending, cookery, and healthy eating advice.

The personal information we collect and use

Information collected by us

We will collect personal information directly from you or receive it from a third party.

In the course of obtaining a referral to our Social Prescribing service, where the referral is made by a third party (referrer), we collect the following personal information from the third party:

  • Name of the person making the referral
  • Contact details (telephone number, email address)

In the course of obtaining a referral to our social Prescribing service, we collect the following information from the person being referred, at the referral stage:

  • Name
  • Contact details (address, telephone number, email address)
  • Date of birth
  • Whether you require an interpreter
  • Information on how did you hear about our service

In the course of providing the Social Prescribing service to you (the person being referred), we collect the following personal information when it is provided to us:

  • Name
  • Contact details (address, telephone number, email address)
  • Date of birth
  • Emergency contact name and phone number
  • Number of appointments, dates and times with Community Connector
  • Medical status
  • Ethnicity
  • Gender
  • Education
  • Employment
  • Housing status
  • Living with status
  • Marital status
  • Our assessment of your level of physical activity, loneliness level, levels of happiness, levels of anxiety, life satisfaction
  • Details of your GP practice and a number of GP / A&E / hospital visits whilst using the service
  • Recordings or screen shots of some of our online sessions. (Your will always be asked for permission first before the recording begins or screenshots are being taken.)

How we use your personal information

If you are a third party making the referral on someone else’s behalf:

We use the referrer’s (third party’s) personal information to:

Confirm the details of the person being referred, if there are any problems with making contact.

If you are the person being referred:

We use your personal information (the person referred to the service) to:

  • Make contact with you about the service.
  • Enable you to join the Social Prescribing service.
  • Determine any accessibility needs.
  • Complete due-diligence checks to ensure the health, safety and welfare of our staff before they make home visits.
  • Develop a personal action plan in partnership with you, and to record our progress through the project. The action plan is used to help us signpost you to, or make referrals to, appropriate support services and to enable follow-up visits by an individual Community Connector. Details of referral options will be discussed with you and your permission to share will be obtained prior to making any referrals to third-party organisations e.g. clubs/societies.
  • Support management functions regarding our workloads, analysing demand profile on the service and analysing outputs of the service through the use of some centralised data.
  • Support project reporting requirements and data sharing between partner agencies through the use of some of the centralised data.

How long your personal data will be kept

If you are a third party making the referral on someone else’s behalf:

All personal information of the third party recorded as part of the referral is stored on an electronic case management system. Recorded information is retained for the duration of the time the person referred to the service is actively engaged with the service. After the service is concluded for any reason, the third party’s data is securely destroyed, as per the Kent Retention Schedules.

If you are the person being referred:

All personal information recorded by the Community Connectors in accordance with the above is primarily stored on an electronic case management system. Recorded information is retained for the duration of the time you are actively engaged with the service. After you leave the service, the health, ethnicity, gender, education, housing, employment & marital status data on your case record is securely destroyed after 6 months (including information held in pocket notebooks), as per the Kent Retention Schedules.

If you use our service between 1/1/21 and 31/1/23 all other personal data will be held by us securely until 31/12/2027. This is because the service is co-funded by the European Union’s Interreg France (Channel) England programme up to 31/1/23 and is subject to audit on the work we have conducted. Any audit by Interreg would take the form of an on-site visit to our business premises and would not require data to be transferred outside of the UK. After this time the complete case record is securely destroyed.

If you use our service after the 31/1/23 all other personal information will be held for a period of 6 months.

Reasons we can collect and use your personal information

The lawful basis on which we collect and use your personal data under the UK GDPR is:

  • Article 6(1)(c): Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Article 6(1)(e): Processing is necessary for the performance of a task carried out I the public interest

We may also collect and use special categories of personal data (e.g. relevant medical conditions) specifically in order for us to provide you with the Social Prescribing Plus service. We will normally collect this data via face-to-face conversations. In cases where this isn’t possible, we may conduct conversations over the telephone or via video calls.

The lawful basis on which we collect and use this special category data is that:

  • Article 9(2)(g): Processing is necessary for reasons of substantial public interest (statutory purposes, safeguarding, equality of opportunity).
  • Article 9(2)(h): Processing is necessary for the provision of health or social care.
  • Article 9(2)(h): ): Processing is necessary for statistical purposes (which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject).

This is specifically in order for us to fulfil our duties under the Care Act 2014; to promote an individual’s social wellbeing and our duties under the Equality Act 2010.

Who we share your personal information with

Your personal data will not be shared.

The personal data that is held by us until 31/12/2027 is for the purposes of audit by Interreg* who provide funding for the project and may wish to see evidence of the work we have conducted. Any audit by Interreg would take the form of an on-site visit to our business premises and would not require data to be transferred outside of the UK.

Where there is a need to share your details for signposting or referral purposes, we will obtain your consent before any referrals are made.

Should there be a need to share data with any other parties we will seek your permission to do so before the data is shared.

Where there is a safeguarding concern or where your safety and wellbeing may be at risk, some data may be shared with appropriate agencies without consent being sought first.

*Interreg - is one of the key instruments of the European Union (EU) supporting cooperation across borders through project funding. Its aim is to jointly tackle common challenges and find shared solutions in fields such as health, environment, research, education, transport, sustainable energy and more.

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
  • 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 UK GDPR.

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, or write to: Data Protection Officer, Sessions House, Maidstone, Kent ME14 1XQ.

The General Data Protection Regulation also gives you right to lodge a complaint with the Information Commissioner who may be contacted on 03031 231113.

Read our corporate privacy statement.