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The Financial Hardship Team privacy notice

We keep this privacy notice under regular review and it was last updated in April 2026.

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

Who we are

We collect, use and are responsible for collecting certain personal information about you. When we do so we are regulated under the General Data Protection Regulation (‘UK GDPR’) and the Data Protection Act 2018. We are responsible as ‘controller’ of that personal information for the purposes of those laws. Our Data Protection Officer is Benjamin Watts.

Our Financial Hardship team sits within the Chief Executive’s Department’s Strategy, Policy, Relationships and Corporate Assurance division and delivers a range of projects supporting Kent residents in or facing financial hardship. These include but are not limited to ReferKent, Digital Kent services, and UK government funded grants in place to support with financial hardship and crisis.

Personal information we collect and use

We collect and use a range of personal information when you provide it to us, or when it is provided to us by an agency on your behalf, to deliver our projects and services. Please note, the list below covers the range of projects and services we offer, and we only collect the data needed in each case, rather than collecting all the below data for each resident.

We collect:

  • personal details (such as name, date of birth, gender, National Insurance details, address and contact details)
  • the personal details and contact details that you are associated with (if applicable, such as parent or carer, child, spouse or those living in the same household)
  • the organisation name and contact details that you are associated with (if applicable, such as your school or college, GP practice, your district or borough council and parish or town council)
  • information related to our relationship with you (such as agreements, correspondence, meeting notes and attendance at events)
  • information related to any support from other services and any benefits you are receiving
  • information relating to your education, employment and career history
  • information relating to your digital access, digital skills and digital engagement
  • opt-in request to receive newsletters and notifications from our service about services on offer
  • financial information such as income, benefits and work status
  • information about your current circumstances and why you require assistance
  • information about the goods and services you require support with.
  • information about social grade, a classification system used to group people based on their socio-economic status
  • other documentation when needed to support an application, such as utility bills and payslips.

Special categories of data

This data is treated with extra care:

  • Information about health conditions or disabilities that may be relevant to your circumstances or the support you require.
  • Information about gender is collected for equality monitoring and evaluation purposes only.
  • Other relevant information about your current circumstances and why you require a referral (if relevant).

Reasons we can collect and use your personal information

Depending on the nature of the service or reason for collecting and using your personal information, we rely on one or more of the following articles:

  • 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 as the lawful basis on which we collect and use your personal data.
  • Article (9)(2)(g) - Reasons of substantial public interests. We rely on the ‘equality of opportunity or treatment purpose’ condition from Schedule 1 of the Data Protection Act 2018 when relying on Article 9(2)(g) to process your special category data.
  • Article 6(1)(a) – Consent: the individual has given clear consent to process their personal data for a specific purpose.

How we use your personal information

We use your personal information to:

  • assess and decide if you meet the criteria for our services
  • work with you to assess your needs and how they can best be met
  • support you in being digitally inclusive and capable
  • maintain a record of people who are supported by the team or access its services
  • process applications for support and arrange delivery of any services or support
  • investigate claims of the project or scheme’s misuse
  • evaluate, impact assess, and quality assure the services we provide
  • inform future service provision and the commissioning of services
  • communicate information to you about other relevant services, opportunities and events delivered by the Financial Hardship Programme (with consent)
  • promote the Financial Hardship Team services on social media and other marketing methods for case studies (with consent)
  • liaise with agencies, companies and charities on your behalf where relevant and appropriate
  • keep you safe from harm
  • respond to enquiries and comments.

Who we share your personal information with

The organisations or third parties we may share your personal information with will vary depending on the service being provided or accessed. To support you and administer our services we may share your data with the following third parties:

  • Teams within Kent County Council or Medway Council (whichever is most appropriate) working to improve outcomes for people.
  • Commissioned providers and suppliers of the local authority (working to support digital inclusion and capability, or to administrate an award).
  • Digital champions delivering support (verified and approved by the digital inclusion and capabilities team).
  • Other local authorities or councils (such as borough, city, district, parish and town councils).
  • Partners and stakeholders improving digital inclusion and financial hardship (such as voluntary and community sector organisations, housing associations, telecoms providers and NHS).
  • Funders (such as European Structural Investment Fund, NHS or the UK government).
  • Commissioned suppliers to conduct evaluation, impact assessments and quality assurance on the service we provide.
  • In the case of a referral being made, partner agencies, such as volunteer organisations and statutory organisations (for example, district councils, borough councils, housing associations, Department for Work and Pensions (DWP)) who may receive your referral and provide support.
  • External providers including Firmstep LTD (case management software), Cantium Business Solutions Ltd (software support), Capita PLC (our contact centre provider), Money and Pensions Service (MaPS) to access the Money Adviser Network (MAN) (this is a service to refer individuals to debt agencies so that they can obtain free financial advice).
  • Internal services such as Social Services, Invicta Audit and Counter Fraud, and wider internal financial hardship programmes that may also help improve your financial resilience.
  • Partner agencies, such as volunteer organisations and statutory organisations in order to provide additional support (such as vouchers) where available and appropriate.
  • Other supporting professionals who are supporting your application.
  • Additional providers including [but not limited to] Beyond Holdings Limited (Evouchers).

We may share your personal data to enable us to verify the information provided and to reduce the risk of fraud affecting Kent’s public services. For this purpose we may share your data with the National Fraud Initiative, which is administered by the Cabinet Office, and/or with the Kent Intelligence Network (KIN).

Read the Kent Intelligence Network privacy notice for more information.

How long your personal data will be kept

Crisis Resilience Fund (including heating oil)

Records will be retained for no longer than 6+ current financial years from the date of application before the records and all data we have in it is permanently deleted from its secure storage.

For the purpose of referring individuals to MaPS for the MAN service, a consent log will be retained for no longer than 1+ current financial year from the date of application before the records and all data we have in it is permanently deleted from its secure storage (as per our retention schedule record AS4.12.17).

ReferKent

For the purpose of referring individuals through ReferKent, personal information will be anonymised after six months from the date of the referral being made. See the ReferKent retention period AS4.12.17 in our retention schedule for more information.

Digital Kent

We will hold your personal information securely and retain it for a maximum of 10 years, after which the information is made inaccessible to system users or securely destroyed.

We will hold children’s (aged 13 or under) personal information securely and retain it for a maximum period of three years, after which the information is made inaccessible to system users or securely destroyed.

Your rights

Under 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
  • You will be entitled to withdraw your consent at any time by contacting the Financial Hardship Programme. The withdrawal of consent would not affect the lawfulness of the processing that took place before its withdrawal.
  • 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 GDPR.

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.

Contact

Contact the Information Governance 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, ME14 1XQ.

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.

Cookies

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Find out how to manage cookies on the UK Information Commissioner’s Office website.

Types of cookies we use

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