Driver improvement courses privacy notice
This notice explains what personal data (information) we hold about you, how we collect, how we use and share information about you. We are required to give you this information under data protection law.
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 and we are responsible as the 'data processor' for all of your personal data held for the purpose of booking you onto a Driver Improvement course. KCC are also the 'data controller' for the additional data we hold about you for your Driver Improvement course and we are responsible for the purpose of those laws. Our data Protection Officer is Benjamin Watts.
Personal information we collect and use
Information collected by us
When you book onto a driver education course, we collect the following personal and personal sensitive information:
- your contact details (e.g. name, postal address, telephone number and email address)
- proof of your identity (e.g. date of birth)
- proof of your validity to drive a vehicle (e.g. driving licence number and type of driving licence such as EU, UK or other)
- which course you will undertake, including the course date as well as the type of driver improvement course (such as the National Speed Awareness Course, National Motorway Awareness Course, What’s Driving Us Course, Rider Intervention Developing Experience Course or Safe and Considerate Driving Course)
- financial information to make a payment for the service to be provided. Payment can be made by a cheque or postal order information. Card payments can also be taken online (via a third party – ‘Pay360’, who are part of ‘Capita’) or over a secure telephone line (via ‘KeyIVR’, with a third party) however no personal details will be collected by our staff. Payments made in person with Kent County Council cashiers will be taken using a card machine. The cashiers will retain the last four digits of the credit or debit card number used for payment. You can also read Pay360/Capita privacy notice and KeyIVR’s privacy notice.
- any special requirements which may affect your ability to undertake a course (such as your physical or mental health condition)
- details of carer or interpreter if required to attend the course with you.
Note: No criminal offence information is collected by KCC, only the ‘course type offered’ and ‘the date they need to attend and complete the course by’ is made known to us.
We use a KCC developed IT system to capture and manage your booking details to arrange the undertaking of a driver improvement course.
We use a video conference platform Zoom to undertake digital classroom iCourse delivery. View Zoom's privacy notice.
How we use your personal information
We use your personal information to arrange:
- a course booking, to send you a booking confirmation, check the accuracy of course details, to send you our terms and conditions and to send you course reminders and updates
- payment of the course fees
- for a carer or interpreter to attend the course with you
- and invite you to attend a digital classroom iCourse via Zoom
- to protect the vital interests of clients through the NHS Test and Trace programme.
How long your personal data will be kept
We will hold your personal information securely and retain it for 1 year in accordance with KCC’s Retention Schedule and the National Driver Offenders Retraining Scheme (NDORS) licence requirements. Your records are anonymised after 1 year and retained for a further 2.5 years, in line with police records of your driving offence.
Reasons we can collect and use your personal information
The provision of your personal information and or sensitive personal information is required from you to enable us to facilitate your access to the driver improvement course.
If you do not provide your personal information or sensitive personal information, we will be unable to arrange for you to book onto and pay for a driver improvement course.
We rely on UK GDPR Article 6(1)b ‘processing is necessary for the performance of a contract to which the data subject is a party’, Article 6(1)(d) ‘processing is necessary to protect the vital interests of a data subject or another natural person’ and Article 9(2)(i) necessary for ‘public health’ as being the lawful basis on which we collect and use your personal information and special category (sensitive) personal information.
The data subject’s contract with us is via agreeing to its terms and conditions at the time of the course booking, which includes the accommodation of any additional needs which may affect the data subject’s ability to undertake a course (such as their physical or mental health or condition).
Our terms and conditions are part of a supplementary document with the Kent Police course offer letter.
We are additionally under NDORs licence to accommodate attendees of a driver improvement course where legally possible, with any additional needs which may affect the data subject’s ability to undertake a course (such as their physical or mental health condition).
Attending a digital classroom iCourse delivered by KCC, will require your prior agreement to the accepting the terms and conditions of Zoom.
Who we share your personal information with
We routinely share your information with:
- the relevant Police Force with whom your driving offence is with
- driver improvement course trainers who deliver the driver improvement courses
- services within our organisation who arrange a course date and respond to any enquiries you might have
- driver improvement course trainers where it is necessary to ensure that the course provision meets your particular need. This information is provided on the ‘course register’ for the trainers to be made aware as it is part of their role on the day of the course to accommodate their client where possible.
- commissioned providers of local authority services (call centre and payment services).
- Clarity Solutions who provide and maintain the NDORS computer booking system on behalf of Kent County Council.
- Royal Association for Deaf People (RAD) to arrange interpreters requested by client.
KCC use Video Platform Conference Zoom to deliver Digitial Classroom iCourses on behalf of Kent Police.
- Your participation on our courses is never recorded by Zoom
- Our courses and content are not monitored by Zoom
- Factor authentication is enabled for access on to our digital classroom iCourses
- View information on how Zoom protects your data security on their website.
This data sharing enables you to attend a driver improvement course.
We will share personal information with law enforcement or other authorities if required by applicable law.
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)
- 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. 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 Commissioners Office on individuals’ rights under GDPR.
If you would like to exercise a right, please contact the Information Resilience and Transparency Team at email@example.com.
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 firstname.lastname@example.org 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 email@example.com, or write to: Data Protection Officer, Sessions House, Maidstone, Kent ME14 1XQ.
Read our corporate privacy statement.