Driver improvement courses privacy notice
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 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 General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws. Our Data Protection Officer is Benjamin Watts.
Personal information we collect and use
Information collected by us
In the course of arranging for you to book onto a driver improvement course we collect the following personal and personal sensitive information:
- contact details (for example, name, postal address, telephone number and email address)
- proof of your identity (for example, date of birth)
- proof of your validity to drive a vehicle (for example, driving licence number and type of driving licence such as EU, UK or other)
- which course you will undertake. For example, the course date as well as the type of Driver Improvement course (such as the National Speed Awareness Course, What's Driving Us Course, Rider Intervention Developing Experience Course, National Motorway Awareness Course and Safe and Considerate Driving (SCD)
- 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 Kent County Council, 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 Kent County Council developed IT system to capture and manage your booking details to arrange the undertaking of a Driver Improvement Course.
How we use your personal information
We use your personal information to:
- arrange for a carer or interpreter to attend the course with you
- arrange a course booking and check the accuracy of course details
- arrange payment of the course fees
- send you a booking confirmation
- send you our terms and conditions
- send you course reminders and updates
How long your personal data will be kept
We will hold your personal information securely and retain it for 3.5 years in accordance with our retentions schedule and the National Driver Offenders Retraining Scheme (NDOR) licence requirements.
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 Article 6(1)b ‘processing is necessary for the performance of a contract to which the data subject is a party’ 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 & 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).
Who we share your personal information with
We routinely share your information 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.
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 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
- withdraw consent at any time (if applicable)
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.
GDPR also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted on 03031 231113.
Read our corporate privacy statement.