Concessionary Fares (ENCTS) privacy notice
We keep this privacy notice under regular review and it was last updated on 22 March 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. We are responsible as ‘controller’ of that personal information for the purposes of those laws. Our Data Protection Officer is Benjamin Watts.
The personal information we collect and use
Information collected by us
In the course of enabling access to transport schemes we may collect the following personal information when you provide it to us:
- date of birth
- National Insurance number
- contact details
- a photograph
- evidence of eligibility to access the scheme
- details of any additional needs you may have or other information needed to ensure the service we provide is appropriate for you
- financial information, if you need to make a payment for the service to be provided
We also obtain personal information from other sources as follows:
- other KCC departments
- commissioned providers of local authority services such as call centre and payment services
How we use your personal information
We use your personal information to:
- produce or replace travel passes
- accept payment in respect of fees and charges
- data may be processed automatically, for example when you submit an application via the internet and when a travel pass is manufactured
- process feedback regarding the services we have provided.
How long your personal data will be kept
We will retain documentary evidence which you have provided to support your application for 3 months in order to facilitate processing. We will hold your personal information for the period in which travel or benefit is being provided plus 1 year or in accordance with our published retention schedule. We will hold feedback regarding the services we have provided for 6 years.
Reasons we can collect and use your personal information
We rely on the public task Article 6(1)(e) and that the individual has given clear consent for us to process their personal data for a specific purpose Article 6(1)(a) as the lawful basis on which we collect and use your personal data.
We rely on the public task Article 6(1)(e) and that the individual has given clear consent Article 9(2)(a) for us to process their sensitive personal data for one or more specified purposes as the lawful basis on which we collect and use your special categories of personal data.
The provision of personal and/or sensitive personal data is required from you to enable us to facilitate your access to the scheme(s).
As we have a contractual basis for collecting your personal data if you do not provide the personal information required as identified then you will be unable to access the scheme(s).
Who we share your personal information with
We routinely share:
- personal data where it is necessary to enable access to schemes / benefits such as through the production of travel passes
- sensitive personal data where it is necessary to ensure that you are and remain eligible to access the scheme
This information may be shared with:
- 3rd party travel card manufacturers
This data sharing enables appropriate travel arrangements to be made.
For a list of our 3rd party suppliers please email email@example.com quoting a GDPR request.
We have a data processing agreement in place with our 3rd party travel card manufacturers 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.
We will also share your personal data with the National Fraud Initiative, which is administered by the Cabinet Office, for the purposes of assisting the prevention and detection of fraud.
Under UK GDPR you have a number of rights which you can access 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 United Kingdom General Data Protection Regulation.
If you would like to exercise a right, please contact the Information Resilience and Transparency Team at firstname.lastname@example.org.
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 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.