Coronavirus Vulnerable Persons Support

Tunbridge Wells Borough Council has used its own data sets from Housing, Council Tax, Benefits, clinical waste collection, assisted collection data, data from the One You service, Disabled Badge data and Electoral Registration (removing any data that we legally cannot use, such as polling district data) to identify individuals who may be vulnerable at this time and need support.

We are also receiving personal data from the Government (NHS, GDS and DWP) via Kent County Council, which may include sensitive data about you.

The types of data that we hold about you could be:

• Personal data, including name, age, date of birth, address, telephone number, email address
• Sensitive data (special category data), including NHS number, medical conditions, designation as a vulnerable person, and receipt of benefits.

Alongside this, Tunbridge Wells Borough Council is collecting personal data from residents of the borough who have requested our help. The data is collected through the contact forms on our website and from telephone calls received by our Customer Contact centre. The data we are collecting in this instance is:

• Personal data, including name, address, telephone number, email address, and personal data of any other adults or children you live with
• Sensitive data (special category data), including health status
• Other data, including food shopping preferences

We are legally allowed to use your data because it is substantially in the public interest to do so, and because it is in the public interest for Tunbridge Wells Borough Council to deliver critical services to its community. We do not need your consent to use your data for some of our processing, but you do still have rights which can be applied to your data (see below for more information).

We will rely on your consent to take part in some of our processing however, in particular where we are working with the Department for Environment, Food and Rural Affairs (DEFRA) and national supermarkets to secure priority slots for food deliveries. If we are using your data as part of this project, we will have already advised you of this, and asked for your consent first. You can remove your consent at any time, but will need to advise us either by telephone or email that you no longer wish to take part in the scheme. If you have already received food deliveries from the supermarket, you will need to advise them separately of your wishes.

For the data we are receiving directly from Government via KCC, we will hold this personal data in this format until 30 September 2020. At this point, the Government will review data sharing requirements between organisations, and either extend the period that we can hold and use or data or instruct us to destroy your records.

For the data we are collecting through our web forms and contact centre, we will hold this personal data in this format for two years starting from 23 March 2020.

We have combined and reprocessed data sets to identify you as a potential ‘vulnerable person’ in need of further support. We have not used any automated decision-making in this process. We may continue to use your information as part of monitoring our ongoing response to the epidemic, and we may share anonymised data with partner agencies after the event, in order to improve future service provision in response to epidemics. We will not re-use your personal data for any other purpose other than that stated above, unless it is compatible with the original purpose.

We may share your data with one or more of the following Controllers/Processors, who may use your data either on our behalf, or to provide you with services directly:

• Other departments within Tunbridge Wells Borough Council
• Kent County Council
• Town and Parish Councils in the Borough area
• Town and Country Housing Group
• Your Borough Councillor and/or County Councillor
• Other central Government departments, such as DEFRA or GDS

All data held by Tunbridge Wells Borough Council is stored securely on servers within the UK and will not be sent outside of the European Economic Area (EEA).

Only limited people within the organisation, and designated representatives of the ‘Controller/Processor’ organisations listed above will have access to your data. The data will only be held in password protected, electronic format, stored on servers within the EEA.

The data will be destroyed by our Controller/Processor organisations in line with their own retention policies, or immediately upon our instruction.

You have a right to:

• Be informed about how we will use your personal data (see this privacy notice).
• Request access to your personal data (a Subject Access Request).
• Request a copy of your personal data in an accessible (machine readable) format.
• Object to the way in which your data is used by us.
• Ask us to rectify your personal data (if you believe it to be incorrect).
• Ask us to delete your personal data.
• Ask us to restrict the use of your personal data.
• Ask us to process your information using human decision making (rather than automation or computer decision making).

We do not have to grant any requests resulting from the exercise of your rights above, but we do have to respond to you as soon as possible (or within one month) with reasons why we have denied them.

Where you have requested to exercise your rights under data protection laws, we will notify all other recipient organisations of your request. They will consider your request separately and may or may not grant the request depending on their own assessment.

If you have any questions or concerns about your personal data, or would like to exercise any of your rights under the Data Protection Act, please contact Jane Clarke, Data Protection Officer, Tunbridge Wells Borough Council, dataprotection@tunbridgewells.gov.uk, or call 01892 554077.

If you wish to make a complaint about how the Council is handling your data, you can email dataprotection@tunbridgewells.gov.uk or contact the Information Commissioner’s Officer at via their website or call 0303 123 1113.