Who are we?
Our collection, use and disclosure of your personal information is regulated by the United Kingdom General Data Protection Regulation 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
To participate in some of the activities you will be asked to register with the website. In the course of registering, you will be asked to provide a user name, which will be what people see if you make a comment on the website. We recommend using an anonymous user name.
You will be asked to provide an email address to create an account which will enable you to take part in some engagement and consultation activities. It will also mean you can choose to receive updates on specific or general engagement and consultation activities.
You will be asked to enter your user name and email address to sign into your account on the website.
We collect your age, sex and the district you live in when you provide it to us on the registration form. We also ask you the districts and topics you are interested in. This information is optional and you do not have to provide it to create an account.
Please note that you are able to browse any publicly accessible sections of this website completely anonymously without registering.
Engagement and consultation information
This is the content you create as part of your interactions with this website. It can include:
- responses to questionnaires and polls, comments on discussion forums, documents, maps, idea boards, stories and guestbooks or questions asked through the Q&A tool
- equalities data collected through questionnaire response - age, sex, ethnicity, religion, sexuality, disability, pregnancy or maternity or if you are a Carer
- employment and education details
- postcode collected through questionnaire response.
We ask you not to provide information that will identify you in your written answers to questions and comments on this website.
You do not need to submit any equalities or postcode information if you do not want to. KCC is committed to the principle that all our customers have the right to equality and fairness in the way they are treated and in the services that they receive. Any information you do give will be used to see if there are any differences in views for different groups of people, and to check if services are being delivered in a fair and reasonable way.
No personal information which can identify you, such as your name or email address, will be used in producing public reports. We will follow our Data Protection policies to keep your information secure and confidential. Your equality data will be anonymised (registration information will be removed) before it is shared with any external organisations who have been commissioned on individual projects to undertake analysis and reporting on our engagement and consultation activities.
IP addresses are collected for website security purposes by Granicus who provide the software for this website. This information will not be linked to your responses and registration information.
We also use Google Analytics to view data related to our website’s traffic and activity. This information may include page visits, length of visit, browser (e.g. Edge, Chrome etc.) or device type (e.g. desktop, mobile etc.) and the site you were on before you clicked over to this website.
IP addresses are held within the Google Analytics platform, which is separate from this website and will not be linked to your responses and registration information.
How we use the information we collect
We collect this information in order to:
- facilitate your participation in our consultation and engagement activities
- understand your views about a particular topic or KCC activity
- analyse consultation and engagement activity
- inform KCC’s future strategy, policy, service design and budget planning
- undertake equalities monitoring
- authenticate and verify your account (through your email address)
- communicate information to you about engagement and consultation opportunities, events and other initiatives, if you have requested to be kept informed
- remind you to update your account information
- inform you of the outcome of the engagement and consultation activities, if you have requested to be kept informed
- respond to enquiries and comments
- to contact you if you object to a Traffic Regulation Order or in other consultations where we are required to contact you
- understand how users interact with the website and improve how our website functions
- protect the integrity of discussion from individuals and groups who may attempt to unduly influence the outcomes of the consultation process
- provide access to private areas of the website for invited users.
This website is moderated by Granicus’ moderation team who provide support to ensure participants are safe from malicious, inflammatory, and illegal materials. If you post something to this website, which is removed by the moderators, you will receive a notification via email informing you of the decision. You will be informed as to which of the moderation rules you are in breach of and asked to review and resubmit your contribution. Moderators do not have access to your user information stored on this website. Moderators are only able to view your publicly visible user name and text or image contribution for the express purposes of moderating those elements. The Moderation Policy is available to view on the website.
We may use your postcode to analyse the geographical spread of responses and in some cases to understand in more detail how responses are impacted by location. We will only ask you for the first five characters of your postcode to avoid being able to identify specific households in less populated areas.
We may use your postcode to carry out a type of profiling to estimate which one of a number of lifestyle groups you are most likely to fall into. We do this using geodemographic segmentation tools. We do not make any decisions about individual service users based solely on automated processing, including profiling.
How long your personal data will be kept
The personal information you provide to create an account (register) will be kept unless it has been inactive for more than two years.
We will hold any personal information provided by you as part of engagement or consultation activity for up to six years following the closure of a consultation.
Reasons we can collect and use your personal information
For engagement and consultation activity carried out on this website we rely on UK GDPR Article 6(1)(e): ‘processing is necessary for the performance of a task carried out in the public interest' and Article 6(1)(c) ‘for compliance with a legal obligation to which the controller is subject’ as our lawful basis.
We rely on Article 6(1)(a) consent when you register and request to be notified of updates and alerts. You can opt out of these updates and alerts at any time by updating your registration profile.
We also rely on consent for the collection of any non-essential cookies.
You can delete your account with us at any time by contacting firstname.lastname@example.org. Please note that all consultation responses will be deleted from the website with the deletion of an account. However, we will not be able to delete responses that have been included (in aggregate, non-identified form) in reports (or data tables) already produced based on the responses available at that time.
You can also update your information and preferences at any time by logging into your account.
We rely on Article 9(2)(g) ‘processing is necessary for reasons of substantial public interest’ (statutory etc and government purposes, equality of opportunity or treatment) as the lawful basis on which we collect and use your special category data.
The processing is necessary for statutory purposes including equalities monitoring or to understand the potential impact of proposals on conditions related to special category data within your response (e.g. when identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people with the view to enabling such equality to be promoted or maintained). It is necessary for identifying or keeping under review the existence or absence of equality of opportunity or treatment between groups of people with the view to enabling such equality to be promoted or maintained. You can read KCC’s Equality Policy on our website.
Who we share your personal information with
We may share your personal data and feedback with those listed below. In some cases that may include your user name and email address:
- services within the Council who are responsible for the management of the engagement or consultation activity
- a third-party supplier who has been contracted to independently analyse the consultation responses. Registration information (user name and email address) will be removed before data is shared
- organisations such as schools and academies with whom we may be consulting in partnership or on behalf of
- district or borough councils or government departments with whom we may be consulting in partnership or on behalf of. Registration information (user name and email address) will be removed before data is shared.
We will share personal information with law enforcement or other authorities if required by applicable law.
Any personal information provided that could identify you will be removed before consultation results are published.
Granicus’ moderators do not have access to your user information stored on this website. Moderators are only able to view publicly visible user names and text or image based contributions for the express purposes of moderating those elements. If you feel a comment or contribution on the site is in breach of the rules you are within your right to alert the moderators through the “alert moderator” link near the comment you believe needs to be escalated to the moderation team. Alerting a moderator will not reveal your identity to the person who posted the comment.
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
- 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.
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.
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.
If you would like to exercise a right, please contact the Information Resilience and Transparency Team at email@example.com.
Withdraw your Consent
Where we rely on your consent, you can withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
You can do this by:
- clicking on unsubscribe on any emails received from Let’s talk Kent
- updating your registration profile
- clicking on cookie management buttons when accessing the website
- contacting KCC directly
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.
Our website may contain links to other websites. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of linked websites and we suggest you review the privacy policies of those websites before using them.
While no online service is completely secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take all reasonable measures 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, Kent County Council, Sessions House, Maidstone, Kent, ME14 1XQ.
The United Kingdom General Data Protection Regulation also gives you the right to lodge a complaint with the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone 03031 231113.
For further information visit https://www.kent.gov.uk/about-the-council/about-the-website/privacy-statement.