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This privacy notice is specifically in relation to the coronavirus (COVID-19) outbreak. It explains how Swale Borough Council will use and protect the personal data that has been provided to the Council in order to respond to this situation.

Personal and special category information we hold

We have been provided with and will process the following information:

  • NHS number
  • first name, other names, surname
  • date of birth
  • address, Postcode
  • contact Information - telephone numbers, email address
  • designation as a vulnerable person

In addition, data relating to medical conditions may be provided to us by individual data subjects.

Personal data can be anything that identifies and relates to a living person. This can include information that when put together with other information can then identify a person.

‘Special category’ data needs more protection due to its sensitivity and in relation to the above encompasses medical conditions, NHS number and designation as a vulnerable person.

How we received your personal information and why we need it

This information has been provided to us by Kent County Council, acting on the direction of the cabinet office through Government Digital Service (GDS). The Information has been derived from the NHS’ Vulnerable Patient List.

The personal information we process has been provided to us directly by the above to identify and assist vulnerable individuals within the Swale area in relation to:

  • obtaining food, medicine, medical, health and/or mental health support
  • to allows us to refer your data to ‘permitted recipients’ to aid you during the coronavirus (COVID-19) outbreak

Information to identify those residents in vulnerable groups will also be obtained from data already held by individual Council departments, for example: information held by the Revenues and Benefits Team and the Electoral Registration Office.

We may also receive personal information indirectly, from the ‘permitted recipients’ or yourselves in order to update the data we hold in relation to contact information and your current circumstances. In addition, whilst not requested, you may volunteer information relating to your medical conditions when you call us or we contact you and this information will be held by the Council as part of the call recording.

What we use the information for

We use the information that we have been provided in order to:

  • identify individuals that are classed as vulnerable within the Swale area
  • identify how we as a council can support vulnerable individuals
  • use the information held to provide aid directly from Swale Borough Council
  • provide information to ‘permitted recipients’ who may contact you offering assistance during this time
  • send out valuable and important information regarding the current situation

Who we share your information with

In this current pandemic we may share your information with other public authorities, emergency services, permitted recipients and other relevant third parties where it is necessary to do so.

Permitted recipients include those organisations that are running the Community Hubs to assist with the Council’s response and include:

  • Optivo – for Sittingbourne residents
  • Children and Families Limited – for Isle of Sheppey residents
  • West Faversham Community Centre - for Faversham residents
  • Swale Community & Voluntary Services

How the law allows us to use your personal information

Swale Borough council rely on the following lawful basis’ to process your personal data:

  • General Data Protection Regulation (GDPR) article 6(1)(d) protection of the vital interests of the data subject
  • GDPR article 6(1)(e) – performance of a task carried out in the public interest,
  • GDPR Article 9(2)(g) – substantial public interest
  • Data Protection Act 2019 (DPA), schedule 1, part 2, paragraph 6 – Statutory & Government Purposes

We confirm that we will only process what we need to provide help to vulnerable people during the coronavirus (COVID-19) outbreak, this includes the disclosure of information to permitted recipients.

When disclosing to the ‘permitted recipients’ we will only be providing enough information for them to carry out the agreed purpose stated above. The information shared will include your name, address, contact details and that you have been designated as a vulnerable person.

Where your information is stored

All data held by Swale Borough Council is stored on servers in the UK and no information will be transferred outside of the European Economic Area.

How long we keep your information for

We will hold your personal and special category data solely for the purpose of the coronavirus (COVID-19) outbreak, until such time as we receive notification from central government that there is no longer a crisis or for a period of two years; whichever is the longer.

Telephone recordings will be deleted after 6 months.

Where we no longer need to continue processing your personal data it will be destroyed securely.

Your data protection rights

Under data protection law, you have rights including your right:

  • of access - You have the right to ask us for copies of your personal information
  • to erasure to processing - You have the right to ask us to erase your personal information in certain circumstances
  • to data portability - You have the right to ask that we transfer the personal information you have provided us to another organisation, or to you, in certain circumstances

For further details in relation to your rights please refer to the Council’s general privacy notice.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Contacting us

If you would like to contact us with any questions regarding your personal data or wish to exercise any of your data protection rights please contact the Data Protection Officer by emailing or by calling 01795 417114.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at

You can also complain to the Information Commissioner's Officer (ICO) if you are unhappy with how we have used your data.

The ICO’s address:

  • Information Commissioner’s Office
  • Wycliffe House
  • Water Lane
  • Wilmslow
  • Cheshire
  • SK9 5AF

Helpline number: 0303 123 1113.

ICO website.

Changes to this Privacy Notice

This privacy notice will be treated as a living document and will be reviewed regularly as the situation changes. If there are any changes made these will be updated on our website.

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