We encourage our customers to voice their concerns as an opportunity to put things right for them and to our improve services.
Processing activity - in order to deal with your complaints and/or enquiries, it is necessary for us to collect and hold personal information about you. The information collected and held will vary and depend on the nature of the service.
You can raise your complaint with us by telephone, e-mail, letter or in person. All we ask is that you clearly let us know how we can reply to your complaint, who is making the complaint and enough details about your complaint so that we can start dealing with it as soon as possible.
Information requirements - our processing activities may include:
- your address, telephone number, email address
- nature of your complaint
- who you are complaining about
- what you would like us to do to put things right
- equalities monitoring
- customer feedback
- call recording
- general correspondence between you and us on matters related to your complaint
- general correspondence between you, us and the Local Government and Social Care Ombudsman or the Housing Ombudsman (where you have complained about us to the Ombudsmen)
- general correspondence between you, us and the designated person (Housing Ombudsman related matters)
- general correspondence between you, us and elected Councillors and/or the Member of Parliament (where you have asked them to represent you)
You are not required to provide the personal information we ask for. If you choose not to do so, in many cases, we will not be able to provide you with a service or respond to any complaints or enquiries you may have.
Please note that we endeavour to collect equality data, for the purposes of statistical analysis only, so as to monitor compliance with our obligations under the Equality Act 2010, in particular, the Public Sector Equality Duty. Please refer to our Equalties Questionnaire Privacy Notice.
Lawful bases - our lawful bases for processing your personal information are:
- UK GDPR Article 6(1)(e) - where needed for the performance of a task carried out in the public interest under the laws that apply to us or the exercise of official authority vested in us
- where processing is necessary for the reasons of substantial public interest (UK GDPR Article 9(2)(g) and DPA 2018, section 10(3) and Schedule 1, Part 2, para.10)
Some of the information collected may comprise:
- special category personal data e.g. health - where processing is necessary for the reasons of substantial public interest (UK GDPR Article 9(2)(g) and DPA 2018, Schedule 1, para.6(1) & (2)(a));
- criminal convictions and offences (including alleged offences) -where processing is necessary for reasons of substantial public interest (UK GDPR Article 10 as supplemented by DPA 2018 section 10(5) & Schedule 1, Part 2, paras. 6(1) and (2)(a)).
We have a Data Protection Policy which sets out how this information will be handled.
Data sharing - your information may be shared with the relevant service department and if you have requested and/or complained about a service, may also be shared with our external service provider (where we have outsourced the service). We may also share your information with a number of other organisations for example Kent County Council’s social services where we have concerns about your and/or another individual’s well-being and the Ombudsmen (where you have complained to the Ombudsmen and we are asked to investigate your complaint). We may share your information with elected Councillors and/or Member of Parliament where you have asked them to represent you.
We rely on a number of exemptions, which allow us to share information without needing to comply with all the rights and obligations under the Data Protection Act 2018. Please refer to the Kent and Medway Information Agreement for further details on our sharing arrangements.
Retention period - we keep your personal information for the minimum period necessary. The information outlined in this Privacy Notice will be kept on our complaints’ database for two years from the date of the file
closure unless exceptional circumstances require longer retention eg: a pending court case. If you are a council tenant, your personal information will be retained on your tenancy file for the life of the tenancy. All information will be held securely and disposed of confidentially.
Anonymisation - ehinicity data and other personal information may be converted ('anonymised') into statistical or aggregated data in such a way that ensures that you cannot be identified from it. Aggregated data cannot, by definition, be linked back to you as an individual and may be used to conduct research and analysis, including the preparation of statistics for use in our reports such as showing the number of complaints we receive and/or equalities monitoring, but not in a form which identifies anyone.
Right to object - where processing your personal information is required for the performance of a public interest task (see our lawful bases above), you have the right to object on ‘grounds relating to your particular situation’. We will have to demonstrate why it is appropriate for us to continue to use your personal data.
Changes to this Privacy Notice - we review this Privacy Notice regularly and will place updates on our website.
Please refer to our Corporate Privacy Notice for further details of how we process your personal information and for details on your additional rights and our Equalities Questionnaire – Service Provision - Privacy Notice.
GDPR Complaints Process Privacy Notice