Privacy notice - Kent and Medway Care Record (KMCR)

Privacy notice - Kent and Medway Care Record

Publication date:
22 April 2021
Date range:
April 2021 - May 2021


Kent and Medway Care Record
Subsection Information
1. Data Controller contact details

Kent and Medway NHS and Social Care Partnership Trust
Head Office, Farm Villa, Hermitage Lane, Maidstone, Kent,

2. Data Protection Officer contact details Leanne McDougall
Head of Information Governance, St Michaels House, St Michaels
Road, Sittingbourne, Kent, ME10 3DW
3. Purpose of Processing

We need to collect and record information about you in order to
provide the right kind of services to meet your needs.

Appropriate collection and sharing of information is an essential part of the provision of your safe and effective care. You could be put at risk if we do not have access to relevant, accurate and up to date information about you.

4. Lawful basis for processing

The processing (sharing) of Personal Data for these purposes is permitted under Articles 6(1) d and 6(1) (e) of the EU General Data Protection Regulation 2016/679 (GDPR) and UK Data Protection Act 2018 (DPA):

  • Vital Interest: processing is necessary in order to protect the vital interests of the data subject or of another natural person.
  • Public Task: the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

The processing (sharing) of special categories of Personal Data via the Kent and Medway Care Record system is permitted under Article 9 (2) (h) and Article 10 of the GDPR and the UK Data Protection Act 2018 (DPA):

  • Direct Care and Administration: processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards.
5. Recipient or categories of
recipients of the processed data

Personal Data (including special category data) will only be shared between the health and social care organisations which have signed the Kent and Medway Care Record Joint Controller or Data Sharing Agreement, and authorised data processors for the purposes of providing health and social care.  These currently include:

  • Dartford and Gravesham NHS Trust (D&G)
  • East Kent Hospitals University NHS Foundation Trust (EKHUFT)
  • Medway Maritime Hospital - Medway NHS Foundation Trust (MFT)
  • Maidstone and Tunbridge Wells NHS Trust (MTW)
  • Kent and Medway Partnership NHS and Social Care Partnership Trust (KMPT)
  • North East London Foundation Trust (NELFT)
  • Kent Community Health NHS Foundation Trust (KCHFT)
  • Virgin Care Services
  • Medway Community Healthcare (MCH)
  • General Practitioners
  • South East Coast Ambulance Service (SECAmb)
  • Integrated Care 24 (IC24)
  • Out of Hours providers (currently IC24, SECAmb and MCH)
  • Kent and Medway Clinical Commissioning Group (KM CCG)
  • Kent County Council (children and adults services) (KCC)
  • Medway Council (children and adults services) (MWC)


In the future it is likely that the  Kent and Medway Care Record will be extended to a wider range of health and care providers.  This may include:

  • Other Providers of community health services
  • Community Pharmacies (Chemists)
  • Hospices.
6. Rights to object

You also have the right to object of sharing Personal Data via KM Care Record (the right to object to processing).  However, the NHS strongly recommends the sharing of data and real-world experience demonstrates that it leads to higher quality and safer care.  An objection to sharing your information will mean that your data will not be shared for any kind of direct care, including extended hours GP access and emergencies.  We ask you to think carefully before making this decision as sharing your health and social care information will make it easier for services to provide the best treatment and care for you.

If you chose to object, we may still need to share data for your care, but it will be using less immediate methods such as email. For example, with KM Care Record, your GP can refer you to a hospital consultant who can then see all the data they may need, but if you are objecting they can only see what the GP has included within their email referral.

If you do wish to object, you should therefore contact the clinician involved in your care, or the other organisations involved in your care and understand what it means for you.  You may also contact KCHFT at  If you choose to object:

You may have to answer questions repeatedly because your full history may not be available to the care professional assessing you.

Decisions about your care may take longer, even in emergency situations, as history needs to be confirmed.

Some medical tests may get repeated unnecessarily e.g. if you had a blood test with your hospital consultant, your GP may not be able to see this

7. Right to access and correction

To access your Personal Data you should contact the Kent Community Health NHS Foundation Trust (KCHFT) Legal team by emailing them at

You have a right to see or obtain a copy of personal information that we hold about you in accordance with General Data Protection Regulation 2016/679 (GDPR), and the UK Data Protection Act 2018 (DPA).

All requests for access to personal information must be submitted in writing. Please note proof of identity will be required for us to be able to assist you.

If you believe that the data received in response to the request contains errors, you should contact the relevant KM Care Record partner’s Data Protection Officer (details of these will be provided to you with our response).
8. Retention Period As KM Care Record is used to share data contained within a local record the retention of data is set by individual providers who follow the NHS Records Management Code of Practice for Health and Social Care 2020.
9. Right to Complain

You can get further advice or report a concern directly to:

In the first instance – the KCHFT Data Protection Officer (via email) at

You also have the right to contact the UK’s data protection supervisory authority (Information Commissioner’s Office) by:

Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Telephone: 0303 123 1113 (local rate) or 01625 545745 (national rate)

Email: Information Commissioners Office

Further information about the way in which the NHS uses personal information and your rights is published by NHS Digital: