How we use your personal data for the Get it free condom service
Revised September 2019

What service is being provided?
A free, confidential condom distribution scheme facilitated by METRO, which give young people easy access to free condoms in Kent & Medway.

What personal data do we need from you?
Name, Address including Postcode, Phone number, Email Address, Date of Birth 

What 'special types' of personal data do we need from you?
Current sexual orientation, gender at registration, racial or Ethnic origin

Who will be using your personal data?
The Data Controller for this service is Kent County Council or Medway Council depending on where you live. The Data Protection lead for them can be found on their website.

METRO acts as a Data Processor for this service.

What will it be used for and what give us the right to aske for is and use it?
We use your information to do the following things that are a part of this service;

  • Delivery of the condoms service
  • Improve the condom service
  • In the event of a safeguarding concern to protect yours or others safety
  • In the event where we need to report or prevent a crime

If we cannot use your data we would not be able to deliver condoms to you that you have requested to receive

We only use your information with your consent unless the law requires us to use it (for example, for safeguarding or crime prevention)

Who else might we share your data with?
Social Services and/or the Police but only where we believe there is a safeguarding or crime concern

How long will your data be kept?
We will keep your information on file for 5 years after the date of your order. Where you consent to receive emails from us about this service we will keep you on the list until you let us know that you no longer wish to receive this information.

Our use of your data will be subject to the following legal rights:

  • Your Right to be Informed
  • Your Right to Access your personal data
  • Your Right for us to Rectify your personal data
  • Your Right to Restrict our processing of your personal data
  • Your Right to object to Automated decision making and profiling

Visit the following links for more information about Privacy Law, our obligations and  your Rights:

The ICO Guide to the General Data Protection Regulation 2016

The ICO Guide to the Data Protection Act 2018

If you have concerns over the way we are asking for, or using, your personal data, please raise the matter with our Data Protection Lead by the following means:
Email: [email protected]
Phone: 020 8305 5000

If you still have concerns following our response you have the right to raise the matter with the Information Commissioner's Office:
Postal Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Phone: 0303 123 1113

For our full Privacy notice: 

Confidentiality Policy

  • METRO needs to obtain and keep personal information on services users, volunteers and paid staff in order to function properly and provide appropriate services. We recognise the importance of confidentiality to individuals and particularly regarding their sexuality, HIV status and mental health status, because of the stigma and prejudice that currently exists. We are committed to ensuring that personal information is collected only for specific purposes and that no more is collected than is needed for those purposes.
  • METRO maintains written records on users of its services for two reasons:
    a) to enable it to provide them with emotional and practical support and to refer on to other agencies as appropriate, and
    b) to provide (anonymous) monitoring statistics to outside bodies such as funders.
  • All paid staff and volunteers are required to conform to The Metro’s Policy on confidentiality and will be required to sign a contract to confirm their acceptance of the policy. A breach of confidentiality may subject a worker or volunteer to disciplinary proceedings.

Confidentiality - treating with confidence personal information about individuals, whether obtained directly or indirectly or by inference. Such information includes name, address, biographical details, and other descriptions of the client’s life and circumstances, which might result in identification.

Confidential Information - private or secret

Personal Information - information which relates to an individual who can be identified from that information (or from that and other information in the possession of the recipient) which includes any opinions or judgments about the individual. As well as name and address this could include physical description, health, job or financial details and information about family and friends.

Disclosure of personal information - giving information in any way to another organisation or individual outside of METRO.

Records - all personal information, files, indexes and diaries that may be held in either computer or manual systems.

  • This section outlines the principles that underpin the working practice of METRO regarding confidentiality.
  • Personal information is only divulged within METRO to ‘those who need to know it’ in order to provide a service and for the purposes of management and supervision.
  • All services offering advice and support of any nature are confidential.
  • Information is stored securely either on computer or in manual records.
  • Personal information about service users should only be disclosed outside METRO when the individual has given consent, though in exceptional circumstances e.g. threats of violence, actual violence, risk of harm to self or others and suspected and actual child abuse, this may not always be possible. When referring to other agencies, the issue of confidentiality will be addressed with the individual being referred.
  • Service users, staff and volunteers can have access to information, which is held on them this will be clearly stated.
  • General information and statistics gathered for planning and monitoring purposes are always anonymous.
  • The general principal in collecting personal information should be that it is only sought for specific purposes and that it should be sufficient, but not more than sufficient for that purpose, i.e. ‘ the least information required is the most information recorded’.
  • When the recording of information is necessary to the provision of any of METRO's services, the principles of the confidentiality policy must be explained to the individual before requesting any personal information.