Privacy notice relating to the processing of personal data by Rhondda Cynon Taf County Borough Council and Amgen Cymru for the purpose of Community Recycling Centres Body Worn Cameras
Introduction
This privacy notice is intended to provide information about how Rhondda Cynon Taf County Borough Council and Amgen Cymru (collectively referred to as ‘we or us’ in this notice) will use (or ‘process’) personal data about individuals for the purpose of Community Recycling Centres Body Worn Cameras.
This notice should be read in conjunction with;
Queries relating to this privacy notice
If you have any questions or queries relating to this privacy notice please contact us on the below;
By email : AmgenEnquiries@rctcbc.gov.uk
By telephone : 01685 870770
In writing : Amgen Cymru, Bryn Pica, Llwydcoed, Aberdare, CF44 0BX
Who we are what we do
The Council and Amgen Cymru have many employees working in our Community Recycling Centres who may be at risk from violence whilst at work. As an employer, we have a duty of care to ensure all our employees remain safe.
Due to an increase of threatening behaviour from visitors to our Community Recycling Centres, we have provided our employees with body worn cameras. The body cameras are worn during work hours and are only in operation when switched on by the employee if they are feeling uncomfortable or in a difficult situation.
We will inform you when the cameras are being switched on, no covert recording will be undertaken.
Whose personal data we process
We may process personal data relating to the following individuals who visit our Community Recycling Centres;
- Members of the public
- Traders
- Commercial traders
The categories of personal data we process
We may process the following categories of personal data when our Body Cameras are enabled;
- CCTV footage
- Contact details such as name, address, post code or telephone number
- Vehicle registration number
- Business name if displayed on your vehicle
Why we process the personal data
We process the data for the following, but not limited to activities;
- To ensure the safety of our employees whilst working on the front line.
- To capture instances of threatening or aggressive behaviour.
- To help Identify individuals who have been threatening or aggressive towards our front line employees.
- To report individuals to South Wales Police if deemed necessary in instances of threatening or aggressive beahavour.
- To report any environmental crimes which may have been captured to the RCT Enforcement Team
Our lawful basis for processing the personal data
Under the General Data Protection Regulation (GDPR), our lawful basis for processing the personal data is as follows:
- Legal Obligation Article 6 (c) GDPR – processing is necessary for compliance with a legal obligation to which the controller is subject.
- Public Task - Article 6 (e) GDPR – 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.
- Article 10, authorised by Schedule 1, Part 1 (1) Data Protection Act 2018 – Employment, Social Security and Social Protection.
- The Management of Health & Safety at Work Act 1999
- Health & Safety at Work Act 1974
- Environmental Protection Act 1990
Who or where we get the personal data from
We will receive the data directly from the body cameras if switched on by an employee.
Who we share personal data with
We may share the personal data with the following key organisations :
When sharing the personal data, we only share the minimum amount necessary in relation to the purpose.
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Who
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Purpose
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RCT Enforcement Team
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Data will be shared in the event of an environmental crime being captured on the body cameras.
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South Wales Police
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Data will be shared to investigate instances of aggressive and abusive behaviour to employees.
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Data Processors
A data processor is a company or organisation that processes personal data on our behalf. Our data processors act only upon our instruction. They cannot do anything with the personal data unless we instruct them to do so. They will not share the personal data with any organisation apart from us or use it for their own purposes. They will hold it securely and retain it for the period we instruct.
- IT System Supplier – Reveal Media Limited
How long we retain the personal data
We retain the footage for the following periods:
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Length of time
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Reason
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Camera Footage – 30 Days
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Statutory requirement
Please note, in the event of a reportable incident, the data may be kept for up to 7 years for that purpose.
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In keeping with the General Data Protection Regulation storage limitation principle, records are periodically reviewed. Not all personal data is retained. Only personal data that is relevant to the record is retained for the entire retention period Information that has no long term or evidential value is routinely destroyed in the normal course of business.
Your data protection rights
The General Data Protection Regulation (GDPR) gives individuals important rights, including the right of access to the personal data that the Council holds about you.
Click here for further information on your information rights and how to exercise them.
Your right to make a data protection complaint
You have the right to complain if you believe we have not handled your personal data responsibly and in line with good practice.
You can do this by contacting Amgen Cymen directly via one of the following communication methods. Most concerns can be resolved relatively quickly through a simple phone call or email;
By email : AmgenEnquiries@rctcbc.gov.uk
By telephone : 01685 870770
In writing : Amgen Cymru, Bryn Pica, Llwydcoed, Aberdare, CF44 0BX
Alternatively, you can raise a formal complaint via the Council’s Customer Feedback Scheme using the following link (Make a comment, compliment or complaint online) or you can contact the Council’s Data Protection Officer at Information.management@rctcbc.gov.uk.
Your right to make a data protection complaint to the ICO
You also have the right to complain to the ICO if you are unhappy with how we have used your data. However, we encourage you to contact us first and provide us with an opportunity to look into your concern and put things right.
The ICO can be contacted:
- Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
- Helpline number: 0303 123 1113
- Website: https://www.ico.org.uk