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Council Vehicles Tracking Privacy Notice

Privacy notice relating to the processing of employee personal data by Rhondda Cynon Taf County Brough Council when tracking council vehicles 

This privacy notice is intended to provide information about how the Council will use (or ‘process’) employee personal data when tracking Council vehicles.

This notice should be read in conjunction with the Council’s corporate privacy notice.

Introduction

All vehicles owned by the Council are fitted with a GPS (Global Positioning System) tracking device. Vehicles that have been leased or hired by the Council for a period of three months or more are also fitted with a GPS device.

The GPS device tracks the location/movement of the vehicle, the time and date it moves/is idle and the speed it travels. By default, this information can be associated with and linked to the driver of the vehicle and in some circumstances its passengers. Vehicles are monitored 24/7. 

Installing GPS devices on council vehicles helps to make fleet management more efficient, cost effective and assists the Council in its duty of care to its employees.

The Council has a Driving on Council Business Policy which makes employees aware of the vehicle tracking and the reasons for the monitoring. This policy should be read in conjunction with this privacy notice.

The Data Controller

The Council is the data controller for the personal data captured when tracking council vehicles.

The Council is registered with the Information Commissioner’s Office (ICO) as a controller under reference Z47870100.

The Data Protection Officer

The Councils Data Protection Officer (DPO) can be contacted in relation to data protection matters.

Should you have the need to contact the Data Protection Officer directly you can do so via email at Information.management@rctcbc.gov.uk

The categories of personal data we process

The information captured when tracking a vehicle can be associated with and linked to the driver of the vehicle. GPS tracking on vehicles therefore indirectly captures the following personal data relating to the driver:

  • The location and movement of the driver, and in some circumstances its passengers when using the vehicle
  • Time/date the driver uses/doesn’t use the vehicle – this can be related to the drivers working times
  • Speed at which the driver is travelling

Why we process the personal data

The purpose of GPS tracking on Council vehicles is to:

  • To make fleet management more efficient and cost effective e.g.:
    • to effectively respond to service demands
    • to effectively configure employees (e.g. working patterns, locations) to provide an efficient and responsive service
    • to reduce wear and tear on vehicles, thus reducing maintance costs.
    • to reduce fuel wastage
    • to lower insurance costs
  • Enhance the security of the vehicles as the whereabouts of the vehicle will be known at all times.
  • To support the manager in fulfilling their responsibilities to safeguard employees that may be vulnerable or at risk due to lone working issues.
  • To monitor driver compliance with the Driving on Council Business Policy e.g. driving performance, unauthorised private use. Where there is a serious breach of policy, GPS tracking information will be used to support disciplinary proceedings.
  • To monitor driver performance and to identify and support the need for driver training e.g. as a result of driver performance to reduce accidents etc.
  • To protect the Council from false claims made by the public or other road users leading to reduced 3rd party claims.

Our lawful basis for processing the personal data

Under the General Data Protection Regulation (GDPR), our lawful basis for processing the personal data when tracking vehicles is:

  • 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 a performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

The primary legislation, regulations and guidance that supports this includes but is not limited to;

Who or where we get the personal data from

We use a system called Quartix Vehicle Tracking to track Council vehicles.

Who we share personal data with

The data captured by the GPS tracking system is accessed by and may be shared with:

  • Fleet Management
  • Employees Line Manager / Management Team etc.
  • Human Resources – in the event of disciplinary action.
  • Insurance Section – in the event of damage to a vehicle. Where there is a third party claim relevant information may be shared with the third party’s representative e.g. insurer.

Data Processors

A data processor is a company or organisation that processes personal data on behalf of a controller (the council).

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.

For the purpose of vehicle tracking we use a system called Quartix.

How long we retain the personal data

We retain the personal data contained within Vehicle Tracking records as follows:

Record

Retention period

GPS Tracking Data (held within the Quartix Vehicle Tracking system)

GPS data is routinely destroyed 7 years after the data is captured

 

Please note where vehicle tracking data is used as evidence in a disciplinary or insurance claim etc. system reports may be held longer for that purpose.

Your data protection rights

The General Data Protection Regulation (GDPR) gives you important rights, including the right to access the personal information the Council hold 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 raise a complaint if you believe the Council has not handled your personal data responsibly and in line with good practice.

If you have a concern about the processing of your personal data when tracking council vehicles, you should contact your Line Manager in the first instance.

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 personal data, but we encourage you to speak to your Line Manager, Human Resources or the Information Management team first. Most concerns can be resolved relatively quickly through a simple meeting or discussion.

The ICO’s contact information is:           

  • Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
  • Helpline number: 0303 123 1113
  • Website: https://www.ico.org.uk