Road Safety Unit Service Privacy Notice

Introduction

This privacy notice is intended to provide information about how Rhondda Cynon Taf County Borough Council (referred to as ‘RCTCBC’, ‘Council’, ‘Local Authority’, ‘we’) will use (or ‘process’) personal data about individuals for the purpose of delivering road safety eduction to children and adults across the borough.  

This notice should be read in conjunction with;

• The Council’s corporate privacy notice 

The Data Controller

The Council is the data controller for the personal data processed for the purposes of road safety.

The Council is registered with the Information Commissioner’s Office (ICO) as a controller under reference Z4870100. 

Queries relating to this privacy notice

If you have any questions or queries relating to this privacy notice please contact the Road Safety Unit:

By email : roadsafety@rctcbc.gov.uk 

By telephone : 01443 494785 

In writing : Road Safety Unit, 2 Llys Cadwyn, Taff Street, Pontypridd, CF37 4TH 

Who we are what we do

The Road Safety Unit delivers a diverse range of front line and support services. We manage the School Crossing Patrol Service and are involved in many joint partnership road safety initiatives such as “Operation Options”.

Our main priority is to provide road safety education, publicity and training, including;

-       Pass Plus Cymru

-       Kerbcraft / Child Pedestrian Training

-       National Standards Cycle Training

-       Megadrive

-       Mature drivers course

-       Operation Options / Atal

Whose personal data we process

We may process personal data relating to the following individuals:

• School children and young people attending one of our courses
• Parent/carer information who give permission for their child to attend a course
• Young drivers (17-25) attending Pass Plus Cymru
• Adults aged 18 + attending training such as mature drivers
• Driving Instructors

The categories of personal data we process

We may process the following categories of personal data for Road Safety purposes:

• Contact details such as name, address, post code, email address and telephone number.
• Date of Birth
• Driving licence number (for Pass Plus Cymru candidates)
• Driving endorsements
• Participants medical/health/disability information that the trainer should be aware of when you attend a course
• Approved Driving Instructors information including financial, the ADI licence, driving licence, DBS certificate and relevant insurance certificates 

Why we process the personal data

We process the personal data for Road Safety purposes, this may include but is not limited to the following activities;

• To administer participation in road safety courses.
• Administer the check code provided by participants to check for any driving endorsements on the DVLA website.
• Manage health, medical and disability information to ensure instructors can make appropriate adjustments for participants safety.
• Recording and reporting of incidents and accidents that may occur when participating in a road safety course.
• Verifying and managing approved driving instructors (ADI).
• Processing financial data, including payments to ADIs and training providers etc.
• Monitoring and reporting to Welsh Government for reporting and financial purposes. 

Our lawful basis for processing the personal data

Under the General Data Protection Regulation (GDPR), our lawful basis for processing the personal data for road safety activities, including attending a course, health and safety are;

• Legal Obligation 6(1)(c) – processing is necessary for compliance with a legal obligation to which the controller is subject. 
• Public Task - Article 6(1)(e) – 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.
• Substantial Public Interest – Article 9 (2)(g) – Processing is necessary for reasons of substantial public interest, on the basis of domestic law which dshall be proportunate to the aim pursued, respect the essnce of the right to data protection and provide the suitable and specific measures to safeguard the fundamental rights and interests of the data subject.
• Schedule 1, Part 2 of the Data Protection Act 2018 – Paragraph 6 – Statutory and Government purposes.

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

• Road Traffic Act 1998
• Health and Safety at Work Act 1974
• We aim to deliver road safety education with the goal of reducing the amount of people killed or seriously injured on our roads. Pass Plus in particular targets the most vulnerable age group (17-25) and is a Welsh Government funded project.
• We operate cycle training under guidance from Department for Transport 

Who or where we get the personal data from

We may receive the personal data from the following categories of individuals or organisations;

• Parents/Carers
• Participants in Courses
• DVLA
• Approved Driving Instructors
• Other Local Authorities 

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. 

Who	Purpose
Internal Council Departments.   Health & Safety Finance	If an accident occurs which requires investigation To administer payments
Approved Driving Instructors	To enable Pass Plus Cymru candidates to complete the practical element of the course
RoSPA/Road Safety Wales	Quarterly prize draw – to encourage participation in Pass Plus Cymru
DVLA	As a duty of care if concerns were raised about someones ability to drive
Welsh Goverment	For reporting and financial purposes.
Other Local Authorities	To administer training on behalf of the Local Authority

How long we retain the personal data 

We retain the personal data contained within the Road Safety Unit as follows: 

Length of time	Reason
Enquiries – Completion of the enquiry plus 1x year	To facilitate course bookings and to reply to enquirers when future course dates are arranged
Applications – Completion of course plus 1x year	To facilitate course bookings and evaluate the impact the course may have on future driver behaviour
Participant driving licence details and endorsements – Completion of course plus 1x year	To facilitate the course booking and maintain a record of any endorsements for licence validity and status.
Accidents / Incidents Date of accident plus 7x years if an investigation needs to be undertaken Date of accident plus 6 months for records that have no evidential value	Guided by the Health & Safety Act 1974
Approved Driving Instructors documentation – End of financial year plus 3x years	To evidence Approved Driving Instructor status.
Parents/Carers/Guardians School consent forms – date of providing plus 1x year	To facilitate school bookings
Mega Drive confirmation of attendance – date of course plus 3x years.	To facilitate course bookings and to reply to enquirers when future course dates are arranged

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 to the Council

You have the right to complain to the Council if you believe we have not handled your personal data responsibly and in line with good practice.

You can do this by contacting the Road safety team diirectly via one of the following communication methods. Most concerns can be resolved relatively quickly through a simple phone call or email;

• Email : roadsafety@rctcbc.gov.uk
• Telephone : 01443 494785
• In writing : Road Safety Unit, 2 Llys Cadwyn, Taff Street, Pontypridd, CF37 4TH 

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