Privacy notice

Waste management comprises of a number of teams covering mainly statutory regulation plus some other functions. These teams are comprised of refuse and recycling collections, street cleansing, fleet transport and environmental enforcement.

Refuse and recycling collections

Undertake the boroughs door to door wheeled bin collections. Black bin collections are undertaken by our in-house service and the recycling functions provided by our recycling partner Coventry City Council.

There is also an internal transfer station operation to support our municipal waste collections from fly tipping and housing void waste. These services sometimes requires the collection and collation of personal data. During the discharge of these functions some refuse collection vehicles carry smart camera capability which record 360-degree images for safety reasons. Signage is installed on the vehicles informing of peripheral recording.

Images captured are overwritten after a statutory 30-day period. Some images may be issued to Warwickshire Police for the detection of crime and would be retained. Please see retention period below. No images are accessed or viewed unless an incident affecting employee safety is compromised. Cameras are maintained and repaired in line with vehicle scheduling.

Street cleansing teams

Deliver our litter picking, litter bin emptying, street sweeping, fly-tipping waste removal and river clearance operations. A number of cleansing teams are deployed across the borough to collect litter dropped on pavements, roads etc and also undertake leaf fall clearances in Autumn.

A key part of the cleansing services is responding to the removal of fly tipped waste which blights a large number of areas in the borough. These services sometimes require the assistance of our environmental enforcement officers to collect and collate any personal data which could identify offenders and assist in their prosecution.

In order to respond to these requirements waste management have purchased and deployed static, overt, smart cameras in hot spot areas to deter and detect crime.

There are five overt cameras in total used in areas of concern. Signage is pre-installed at sites of interest to discharge our statutory obligations under the Regulation of Investigatory Powers Act 2000 (RIPA). Image management is overseen by our central CCTV team and all Images captured are overwritten after a statutory 30-day period.

Some images may be used as evidence and in support of a crime being detected. No images are accessed or viewed unless a environmental crime is suspected. Cameras are positioned to maximise coverage of a location and also to limit the risk of collateral intrusion. 

In order to underline our commitment to enforcement, we have now purchased covert cameras to use within the borough to support the prevention and detection of crime and assist to lower anti-social behaviour which impacts on local residents.

There is strict criteria regarding the deployment of covert cameras, when and where they can be used. All relevant applications requires authorisation via magistrate’s court. Covert camera’s will only be deployed in areas where all other resolution efforts have been exhausted and crime is still being experienced.

Environmental enforcement

As described above, has both an in-house provision for overseeing controlled waste offences in the borough and an external enforcement partner to undertake littering, graffiti and fly posting patrols and target offences observed.

These duties require the collection and collation of personal data. In the execution of these duties, our environmental enforcement teams utilise body worn cameras for the protection of both the officer and the person of interest following being spoken to.

Following an incident witnessed, at the start of any recording, the operating officer will, where possible, make a verbal announcement to indicate why the recording has been activated. This will include:

• date, time and location
• nature of the incident
• confirmation to those present that the incident is now being recorded (both video and visual)
• if the recording has started prior to arrival at the scene of an incident, the user will, as soon as possible, announce to those present that recording is taking place and that actions and audio are being recorded

Operating officers will use straightforward speech that can be easily understood by those present. Operating officers will also try attempt to minimise intrusion of privacy on third parties not involved in the incident, by keeping the camera focused on the event and not bystanders.

Unless circumstances dictate otherwise, recording will continue uninterrupted from the start of recording until the conclusion of the incident. Officers are instructed to continue to record for a short period after any incident to clearly demonstrate to any subsequent viewer that the incident has concluded and that the user has resumed other activities.

Prior to concluding recording, the operating officer make a verbal announcement to indicate the reason for ending the recording. This should state:

• date, time and location
• reason for concluding recording

Fleet transport services

Supports the council’s internal vehicle provision with, procurement, MOTs, inspections, service, maintenance, and repairs. Transport operations helps to ensure Nuneaton and Bedworth borough council conforms to its obligations as a compliant and reputable fleet operator.

Gresham Road Depot

Operations are located on Bermuda Industrial Estate. The site is serviced by ten external cameras and one internal reception camera for security and safety reasons. The camera images are monitored by our internal CCTV team, with the potential for any incidents to be reported to the police immediately detected.

Relevant signage is deployed to notify users of the site that recording is taking place and details of where further information can be sought.

Scope

This privacy notice relates to:

• suppliers and contractors of Nuneaton and Bedworth Borough Council who have roles in delivering the council’s waste management and environmental enforcement services
• people with whom we have contact in the course of delivering the Council’s Waste Management and Environmental enforcement services
• information obtained or provided by post, smart and body worn camera deployment, email, telephone, face-to-face, text, social media, and online

The data controller

The data controller is:

We will store the data in our secure computer and manual record systems and restrict access according to relevant policies and procedures.

Personal data

In delivering the council’s waste management and environmental enforcement services. We collect and use personal data for the purposes of logging, investigating, and updating relevant parties about the provision of such a service. This includes the collection and use of data such as:

• your title and name
• your address and contact details
• details of how the issue affects you
• any vulnerabilities you may have
• notes about any relevant circumstances that you have told us about
• other occupants in your home
• private vehicle registration details

We will use this data for the following purposes:

• to deliver a waste management and environmental enforcement regulatory service
• where necessary, to detect or prevent crime
• we will only use your information in ways which are permitted by the General Data Protection Regulation and the current UK Data Protection law

Legal basis

The processing is necessary so that the Council can fulfil its obligations to deliver an Environmental Health service.

Where the processing is necessary to manage your role within the terms of a contract you hold with the Council, data protection law describes this legal basis as necessary for the performance of a contract.

Where the processing is necessary to fulfil the Council’s legal obligations, data protection law describes this legal basis as a legal obligation.

Where the processing is necessary to enable the Council to exercise its legal powers, data protection law describes this legal basis as necessary for performance of a public task, or in the public interest.

Where the processing is necessary to detect or prevent crime, data protection law describes this legal basis as necessary for performance of a public task, or in the public interest.

Where the processing is necessary to save life or to protect health, data protection law describes this legal basis as protecting vital interests.

If you do not provide the information we ask for we may not be able to provide the service that you need.

In certain circumstances we may need to process Special Categories of personal information or criminal conviction data.  Where this is necessary, data protection law describes this exemption as being of substantial public interest.

Consent

We do not need your consent to collect or process your personal information. This is because we need the information for us to administer your contract with the Council or to fulfil our legal or contractual obligations, or in the public interest or the Council’s legitimate interests. If circumstances arise that do not fall within these criteria, we will seek your consent before collecting or processing your personal data.

Disclosure

Nuneaton and Bedworth Borough Council may pass on your personal data to third parties for the purposes of detecting or preventing fraud or other crime, or for taking enforcement action, or if it is necessary to provide the service.

These organisations may include, but are not limited to, Warwickshire Police, Food Standards Agency, Health and Safety Executive, Environment Agency, neighbouring Local Authorities, Warwickshire Fire and Rescue, the Coroner’s office, HMRC, Immigration Service, Public Health England, Home Office, Gangmasters and Labour Abuse Authority, Driver and Vehicle Licensing Authority.

We do not share your information with the subject of any complaint made by you without your expressed permission and only when it is crucial to the case. If you agree to provide a statement or attend court it is likely that your information and/or identity will be made available to the subject of the complaint. This will be discussed with you before we disclose the information to someone else.

Retention period

Nuneaton and Bedworth Borough Council will process or retain your personal data for as long as may be required by relevant legislation or approved guidance covering retention periods. In most cases this will be a minimum of six years.

Your rights as a data subject

You have the right:

• to request a copy of the information that we hold about you
• to correct data that we hold about you that is inaccurate or incomplete
• in certain circumstances you can ask for the data we hold about you to be erased from our records
• where certain conditions apply, to restrict the processing
• in some circumstances, to have the data we hold about you transferred to another organisation
• to object to certain types of processing such as direct marketing
• to complain if we refuse a request, you may make using these rights and you are not happy with our reason

We may refer any request you may make using these rights to another organisation if they have been involved in processing your personal data.