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Your data

We have created this policy which covers how we:

  • collect
  • use
  • share
  • transfer
  • look after

... your data. The policy also gives you information on how to contact us, and lets you know your rights as a data subject.

 


 

Why we collect data

We provide local waste management services for Staffordshire and the people who live and work here. We collect data to support the delivery of the service and the safe, legal and appropriate use of these services.

We collect data for the following reasons with respect to our household waste and recycling centre (HWRC) services:

  • to detect and deter crime
  • to encourage a safe environment for service users and staff alike
  • to inform service investigations
  • to monitor service demand
  • to identify inappropriate use of services
  • to respond to your correspondence
  • to process payments
  • to ensure that all applicable commercial and industrial wastes are paid for and are transferred in a legally compliant manner (see additional details below)

The classification of household waste is outlined in the Environmental Protection Act 1990 and further defined in the Controlled Waste Regulations 2012. Paragraph 2 in schedule 1 of the Controlled Waste Regulations identifies what is to be treated as household waste, industrial waste or commercial waste and where charges can be applied for disposal. Charges are made at Staffordshire's HWRCs for households the disposing or recycling of non-household waste and for trade waste.

The Environmental Protection Act 1990, section 34(1) outlines duty of care requirements to ensure the safe management of waste to protect human health and the environment. The code applies to anyone who imports, produces, carries, keeps, treats or disposes of waste (occupiers of domestic property disposing of household waste from that property are exempted from the section 34(1) duty of care). To present waste for disposal the trader must demonstrate that they have complied with their duty of care by providing evidence of a waste carriers licence registration number. To transfer waste there must also be a written description of the waste, which must be agreed and signed for by the trader and the waste broker (i.e. HWRC site operative).

Legal basis

Article 6 (e) of the 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."

 


 

Our responsibilities

We are responsible for managing the information we hold and we recognise that this information is important to you. We take our responsibilities seriously and use personal information fairly, correctly and safely in line with the legal requirements set out by the General Data Protection Regulations (GDPR). Anyone who receives information from us is also under a legal duty to do the same and has a set of data protection clauses included in their contract.

Because we collect and process personal information about individuals, we are a 'data controller' as defined in the General Data Protection Regulations (GDPR). This means that we must make sure you know what we intend to do with your information and who it could be shared with.

Our HWRC sites are managed on our behalf by Amey PLC.  In order to manage and deliver this service effectively, personal data is processed only in accordance with the terms and clauses of the contract in place between Staffordshire County Council and Amey PLC.

Contact details

As data controller our contact details are:

Data Protection Officer
Information Governance Unit
Staffordshire County Council
1 Staffordshire Place
Stafford
ST16 2DH

As data processor, Amey PLC's contact details are:

Amey UK PLC
Chancery Exchange
10 Furnival Street
London
EC4A 1AB

 


 

How we collect data

Your data may be collected or recorded in various ways, including:

  • on paper
  • via telephone
  • via email
  • face to face
  • via service user trade waste or household waste declaration form
  • via CCTV
  • via automatic number plate recognition (ANPR) cameras
  • via customer payment details (chargeable non-household waste and trade waste)

Data may be collected directly from you or data about you may be gathered from other sources, and we may need to ask other agencies or organisations for relevant data about you to fulfil our legal responsibilities or to provide services.

 


 

How we use your personal data

We will use your personal information for a limited number of purposes and always in line with our responsibilities, where there is a legal basis to do so, and in line with your rights under the GDPR. When we collect personal data from you, we will only use it as defined within this privacy notice. We will not collect any personal data from you that we do not need.

We will use the information gathered in order to:

  • deliver our services
  • contact you where necessary
  • ensure that we fulfil our legal obligations
  • to encourage a safe environment for service users and staff alike

If we wish to use or share your data for any purpose other than that for which it was originally collected, we will provide information on these purposes prior to starting the work. We will strive to make sure that the third party has sufficiently robust systems and procedures in place to protect your personal information.

Sometimes we may not be able to provide a service if you do not provide data.

 


 

How we share your data

Where necessary information may be shared with other organisations and partners that provide services on our behalf. In such cases, the information provided is only the minimum necessary to enable them to provide services to you. These organisations are required to retain your information in a secure manner and only use it to undertake the services they provide to you.

We are also required by law to protect the public funds it administers and may share information provided to it with other bodies responsible for auditing or administering public funds in order to prevent and detect fraud. More information is available from the National Fraud Initiative web site.

If the information we intend to share is of a sensitive, personal nature we will only share it with partner organisations if we have obtained your consent or unless we are legally required to share it. We have an information sharing protocol with local partners under which our partners agree to similar commitments toward privacy, security and transparency.

Personal information about you may also be provided to other local authorities. For example, if you have moved from one local authority to another and the new authority requires confirmation of the services you were receiving.

At no time will your information be passed to organisations external to us or our partners for marketing or sales purposes or for any commercial use without your prior express consent.

 


 

How we look after your data

Under the general data protection regulations we have a legal duty to protect any information that we hold about you. We take measures to safeguard your data and apply security standards and controls to prevent any unauthorised access to it.

Information which you have provided will be stored securely in accordance with the terms and clauses of the contract in place between Staffordshire County Council and Amey PLC. It will only be used for the purpose(s) stated when the information was collected.

The amount of time data is kept before being disposed of will vary depending on why it was collected, how it is used, and various UK laws in line with our retention and disposal schedules.

Extract from contract schedules

"(1) at the Employer's option, permanently and securely delete or return to the Employer all the Personal Data promptly on termination of this Agreement, and delete any existing copies of the Personal Data save to the extent that the Contractor is required to retain copies of the Personal Data by the laws of the United Kingdom, European Union law or individual European Union member state law to which the Contractor is subject"

 


 

Use of personal information for marketing

We will only send you information about our services and/or products if you have asked us to do so or, based on the information we hold, those services are considered of benefit to you. You can opt out of this at any time by letting us know using the contact details below. Your information may also be shared with other service providers who may contact you if they provide services to help you.

 


 

Use of CCTV

CCTV systems are installed at our HWRCs for the purposes of public safety and the prevention and detection of crime. Signs are prominently displayed notifying you that CCTV is in operation and providing you with details of who to contact for further information about them.

We will only disclose CCTV images to third parties for the purposes as stated above of public safety and the prevention and detection of crime. CCTV images will not be released to the media for entertainment purposes or placed on the internet.

You have the right to see CCTV images of yourself and be provided with a copy. See details of how to make a request in the what are your rights section below.

 


Use of automatic number plate recognition (ANPR)

ANPR systems are installed at our HWRCs, except Wombourne, for the purpose of recording vehicle registrations as they enter the HWRC sites.

Signs are prominently displayed notifying you that ANPR is in operation and providing you with details of who to contact for further information about them.

We will only disclose ANPR images to third parties for the purpose as stated above.  ANPR images will not be released to the media for entertainment purposes or placed on the internet.

You have the right to see ANPR images and be provided with a copy.  See details of how to make a request in the what are your rights section below.

 


 

What are your rights?

Under the GDPR you, as the data subject, you have the right to:

  • access the information we hold about you. This information is usually provided free of charge but we may charge depending on the administrative costs of providing the information. You have the right to request this in machine-readable form so that it can, if required, be transferred to a third party
  • request that we rectify any information about you that is incorrect. Simple inaccuracies, such as address changes will be made. Depending on the purpose for processing, records (including statements and opinions) may not be changed. However, there may be the option for you to provide a supplementary statement which will be added to the file
  • request that records we hold about you are erased
  • restrict processing of the information we hold about you if you have an objection to that processing, whilst your objection is investigated
  • request that any information that you have provided to us is given back to you in a format that you can give to another service provider if required
  • object to processing of your personal information including automated decision making and profiling
  • make a complaint to a supervisory authority if you are not satisfied with how the information held about you has been handled

 


 

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you, or if you have a complaint about privacy or misuse of data.

Email: DPO@staffordshire.gov.uk

Post to:

Data Protection Officer
Information Governance Unit
Staffordshire County Council
1 Staffordshire Place
Stafford
ST16 2DP

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO).

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