Privacy Statement
Privacy Notice – Environmental Services
This privacy notice covers how Pembrokeshire County Council (as a Data Controller) will collect, use and share your personal data for the purposes of fulfilling the duties of the Environmental Services Waste and Recycling department.
Why we need your information (purpose of processing)
We collect and use your personal information so that we can:
- Deliver services and support to you these include, Garden Waste subscriptions, Trade Waste Agreements, Waste & Recycling Assisted Collections, Container/Bag requests, Real Nappy Cash Back Scheme, Nappy & Incontinence Waste Collections (AHP), Larger Household Collections, Waste & Recycling Centre Bookings and Bulky Waste collections.
- Investigate issues that you have told us about
- Tackle issues like anti-social behaviour, fly-tipping, abandoned vehicles, and fly-grazing
- Help investigate any worries or complaints you have about your services
- Check the quality of services
- Help with research and planning of new services
- To ensure compliance with statutory requirements
CCTV and body-worn cameras are in use at our Waste and Recycling Centres (WRCs) which include: Manorowen, St Davids, Winsel, Waterloo, Crane Cross and Hermon. CCTV is in place at the Waste Transfer Station near Milford Haven. Our Waste and Recycling vehicles are also fitted with CCTV. The purposes for this are as follows:
- For the prevention, reduction, detection and investigation of crime and other incidents
- To ensure the safety of our staff, contractors and members of the public
- To assist in the investigation into suspected breaches of recycling and waste policies and procedures by our staff, contractors and members of the public.
Pembrokeshire County Council Environmental Enforcement officers and Waste Advisors wear and use body-worn cameras. This is for the collection of evidence to aid prosecutions and to improve officer safety.
The information that you provide will be processed according to the UK General Data Protection Regulation, the Data Protection Act 2018, the Environmental Protection Act 1990, and The Controlled Waste (England and Wales) Regulations 2012, the Equality Act 2010 and the Refuse Disposal (Amenity) Act 1978.
We will also make any disclosures required by law and we may also share this information with other bodies responsible for detecting/preventing fraud/crime or auditing/administering public funds to ensure money is targeted and spent in the most appropriate and cost-effective way. In order to achieve this, information will be shared with our Audit Service within Pembrokeshire County Council and with The Auditor General for Wales Audit Wales Privacy and Cookie Policy (opens in a new tab).
We will not make any disclosures to third parties for marketing purposes.
Your data will be secure and confidential at all times, and we will only collect the personal information that is required to provide you with our service.
What personal data is being collected?
The categories of personal data being collected are:
- Name
- Address
- Contact Details including email and contact number
- Payment information
- Health data (this is required in relation to our Waste and Recycling Assisted Collections)
- Number of persons in a household (information is collected in relation to Waste & Recycling collections from larger households)
- Date of birth or due date of birth of your child, their gender and your financial details (this is collected in relation to the Real Nappy Cash Back Scheme)
- Vehicle registration (this is collected in relation to processing of our waste and recycling centre booking system, investigating fly tipping, fly-grazing, abandoned vehicles and road traffic accidents)
- Make, model and colour of vehicle along with location/photo of vehicle (in relation to abandoned vehicles)
- Images/video/audio (this is collected via our CCTV and body worn cameras)
What is our lawful basis for processing your personal data?
The UK General Data Protection Regulations (UK GDPR) requires specific conditions to be met to ensure that the processing of your personal data is lawful. These relevant conditions are below:
- Article 6 (1)(e) Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
- Article 6 (1)(f) Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
Some types of personal data are more sensitive than others and need more protection. This is classed as ‘special category data’ and could include information about your racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership and the processing of genetic or biometric data, health and sex life and sexual orientation.
We process this type of special category data as it is necessary for reasons of:
- Article 9 (2)(g) Substantial public interest.
(The relevant Data Protection Act 2018 condition is – Schedule 1 Part 2: Statutory and government purposes)
Who will we share your information with?
We may need to share your personal data with internal departments, other organisations and third parties, this will include:
- Natural Resources Wales (NRW)
- Police
- FRAME, Intelligent Security Systems (ISS), Dyfed Alarms, Routeware Ltd who are our data processors.
We use data processors (third parties) who provide services to us in terms of IT provision and disaster recovery. We have contracts in place with these data processors and they cannot do anything with your personal information unless we have instructed them to do it. They will hold your data securely and your personal information will only be shared in accordance with UK GDPR. When it is necessary for your personal information to be transferred outside of the UK as part of these contracts, this will only be done in accordance with the UK GDPR.
Pembrokeshire County Council has a duty to protect the public funds it manages. Therefore, the information that you have provided to us may be used for the prevention and detection of fraud and for auditing purposes both internally and externally.
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by visiting CIFAS (opens in a new tab).
How long do we keep hold of your information?
Pembrokeshire County Council will only keep your information for as long as is necessary, we will retain the information provided to us for:
Missed Collections and Service Requests – 3 years
Garden Waste – Two years after termination of the service
Trade Waste – 3 years
Waste & Recycling Assisted Collections - For as long as customer is eligible for the service.
Container/Bag Requests – Destroyed once delivered
Real Nappy Cash Back Scheme - 3 years from last contact
AHP Nappy Collection Service - As long as service required or after 3 missed collections.
Larger Household Collections - As long as service required or after 3 missed collections
Fly Tipping – 7 years after last action including prosecution
Abandoned vehicles – 6 years
Fly-grazing - 6 years
Waste & Recycling Centres booking system - 5 years after account closed or inactive
Bulky Waste collections – 3 years
CCTV on Waste & Recycling Vehicles: Garden waste lorries, AHP, grey bags and hook lifts - if no incident gets overwritten every 2.5 weeks. When an incident happens data will need to be kept longer and decided on case-by-case basis.
CCTV on Waste & Recycling Vehicles: Kerb side collection lorries - if no incidents info gets overwritten every 10 days. When an incident happens data will need to be kept longer and decided on case-by-case basis.
CCTV at Waste & Recycling Centres – 31 days, where incidents reported may be kept longer.
Your information will be securely disposed of once it is no longer required.
Your Rights
Under the UK General Data Protection Regulation and Data Protection Act 2018, you have rights as an individual including:
- The right to Rectification – you have the right to ask to have your information corrected.
- The right to Restrict processing may apply – you may request that we stop processing your personal data however, this may delay or prevent us delivering a service to you. We will seek to comply with your request but may be required to hold or process information to comply with our legal duties.
- The right to Object – this is not an absolute right and will depend on the reason for processing your personal information.
- The right to Erasure - you may request that we erase your personal data however, this may delay or prevent us delivering a service, or continuing to deliver a service. We will seek to comply with your request but may be required to hold or process information to comply with our legal duties.
- The right to not be subject to Automated decision making and profiling.
- The right of Access – you have the right to ask us for copies of your personal data. To make a request, please contact:
Access to Records
Pembrokeshire County Council
County Hall
Haverfordwest
SA61 1TP
Email: accesstorecords@pembrokeshire.gov.uk Telephone: 01437 764551
Complaints or Queries
Pembrokeshire County Council endeavours to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this seriously. We encourage people to bring to our attention if they believe that our collection or use of information is unfair, misleading or inappropriate.
This privacy notice does not provide exhaustive detail of all aspects of our collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below:
Data Protection Officer
Pembrokeshire County Council
County Hall
Haverfordwest
SA61 1TP
Email: dataprotection@pembrokeshire.gov.uk
Telephone: 01437 764551
If you want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office as the statutory body which oversees data protection law:
Information Commissioner’s Office – Wales
2nd Floor, Churchill House
Churchill Way
Cardiff
CF10 2HH
Email: wales@ico.org.uk
Telephone number: 0330 414 6421
Our Contact Details as Data Controller are:
Pembrokeshire County Council, County Hall, Haverfordwest, Pembrokeshire, SA61 1TP
Email: enquiries@pembrokeshire.gov.uk
Telephone number: 01437 764551
Our Data Protection Officer’s information is detailed above in the Complaints and Queries section.
Changes to this privacy notice
We keep our privacy notice under regular review.