Privacy Statement

Pembrokeshire County Council logo

Privacy Notice - Closed Circuit Television (and audio recording) (CCTV) on School Transport

This privacy notice covers how Pembrokeshire County Council (as a Data Controller) will collect, use and share your personal data where closed circuit television and audio recording is used on school transport services. There are signs clearly displayed on all buses which have CCTV and audio recording equipment fitted.

Why we need your information (purpose of processing)

The council works with transport providers and schools to ensure that these are operated lawfully and in a way that enables us to reduce anti-social behaviour, criminal activity and the threat of crime on some school transport.

This involves collecting and using your personal information via CCTV and audio recording, so that we can:

  • Reassure parents that the safety of the pupils is paramount
  • Create an environment in which the students will feel is safer and in which they will want to travel to and from school
  • Protect the health & safety of employees, customers and members of the public
  • Comply with child protection obligations, allegations or complaints
  • Manage safe behaviour on school transport, safeguarding passengers and drivers
  • Manage and investigate allegations, complaints, offences and incidents
  • Prevent, deter and detect fraud and crime, antisocial behaviour, criminal damage, public disorder, unlawful behaviour and inappropriate conduct
  • Support the police in the reduction of anti-social behaviour and vandalism and assist in the preservation of public order
  • Assist with the identification of offenders and aid the school and transport provider in identifying the students, in conjunction with the police and schools
  • Facilitate the apprehension and prosecution of offenders
  • Assist the police with providing evidence, where criminal and civil prosecutions arise
  • Support the bringing of offenders to justice and to increase community safety
  • Provide public services and to monitor and improve the Council’s performance
  • Meet our legal obligations
  • Support the establishment, exercise or defence of legal and insurance claims

The information that you provide will be processed according to the UK General Data Protection Regulation and the Data Protection Act 2018. Any system will be operated in accordance with the 12 guiding principles set out in the Surveillance Camera Code of Practice 2013, and under the Protection of Freedoms Act 2012, and will be carried out in line with the Information Commissioner’s Office CCTV Code of Practice.

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:

Videos with audio and images.

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)(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.

Who will we share your information with?

CCTV footage will only be viewed and shared when necessary (for example, in response to an incident or to detect or prevent crime).

We may need to share your personal data with internal departments, other organisations and third parties, this will include:

  • The Council’s transport and education departments, relevant schools and/or social work teams, transport operators and, if necessary, the police.

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 31 days after footage/images have been recorded, unless it has been requested, for example in relation to an ongoing investigation. 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 No: 0330 414 6421

Our Contact Details as Data Controller are:

Pembrokeshire County Council, County Hall, Haverfordwest, Pembrokeshire, SA61 1TP.

Telephone number: 01437 764551 or enquiries@pembrokeshire.gov.uk

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.

ID: 11695, revised 16/09/2024