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A229 Blue Bell Hill Traffic data collection privacy notice

We keep this privacy notice under regular review and it was last updated on 11 August 2024.

Kent County Council (KCC) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

Who we are

KCC collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the United Kingdom General Data Protection Regulation (‘UK GDPR’) and the Data Protection Act 2018. We are responsible as ‘controller’ of that personal information.

As part of developing proposals for infrastructure improvements to the A229 Blue Bell Hill (including M20 J6 and M2 J3), KCC is collecting traffic flow data at various locations across Kent, Medway, Thurrock and Essex. This traffic flow data will be used to create traffic models and scheme designs which aim to improve journey time reliability, reduce congestion along the route, improve road safety and improve air quality. Collecting traffic flow data from additional locations to the A229 Blue Bell Hill ensures we’re adequately representing longer distance and cross River Thames traffic movements. Traffic flow data will be captured using CCTV and ANPR cameras during a series of 2 week periods, 24 hours a day, at up to 60 x locations across Kent, Medway, Thurrock and Essex, between Sept 2024 and March 2026. We are responsible as ‘controller’ of that personal information.

Our Data Protection Officer is Benjamin Watts.

Personal information we collect and use

In order to evaluate motorised and non-motorised traffic flow information at these various locations, we collect the following personal information:

  • Video footage.
  • Vehicle registration number plates.

How we use your personal information

We use your personal information to:

  • understand the traffic flow of motorised transport (including vans, lorries, cars, motorbikes, scooters) in relation to the vehicle types and volumes, turning movements at junctions, queues, routing, journey times and speed
  • understand the traffic flow of non-motorised transport (including pedestrians, cyclists) in relation to the user volumes, direction, turning movements and use of crossing facilities
  • identify the motorised vehicle classification details (including vehicle type such as car, bus, weight, number of axles etc.)
  • create an anonymised, aggregated and non-personal spreadsheet output which combines motorised and non-motorised traffic flow data and vehicle classification details
  • create non-personal traffic models and scheme designs.

Reasons we can collect and use your personal information

We rely on Article 6(1)(e) of GDPR processing is ‘necessary for the performance of a public task in the public interest’ under Section 289 of the Highways Act 1980, as being the lawful basis on which we collect and use your personal data.

We take the following appropriate safeguards in respect of your special category when relying on the conditions above:

  • We have a Standard Operating Procedure for the traffic cameras in accordance with KCC’s CCTV Policy.
  • This policy is retained throughout the time we use your data and for 6 months after we cease to use it
  • We have a Retention Schedule which explains how long data is retained
  • We maintain a record of our processing in our ‘Record of Processing Activities’ and record in it any reasons for deviating from the periods in our Retention Schedule.

The provision of video footage and vehicle registration number plate information is required from you to enable us to improve the infrastructure on the A229 Blue Bell Hill (including M20 J6 and M2 J3).

If you do not provide video footage and vehicle number registration plate information, we may not be able to improve the infrastructure on the A229 Blue Bell Hill (including M20 J6 and M2 J3).

How long your personal data will be kept

We will hold your personal information for the following periods:

  • Raw video footage captured via CCTV will be kept for 3 months from the date of the final traffic model report is delivered, whereupon the original video footage will be manually deleted.
  • Vehicle registration number plate details captured via ANPR will be kept for 3 months from the date of the final traffic model report is delivered, whereupon this information will be manually deleted.
  • Traffic flow information, traffic models, and scheme designs (all which are anonymised, aggregated, and non-personal data) will be kept in perpetuity and used to develop future infrastructure improvements.

Who we share your personal information with

Video footage and vehicle registration number plate details are collected via CCTV and ANPR cameras by various third-party traffic data suppliers; who are all under a contract with Aecom (who are a third-party supplier working for KCC).

Third-party traffic data suppliers will share the vehicle number plate details with the DVLA (via an encrypted link) to determine the vehicle classification (i.e. vehicle type - such as car, bus, van, motorcycle etc).

Third-party traffic data suppliers will then create an anonymised, aggregated, non-personal traffic data spreadsheet output which combines motorised traffic flow data from the CCTV footage with the DVLA vehicle classification data, and non-motorised traffic flow data, also from the CCTV footage.

Third-party traffic data suppliers will share the summary spreadsheet output with Aecom, who will then create (non-personal) traffic models and scheme designs for Kent County Council.

Kent County Council will use the traffic data spreadsheet output, traffic models and scheme designs to develop infrastructure improvements on the A229 Blue Bell Hill (including M20 J6 and M2 J3).

Kent County Council will share the traffic data spreadsheet output and scheme designs with Essex County Council, Medway Unitary Authority, Thurrock Unitary Authority and National Highways to develop infrastructure improvements.

Kent County Council will share non-personal summary information regarding the A229 Blue Bell Hill Traffic data collection with the Department for Transport, as part of future funding applications.

Third-party traffic data suppliers have a data processing agreement in place with the DVLA who process your data on KCC’s and Aecom’s behalf.

We will share personal information with law enforcement or other authorities if required by applicable law or in connection with legal proceedings.

We will share personal information with our legal and professional advisers in the event of a dispute, complaint or claim. We rely on Article 9(2)(f) where the processing of special category data is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

We will not transfer your personal data outside of the UK.

Your rights

Under UK GDPR you have rights which you can exercise free of charge which allow you to:

  • know what we are doing with your information and why we are doing it
  • ask to see what information we hold about you (subject access request)
  • ask us to correct any mistakes in the information we hold about you
  • object to direct marketing
  • make a complaint to the Information Commissioner’s Office.

Depending on our reason for using your information you may also be entitled to:

  • object to how we are using your information
  • ask us to delete information we hold about you
  • have your information transferred electronically to yourself or to another organisation
  • object to decisions being made that significantly affect you
  • stop us using your information in certain ways.

We will always seek to comply with your request however we may be required to hold or use your information to comply with legal duties. Please note, your request may delay or prevent us delivering a service to you.

For further information about your rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the United Kingdom General Data Protection Regulation.

If you would like to exercise a right, please contact [the Information Resilience and Transparency Team at data.protection@kent.gov.uk.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Contact

Please contact the Information Resilience and Transparency Team at data.protection@kent.gov.uk to exercise any of your rights, or if you have a complaint about why your information has been collected, how it has been used or how long we have kept it for.

You can contact our Data Protection Officer, Benjamin Watts, at dpo@kent.gov.uk.

UK GDPR also gives you right to lodge a complaint with Information Commissioner, who may be contacted via the Information Commissioner's website or call 03031 231113.

Read our corporate privacy statement.