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Infrastructure Property Maintenance and Enforcement Surveillance Equipment privacy notice

This notice explains what personal data (information) we hold about you, how we collect, how we use and may share information about you. We are required to give you this information under data protection law.

Who we are

Kent County Council (KCC) collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws. Our Data Protection Officer is Benjamin Watts.

The Infrastructure division within Kent County Council manages the council’s property portfolio, and commissions Facilities Management of its property estate provided by Skanska or other service providers for sites not in the FM Contract (Deadline Solutions Ltd). The service providers act as data processors of that personal information on behalf of KCC where KCC is not the data processor.

The personal information we collect and use

Information collected by us

Whilst enforcing our policies and for crime prevention and public safety we may collect the following personal information:

  • video images of you
  • photo images of you (for example, photographs of any movement at a location)
  • your vehicle details (for example, vehicle licence plate number, including ANPR (if ANPR is in use this will be identified on the notices at site) and vehicle type)
  • your conversations (for example, audio recordings of verbal conversations)

How we use your personal information

We use your personal information to:

  • assist with the prevention and detection of crime and protect property
  • increase the security and welfare of employees when there are concerns around their safety
  • improve public safety
  • assist in the prevention and reduction of public disorder and anti-social behaviour
  • provide data intelligence for third party insurance claims, incidents and accidents

CCTV footage is used by the police when investigating and prosecuting theft (for example, fixtures and fittings), vandalism (for example, damage to property such as fences from breaking and entering premises) and arson and fire prevention, both during operational hours and when shut. CCTV is also used for insurance and accident investigations involving incidents with the public and/or corroborating complaints by the public.

How long your personal data will be kept

We will hold your personal information securely and retain it for 30 days (unless this cannot be supported by an individual system where the local notice will show the different retention) or for longer where footage has been captured to comply with statutory obligations we may be subject to, in accordance with our Retention Schedule.

We then securely destroy your personal information after this date and when manually deleted will keep a record of when we have disposed of it.

Reasons we can collect and use your personal information

The provision of personal information is required from you to enable us to enforce our policies and for crime prevention and public safety.

We rely on, processing is ‘necessary for the performance of a public task in the public interest’; ‘is necessary in order to protect the vital interests of the data subject or another natural person’, as well as ‘to comply with a legal obligation to which (Kent County Council) is subject’ being the lawful basis on which we collect and use your personal information.

For special category and criminal offence data we rely on ‘processing is necessary for legal claims or whenever courts are acting in their judicial capacity’ and substantial public interest (statutory purposes and prevention and detection of crime).

The lawful basis is underpinned by acts of legislation and Codes of Practice that dictate what actions can and should be taken by local authorities, including but not limited to:

  • Section 68 of the Serious Crime Act 2007.
  • Section 33 of the Protection of Freedoms Act 2012.
  • Surveillance Camera Code of Practice Pursuant to Section 31(3) of the Protection of Freedoms Act 2012.
  • Section 163 of the Criminal Justice and Public Order Act 1994.
  • the Crime and Disorder Act 1998.

Who we share your personal information with

Audio, video and photo information may be shared with Kent Police but only when there is a lawful reason for them to view it such as where it is necessary to investigate illegal activity such as vandalism or obtaining evidence in relation to a public order offence.

Further, we will share personal information with law enforcement or other authorities if permitted or required to do so by applicable law.

Your rights

Under 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:

  • 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
  • object to how we are using your information
  • 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 GDPR.

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.

Viewing and analysis of the CCTV images will only be undertaken by authorised employees. All monitoring of camera recordings is logged and kept in a secure location.

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.

Who to 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.

With regards to the disclosure of CCTV please contact cctvdisclosures@kent.gov.uk.

You can contact our Data Protection Officer, Benjamin Watts, at dpo@kent.gov.uk, or write to: Data Protection Officer, Sessions House, Maidstone, Kent ME14 1XQ.

GDPR also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissionerwho may be contacted on 03031 231113.

Read our corporate privacy statement.