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Mobile library CCTV and dash cam 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

Libraries, Registration and Archives (LRA) is an internal service of Kent County Council which 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) which applies across 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 personal information we collect and use

Information collected by us

Whilst operating our mobile library and stock services vans, we may collect the following personal information:

  • video images of you
  • your vehicle details (for example, vehicle licence plate number and vehicle type)
  • audio recordings (for example, audio recordings of verbal conversations).

How we use your personal information

We use your personal information to:

  • 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 insurance claims, incidents and accidents
  • assist with the prevention and detection of theft, vandalism and to protect property.

Reasons we can collect and use your personal information

We rely on the following lawful basis in the UK GDPR to collect and use your personal information:

  • processing is necessary for the performance of a task carried out in the public interest - Article 6(1)(e)
  • processing is  “necessary for the purposes of our legitimate interests or those of us or a third party” - Article 6(1)(f).

And where the information or images we use includes special category (sensitive) information we will rely on:

  • processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity - Article 9(2)(f)” and
  • “processing is necessary for reasons of substantial public interest on the basis of UK law” - Article 9(2)(g). The substantial public interest conditions we rely on as set out in Schedule 1, Part 2 of the Data Protection Act 2018 are: our statutory purposes as conferred on us in law, preventing or detecting unlawful acts, safeguarding of children or individuals at risk.

Where we process criminal offence data we will only do so where we are authorised to do so by UK law in accordance with the conditions in Schedule 1, Part 3 of the Data Protection Act 2018: legal claims, extension of the substantial public interest conditions.

The UK GDPR lawful basis is underpinned by a broader legal basis which is set out in 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 163 of the Criminal Justice and Public Order Act 1994 (which provides local authorities with the power to take steps that they consider will promote the prevention of crime or the welfare of the victims of crime, including CCTV)
  • Section 111(1) of the Local Government Act 1972
  • Code 33 Protection of Freedoms Act 2012
  • Surveillance Camera Commissioner's Code of Practice.

How long your personal data will be kept

We will hold your personal information securely and retain it for two months or for as long as it is necessary to fulfil the purpose of an investigation or insurance claim.

Footage is automatically destroyed after 60 days or where it has been retained in relation to an investigation or insurance claim your personal information will be securely destroyed once this has been fulfilled and a record kept of when we have disposed of it.

Who we share your personal information with

Video and audio 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 activity and share intelligence to protect vulnerable people who may be missing. We may also share information with KCC’s insurance company and third party insurers following vehicle accidents where applicable.

We may also share it with our legal advisers where necessary.

Our systems are supplied and maintained by Pro Parts (Kent) Ltd. They may have to access the system on occasions where there is a fault.  We do not allow our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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 Commissioners 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 on individuals’ rights under UK GDPR.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidently lost or used or accessing 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 send all requests for access to CCTV footage to cctvdisclosures@kent.gov.uk.

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, or write to: Data Protection Officer, Sessions House, Maidstone, Kent ME14 1XQ.

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

Read our corporate privacy statement.