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1. OVERVIEW AND ABOUT US

1.1. Countrystyle Recycling Limited (Countrystyle) is a privately owned waste management company engaged in the provision of waste collection, processing, recycling, recovery and disposal services to its customers having regard to the Waste Hierarchy.

1.2. Countrystyle’s registered office is at Countrystyle Head Office, Ridham Dock Road, Iwade, Sittingbourne, Kent, ME9 8SR

1.3. Countrystyle is committed to safeguarding the privacy of our customers and website visitors. This Privacy Notice describes how we collect, use and share information that may contain Personal Data.

1.4. Our head of privacy can be contacted at: compliance@countrystylerecycling.co.uk

2. COUNTRYSTYLE’S CUSTOMERS

2.1. Under the EU General Data Protection Regulations (GDPR) Countrystyle is obliged to provide individual customers and individuals identifiable from data that we hold relating to our corporate or local authority customers, with certain information relating to Countrystyle and how we collect and use their ‘Personal Data’.

2.2.Why do we process your Personal Data?

2.2.1. We need to hold basic Personal Data so that we can provide our services to you in accordance with our terms of business entered into with you.

2.2.2. Without this Personal Data Countrystyle would be unable to provide its contracted services to you or your business.

2.2.3. We only collect and process Personal Data that we need in order to provide you with, and to manage, Countrystyle’s contracted services.

2.3. What type of Personal Data do we process?

2.3.1. Account Data: this includes details such as your name and email address;
2.3.2. Profile Data: this would include, in addition to your name, your address, telephone number, gender, date of birth and possibly, employment details/job title;
2.3.3. Transaction Data: this covers Personal Data provided in the course of using Countrystyle’s services and may include details of the transaction you have entered into with us and the payment methodology you used (including payment card details); and
2.3.4. Notification Data: this information you provide to us for the purposes of subscribing to Countrystyle’s email or newsletter notifications.

2.4. Where is your Personal Data processed and by whom?

2.4.1. Your Personal Data is only processed by Countrystyle staff located in the United Kingdom.

2.4.2. No one else has access to your Personal Data unless Countrystyle has a legal obligation to provide that third party with your Personal Data (eg: it is reasonably necessary to do so to obtain or maintain insurance coverage) or you give us your consent to do so.

2.4.3. It is likely that we will need to share your Personal Data with Countrystyle’s suppliers or contractors in order, for example, to distribute our newsletter or to maintain our database software.

2.5. What is the legal basis for Countrystyle processing your Personal Data?

2.5.1. Legal Obligation: Countrystyle processes some Personal Data in order to comply with a legal obligation for example under the requirements of the Waste Duty of Care obligations imposed by Section 34 of the Environmental Protection Act 1990; and/or

2.5.2. Contractual Obligation: Countrystyle also processes Personal Data where it is necessary in order to perform a contract with you for the delivery of Countrystyle’s services or in order to enter into such a contract with you; and/or

2.5.3. Legitimate Interest: Countrystyle also processes Personal Data where it is necessary in order to pursue a legitimate interest such as for the proper administration of our business, for example, by updating you on our activities and other services we can offer you; and/or

2.5.4. Insurance Risk: Countrystyle may process Personal Data where necessary for obtaining or maintaining insurance coverage, managing risk or obtaining professional advice, the legal basis for doing so is the proper protection of our business against risk.

2.5.5. Your Consent: if your Personal Data is used for anything other than the above reasons, Countrystyle will always obtain your consent to such use first.

2.6. How secure is your Personal Data?

2.6.1. Countrystyle takes all reasonable steps to ensure that your Personal Data is processed securely.

2.6.2. Countrystyle has implemented technology and security policies, rules and measures designed to protect your Personal Data under our control.

2.6.3. Other than online data, all your Personal Data is restricted to our offices and only Countrystyle employees have access to this data. There are exceptions to this as outlined in paragraph 2.4.3 and in these cases, the third party receiving your Personal Data for these limited circumstances is the subject of a non-disclosure agreement with Countrystyle or separate privacy policies.

2.7. How long do we keep your Personal Data?

2.7.1. Your Personal Data may be kept for 2 or 3 years to comply with Waste Duty of Care obligations (depending on whether the waste we manage for you is non-hazardous (2 years) or hazardous (3 years)).

2.7.2. If your Personal Data relates to the accounting or financial records of Countrystyle that may be available for inspection by HMRC, we are obliged to keep this data for a minimum of 6 years.

2.7.3. All Personal Data falling within the categories in paragraphs 2.7.1 and 2.7.2 above will be destroyed after these time periods if not longer required for any lawful purpose.

2.7.4. If you have provided your consent to the processing of your Personal Data for marketing purposes, this will be kept until such time as you notify us that you no longer wish to receive information from Countrystyle.

3. WEBSITE VISITORS

3.1. About Cookies.

3.1.1. By using Countrystyle’s website and agreeing to this Privacy Notice, you consent to our use of cookies in accordance with the terms of this Privacy Notice.

3.1.2. Countrystyle uses cookies for the following purposes:

3.1.2.1. Authentication: we use cookies to identify you when you visit our website and as you navigate our website;
3.1.2.2. Security: we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
3.1.2.3. Analysis: we use cookies to help us to analyse the use and performance of our website and services.

3.1.3. For administration and internal business purposes, Countrystyle may collect information about your computer, such as, your IP address and operating system. This information does not identify you personally and is statistical data only which identifies your browsing patterns.

3.1.4. You may prevent us from storing a cookie on your computer by setting your browser so that it will not accept cookies.

4. WHAT ARE YOUR RIGHTS?

4.1. Summary: Your principal rights under GDPR are as follows:

4.1.1. the right to access;
4.1.2. the right to rectification;
4.1.3. the right to erasure;
4.1.4. the right to restrict processing;
4.1.5. the right to object to processing;
4.1.6. the right to data portability;
4.1.7. the right to complain to a supervisory authority; and
4.1.8. the right to withdraw consent.

4.2. Access to your information: You have the right to request a copy of the Personal Data that we hold about you. If you like a copy of some or all of your Personal Data please contact our Head of Privacy on the email address in paragraph 1.4 above or write to the Head of Privacy at the registered office of Countrystyle set out in paragraph 1.2 above.

4.3. Request to correct or remove your Personal Data: Countrystyle wants to be sure that your Personal Data is accurate and up to date. You may ask us to correct or remove such information that you think is inaccurate at any time.

4.4. Proof of Identity: If you make a request to access, correct or remove your Personal Data under paragraphs 4.1 or 4.2 above, we will ask you to supply appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

4.5. Complaint: If you wish to raise a complaint about the way Countrystyle handles your Personal Data, again please write to our Head of Privacy at the email address or the registered office of the Company referred to above. If you are not satisfied with the way Countrystyle handles your complaint you can take your complaint to the Information Commissioners Office (ICO). You can contact the ICO via the link https://ico.org.uk/concerns/.

5. AMENDMENTS

5.1. Countrystyle may update this Privacy Notice from time to time by publishing a new version on its website. Please check this page occasionally to ensure you are happy with any changes to this Privacy Notice.

5.2. Countrystyle will notify users of any material changes to this Privacy Notice by identifying a link on its homepage of its website to the updated policy for a period of not less than 14 days.

Privacy Policy For Audio & Visual Body Worn Cameras operated at Reuse & Recycling Centres and Waste Transfer Stations  

1. INTRODUCTION

1.1. Countrystyle Recycling Limited (Countrystyle) is the contractor currently appointed by The London Borough of Bexley (Council) to manage the Reuse & Recycling Centres (RRCs) at Foots Cray, Sidcup and Thames Road, Crayford and the Waste Transfer Station (WTS), also at Thames Road, Crayford (the Sites).

1.2. Countrystyle places the highest priority on the health, safety, security and welfare of Site users, its staff and visitors to the Sites. Countrystyle will take all reasonably practicable steps to maintain safe and secure conditions at the Sites.

1.3. Body Worn Cameras (BWC) are used on the Sites to aid in the deterrence or detection of crime and other incidents with the primary aim of keeping Site users, our Staff and Visitors safe.

1.4. BWC can only be operated and used appropriately and within a stringent legal and regulatory framework.

2. WHAT IS THIS NOTICE FOR?

2.1. In order to comply with the General Data Protection Regulations (GDPR), we are required to provide Site users, our Staff and Visitors to the Sites with the information set out in this Privacy Notice.

3. WHO ARE WE AND WHAT ARE OUR CONTACT DETAILS?

3.1. Countrystyle is the contractor operating the Sites for the Council as outlined in paragrpah 1.1 above.

3.2. Countrystyle collects, uses and is responsible for accessing certain information about you and is both a Data Controller and a Data Processor.

3.3. Because we may share this information with the Council, we are a what is called a Joint Data Controller under GDPR, alongside the Council.

3.4. Our registered address is Ridham Dock, Ridham Dock Road, Iwade, Sittingbourne, Kent ME9 8SR.

4. WHO IS OUR DATA PROTECTION OFFICER?

4.1. Our Data Protection Officer is:
  • Stuart Butler-Gallie;
  • Compliance Director;
  • Ridham Dock, Ridham Dock Road, Iwade, Sittingbourne, Kent ME9 8SR.

5. WHAT PERSONAL INFORMATION DO WE COLLECT AND USE?

5.1. In order to enforce the Council’s policies concerning the use of the RRCs and WTS, to include identifying the use of aggressive or threatening behaviour by members of the public against our Staff, Council employees, other Site Users or Visitors to the Sites, we collect, via BWC, the following personal information:
5.1.1. Video images of you;
5.1.2. Photo images of you (e.g. which might relate to fly-tipping of waste at or near the Sites or some other breach of the rules of use of the RRCs or WTS);
5.2. We also collect your conversations via audio recordings of verbal conversations using BWC. This is ONLY the case if deemed necessary for the protection of Staff, other Site Users and/or Visitors to the Sites whilst making face-to-face enquiries with the public about their purpose at a Site.
5.3. If you are a Trade Waste user of the WTS we will also collect the following personal information from you:
5.3.1. Your name;
5.3.2. Your address.

6. HOW DO WE USE YOUR PERSONAL INFORMATION?

6.1. We use your personal information to:
6.1.1. assist with the prevention or detection of crime at the Sites;
6.1.2. increase the security and welfare of our Staff, other Site Users and Visitors when there are concerns about their safety;
6.1.3. assist in the prevention and reduction of public disorder and anti-social behaviour; and
6.1.4. provide data intelligence for third party insurance claims, incidents and accidents.
6.2. Examples of the use of BWC footage or audio recordings include:
6.2.1. use by the Police to investigate and prosecute:
6.2.1.1. theft from the Sites e.g. TVs, scrap metal, batteries;
6.2.1.2. vandalism; 
6.2.1.3. arson.
6.2.2. insurance and accident investigations involving incidents with the public; and
6.2.3. corroborating complaints by the public or Site Staff.

7. WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?

7.1. Countrystyle collects your personal information and shares this with the Council in order to:
7.1.1. enforce the Council’s policies for the use of the RRCs and WTS; and 
7.1.2. protect the health & safety of Site users, our Staff and Visitors to the Sites.
7.2. Under GDPR we rely on:
  • ‘processing being necessary for the performance of a task carried out in the public interest’; and
  • ‘processing being necessary for compliance with a legal obligation to which the controller is subject’.

8. WHO WILL WE SHARE YOUR PERSONAL INFORMATION WITH?

8.1. Countrystyle will share audio, video and photo information with:
8.1.1. the Council;
8.1.2. the Police;
8.1.3. Insurance Companies where an insurance claim arises in respect of incidents occuring at the Sites; 
8.1.4. other law enforcement or public authorities or where we are required to do so by applicable law;

9. YOUR RIGHT TO OBJECT TO USE OF YOUR PERSONAL INFORMATION

9.1. Under GDPR you have various rights which you can exercise free of charge. These include your right to:
9.1.1. know what we are doing with your information and why;
9.1.2. ask to see what information we hold about you. This is called a DATA SUBJECT REQUEST;
9.1.3. ask us to correct any mistakes in your information;
9.1.4. object to direct marketing; and
9.1.5. make a complaint to the Information Commissioner’s Office.
9.2. Countrystyle will always seek to comply with your request subject to our obligation to continue to hold or use the information to comply with legal duties.

10. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

10.1. BWC (audio and visual) images are stored securely as follows:
10.1.1. on the SD card of the camera of the BWC;
10.1.2. this is encrypted whilst images/audio are stored on the SD card;
10.1.3. images and audio can only be accessed on the camera screen by entry of a Pin number held by the Site Manager and not the BWC operator(s);
10.1.4. the images/audio stored on the camera’s SD card is downloaded via a secure docking station to a Countrystyle PC located in the weighbridge or main offices at the respective Site; 
10.1.5. once downloaded onto Countrystyle’s server, the images on the camera of the BWC are automatically deleted;
10.1.6. downloaded images/audio can only be accessed via the Evidence Management Software accessed on the Site PC via a Cloud-based web service protected by administrator user name and password held only by the Site Manager;
10.1.7. as images are encrypted, these cannot be viewed without the appropriate software and the software cannot be accessed without the appropriate user name and password;
10.1.8. the Council or the Police can ask Countrystyle for copies of images/audio taken/recorded on BWC. This can only take place by downloading these from the Site PC via the software to a memory stick and handed directly (via protocols, including being signed for) to an authorised Council officer or the Police;
10.1.9. downloaded images/audio are retained for such period as required to enforce any action that may be taken either by the Police or the Council. Otherwise, the maximum period that Countrystyle will retain images/audio for is 30 days from recording.

11. WHO SHOULD YOU CONTACT ABOUT YOUR PERSONAL INFORMATION COLLECTED AT A SITE?

11.1. You can contact our Data Protection Officer:
  • Stuart Butler-Gallie;
  • Compliance Director;
  • Ridham Dock, Ridham Dock Road, Iwade, Sittingbourne, Kent ME9 8SR.
by email to compliance@countrystylerecycling.co.uk or by writing to the above address.
11.2. GDPR also gives you the right to lodge a complaint with a supervisory authority. In the UK this is the Information Commissioner who can be contacted on 03031 231113.