Privacy policy for audio and visual body worn cameras operated at reuse and recycling centres and waste transfer stations.

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.

2.1. 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.

3.1. 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.

4.1. Our Data Protection Officer is:

• Anita Harris;
• Head of Human Resources;
• Ridham Dock, Ridham Dock Road, Iwade, Sittingbourne, Kent ME9 8SR.

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.

6.1. 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.

7.1. 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’.

8.1. 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;

9.1. 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.

10.1. 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.

11.1. You can contact our Data Protection Officer:

• Anita Harris;
• Head of HR;
• 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.