Dudley Council
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Waste Collection Vehicle CCTV System and In-Cab Project Privacy Notice

Who we are and what we do

Dudley Council provides an in-house Waste Collection service, incorporating household refuse, green and recycling collections, as well as a service to local businesses.  Under the Health and Safety at Work Act 1974, employers have a duty to protect the health, safety and welfare of their employees and other people who might be affected by their business.  Employers must do whatever is reasonably practicable to achieve this.  This means making sure that workers and others are protected from anything that may cause harm, effectively controlling any risks to injury or health that could arise in the workplace.


What type of personal information do we collect?

CCTV images of traffic and other road users, property (limited), pedestrians and the Waste Collection workforce during the duration of each journey.

The in-cab device will hold street names and property numbers for all properties receiving a domestic and commercial waste collection in the Borough. The collection crews will only view the street names and property numbers for properties that have reported missed bins, requested delivery/collection of waste/recycling containers and those properties that are entitled to assisted collections. The reasons for the assisted collection will not be displayed or available to view. Collection crews will also be able to view daily Bulky waste and white goods collections. Photographs of problem collections may be taken. 

How do we collect this information?

Images are recorded by four CCTV cameras that are fitted to each collection vehicle.  The cameras are positioned to give the greatest coverage around the vehicle as possible, they are positioned one at the front, one at the rear and one on each of the wing mirrors. 

The information for in-cab is collected via Dudley Council Plus and then sent to the in-cab devices by the Waste Care Team. The photographs are taken by the collection crews using the webfleet in cab device and are sent via 3/4G to the Whitespace desktop software within Waste care.

What is our lawful basis to obtain and use your personal information?

The lawful basis for collecting this information is that:

  • processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
  • processing is necessary for the compliance with a legal obligation to which the controller is subject
  • For in-cab the Environmental Protection Act 1990

We collect this information to:

  • protect the health and safety of the collection crews and members of the public
  • identify dangerous activities that pose a risk to health and safety being undertaken by the crew or members of the public
  • provide assistance in accident investigation (including near misses)
  • support the assessment of problems with access to properties or past instances of missed collections
  • support the investigation into insurance claims from third parties
  • accurately respond to complaints and instances of missed collections
  • streamline the complaints procedure
  • evidence collection issues

How do we keep this information secure?

The security of your personal information is important to us. The images captured are secured in transit and any images retained for incident management are held securely and only accessible by authorised officers.

In-cab information will only be accessible to authorised officers.

How long do we keep this information?

Footage is recorded on the hard drive in the vehicle and is automatically overwritten after 60 days.

Downloaded images are only retained if an incident occurs and will only be held for the duration of any incident/investigation.

For in-cab we keep the information in accordance with the Council’s retention policy which details how long we keep different records.
The schedule is available on request to the Information Governance Team - information.governance@dudley.gov.uk


Who are we likely to share this information with?

In the event of an incident/claim, we may share the downloaded images with other Council departments, the police, Health & Safety Executive and relevant insurance companies.

For in-cab with other Council departments if required.

What are your information rights?

Your Information Rights are set out in the law. Subject to some legal exceptions, you have the right to:

  • Have any inaccuracies corrected; 
  • Have your personal data erased; 
  • Place a restriction on our processing of your data; 
  • Object to processing; and 
  • To request your data to be ported (data portability)

You also have the right to request a copy of the personal information the council holds about you.

If you wish to exercise your information rights, please contact our Data Protection Officer at information.governance@dudley.gov.uk  or alternatively write to:
Corporate Information Governance Team
Dudley MBC
Priory Road