Household Waste Recycling Centre booking form 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
We are Kent County Council (KCC). 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 (GDPR) 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 waste management service
The waste management service is carried out by KCC and helps people to manage their waste and encourages the use of waste as a resource in synergy with economic and housing growth in Kent plus ensures a robust, commercial approach to commissioning, performance and delivery throughout the service.
We currently manage 18 Household Waste Recycling Centres (HWRCs) and 6 transfer stations and closed landfill sites across Kent. The sites are operated by contracting parties under the remit of Kent County Council.
A website-based booking system to enable customers living in Kent, to use the HWRCs has been developed to control demand upon re-opening during the COVID-19 pandemic.
To determine how our customers feel about using the website-based booking system along with the service they received when they visited a HWRC, we are carrying out a short customer satisfaction survey for those residents who agree to tell us their views.
Personal information we collect and use
Information collected on our behalf
When you book a visit to a HWRC or complete an optional customer satisfaction survey regarding your experience of using the online booking form and your visit to a HWRC, we collect the following personal information when you provide it to us:
- your contact details - for example your name, email address, telephone number and postcode
- your vehicle details - for example your vehicle registration plate number, make and type of vehicle etc
- feedback regarding your experience of using the online booking form and your visit to a HWRC, if you chose to complete the customer satisfaction survey.
We may also collect personal data if you chose to provide it to us when completing the customer satisfaction survey:
- your identity (age band for example, 25 to 44, and gender), only if you decide to provide us with this information and only if you opt-in to complete the customer satisfaction survey.
We may also collect the following information should you provide it to us:
- a request for assistance at an HWRC with unloading your vehicle.
How we use your information
Once you have submitted your visit request and information, the BookingBug system creates a daily report for each HWRC noting Booking reference number, vehicle details and date/time of visit. These reports are supplied to our contractors so they know to expect you.
Our Waste Management contractors operate on behalf of Kent County Council to manage the daily operation of the HWRCs. They will use the daily reports of vehicle registration number and booking reference to ‘check in’ customers upon arrival at the HWRC. Their privacy notices can be found on the FCC environment website and the CSKL website.
Our waste management contractors operate the following:
- CSKL: Dartford, Maidstone, Sevenoaks, Swanley, and Tunbridge Wells HWRCs
- FCC: Ashford, Canterbury, Deal, Dover, Faversham, Folkestone, Herne Bay, Margate, New Romney, Pepperhill, Richborough, Sheerness and Sittingbourne HWRCs.
In accordance with the above process we will use information collected from you to:
- identify you as part of your online booking request only
- process and confirm your booking
- contact you regarding your booking should it need to be amended or cancelled
- book you in on arrival at the recycling centre
- assist you with unloading your vehicle at the recycling centre should you require it
- notify you if there is an issue with the HWRC network that will impact upon your booking
- ensure that Kent County Councils booking rules are adhered to, including our terms and conditions
- determine how far customers travel to use the HWRC service, to assess availability/capacity at the sites, to determine how many non-Kent residents are using the HWRC service, and support any future policy change recommendations, in line with our Kent Disposal Strategy (PDF, 1.7 MB)
- contact you with a short satisfaction survey, if you have given permission for us to do so at the time of booking, to understand your experience of using the online booking form and your visit to a HWRC
Postcode data is extracted separately from the BookingBug system and used by KCC to determine where customers travel from to visit each HWRC for example X% of Sevenoaks HWRC customers were from Sevenoaks, X% were Kent residents outside of Sevenoaks, and X% were Non-Kent residents from Surrey etc.
If you ticked the box giving permission for KCC to contact you regarding a short satisfaction survey following your HWRC visit, your email address will be downloaded from the BookingBug system and used by KCC Performance Management Team to send you the survey link.
When appropriate to the service concerned (when a legitimate interest relevant to the service exists) KCC collect basic customer profile information, like age and gender, to help us understand which customer groups needs are being met by our services and which groups require better service provision. Profile data supplied in the customer satisfaction survey is only analysed when grouped with other customers, not individually, to help understand service performance amongst different customer groups and to inform future service provision decisions and/or service improvement.
Collecting and sharing your personal information
In order to administer and manage the booking scheme, we will share your customer unique booking reference number, your vehicle details and whether you require assistance at an HWRC to unload your vehicle, with the following third parties:
- the Waste Management Contractor who operate the HWRC that you will be using on KCC’s behalf.
- BookingLab Ltd. who operate the website-booking system (entitled BookingBug) on behalf of Kent County Council.
BookingLabs Ltd. are required to treat your data in accordance with GDPR and data protection legislation.
We will share personal information with law enforcement or other authorities if required by applicable law or in connection with legal proceedings.
We will share personal information with our legal and professional advisers in the event of a dispute, complaint or claim. We rely on Article 9(2)(f) where the processing of special category data is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
We share your email address with KCC Performance Management Team who will send you the survey link. Where you have agreed to participate in a survey when you booked via telephone, we will share your telephone number with KCC Contact Centre for the purposes of undertaking the survey via telephone.
Bookings made via our telephone contact centre
You may also make bookings over the telephone to use our HWRCs if you do not have access to the internet. To help deal with incoming telephone contact efficiently, such telephone calls are managed by our contact centre.
All of our contact centre advisors are employees of Agilisys, which operates the Contact Centre on our behalf or KCC staff when required.
Only authorised members of staff have access to the call recordings. Call recordings may also be shared with a limited number of authorised members of KCC staff, as part of our quality monitoring processes and complaints handling procedures.
When you contact our telephone contact centre and make a booking through them, the operative will fill in the booking form on your behalf. That will then generate a booking. We then share this with the HWRC operative as described above.
If you gave permission to be contacted regarding a customer satisfaction survey during your telephone booking, you will be contacted by telephone after your HWRC visit, and your survey responses entered into the survey form by the telephone agent on your behalf.
No information relating to your call is retained by Agilisys employees and information about your call is stored on computer systems belonging to and maintained by KCC.
Improving our service
In order to determine how far customers travel to use the HWRC service, how many non-Kent residents use our facilities and to assess availability/capacity at the sites, postcode information only will be processed automatically by KCC teams responsible for analysing this information. Results of analysis (in which full individual post codes will not be shown) will be reported at aggregate level showing how many customers travel from outside Kent (as described above), and will be shared with County Members to support any future policy change recommendations, in line with our Kent Disposal Strategy (PDF, 1.7 MB).
Responses to the satisfaction survey are summarised at aggregate level and will be used to support any future policy change recommendations, in line with our Kent Disposal Strategy (PDF, 1.7 MB).
How long your personal data will be kept
We will hold both your personal information (i.e. contact details and vehicle details) securely and retain this for 6 months, for the purposes of monitoring repeated use by you of our recycling facilities. This is to ensure that Kent County Councils booking rules are adhered to.
Information regarding your request for assistance at an HWRC with unloading your vehicle will be deleted the day after your visit to an HWRC.
If you call the telephone number to request a booking, calls will be recorded for training and monitoring purposes and to help us deal with customer feedback. Recordings are stored securely for up to 6 months then permanently deleted.
BookingLabs Ltd will only keep your personal data for up to 6 months then permanently deleted.
Your postcode information at aggregate level is contained within a report that will be created periodically and used to determine how far customers travel to use the HWRC service, how many non-Kent residents use our facilities and to assess availability/capacity at the sites. These reports (at aggregate level) of travel journeys by Kent (and non-Kent) residents to HWRC sites may be kept for future use to support any future policy change recommendations, in line with our Kent Disposal Strategy (PDF, 1.7 MB).
Reasons we can collect and use your personal information
KCC as the Waste Disposal Authority has a statutory duty to provide facilities for its residents to dispose of their household waste under section 51 of the Environmental Protection Act 1990 and has express and implied powers as to how this duty can be exercised. Accordingly, collection and processing is justified in so far as it is necessary. The legislative basis for this is, Regulation 6(1)(e) of GDPR “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 and section 8(c) of the Data Protection Act 2018, “the exercise of a function conferred on a person by an enactment or rule of law”.
We rely upon Article 6(1)(b) processing necessary for the performance of a contract to which the data party is subject, because when booking your HWRC visit you will be asked to agree to the Terms and Conditions as detailed in the booking form.
To carry out the customer satisfaction survey, we rely on Article 6(1)(e) “processing is necessary for the performance of a task carried out in the public interest” and Article 9(2)(j) is necessary for “research and statistical purposes in the public interest” as the lawful basis on which we collect and use your special categories of personal data.
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 for a copy of your non-trade waste declaration form
- 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.
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 firstname.lastname@example.org 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 email@example.com, or write to: Data Protection Officer, Sessions House, Maidstone, Kent ME14 1XQ.