Global Positioning System tracking in Council vehicles
The proper handling of personal information by Carmarthenshire County Council is very important to the delivery of our services and maintaining public confidence.
Personal data is any information that relates to a person who can be directly or indirectly identified from the information. The terms ‘information’ and ‘personal data’ are used throughout this privacy notice and have the same meaning.
To ensure that the Council treats personal information correctly, we seek to adhere in full to the requirements of Data Protection legislation.
This privacy notice has therefore been produced to explain as clearly as possible what we do with your personal data.
1. The purpose for which we use your personal data
We use Global Positioning System (GPS) tracking in Council vehicles to make fleet management more efficient and cost effective. Specifically, it enables us to:
• Effectively respond to service demands.
• Effectively configure employees (e.g. working patterns, locations) to provide an efficient and responsive service.
• reduce wear and tear on vehicles, thus reducing maintenance costs.
• Reduce fuel wastage.
• Lower insurance costs.
GPS tracking also enhances the security of our vehicles as their whereabouts will be known at all times.
It also supports managers in fulfilling their responsibilities to safeguard employees that may be vulnerable or at risk due to lone working issues.
GPS is also used to monitor driver compliance, for instance, driving performance or unauthorised private use. Where there is a serious breach of policy, GPS tracking information may be used to support disciplinary proceedings.
Tracking also allows us to monitor driver performance and to identify and support you by identifying training needs and helping to reduce accidents etc.
Finally, GPS tracking protects the Council from false claims made by the public or other road users, leading to fewer third party claims.
The lawful basis for processing the personal data is as follows:
Legal obligation – processing is necessary for compliance with a legal obligation to which the controller is subject. These legal obligations are in relation to Health & Safety (Lone Working) and Monitoring of Driver Performance (Speed, Accidents)
The relevant legislation includes:
• The Management of Health & Safety at Work Act 1999
• The Health & Safety at Work Act 1974
• Road Traffic Act 1988
Public task/work - the other basis for processing this data is that it is necessary to do so to perform a task carried out in the public interest, or in the exercise of official authority vested in the controller (on the basis of the legislation listed above).
2. What type of information do we use?
The information captured when tracking a vehicle can be associated with and linked to the driver of the vehicle. GPS tracking on vehicles therefore indirectly captures the following personal data relating to the driver:
• The location and movement of the driver, and in some circumstances its passengers when using the vehicle.
• The times/dates the driver uses/doesn’t use the vehicle – this can be related to the drivers working times.
• The speed at which the driver is travelling.
• Driving style and associated data (harsh braking, harsh acceleration) etc.
• Other data relating to vehicle telematics/information.
3. Do we use information received from other sources?
We only collect personal data using GPS tracking installed in vehicles. We don’t routinely obtain information about you from any other sources.
4. Transferring your information abroad
We don’t transfer any information about you outside of the UK.
5. Who has access to your information?
The Council will use your personal data only when there is a need for us to do so and to the extent that is necessary in each case. An example of who might use the data is set out below:
• The Council’s Fleet Management team and service managers.
• The employee’s Line Manager/Management Team.
• Health & Safety team
• Human Resources (only in the event of disciplinary action where appropriate).
• Risk Management (Insurance Section) – in the event of damage to a vehicle. Where there is a third party claim relevant information may be shared with the third party’s representative for example, an insurer.
There are also other specific situations where we may be required to disclose information about you, such as:
• Where we are required to provide the information by law.
• Where disclosing the information is required to prevent or detect a crime.
• Where disclosure is in the vital interests of the person concerned.
6. How long we will keep your information
GPS data is routinely deleted 7 years after the data is captured.
Please note where vehicle tracking data is used as evidence in a disciplinary or insurance claim etc. system reports may be held longer for that purpose.
7. Your Data Protection rights
You have the right to:
- Obtain access to the personal data that Carmarthenshire Council is processing about you
- Have any inaccurate or incomplete information rectified (corrected)
- Withdraw your consent to processing, where this is the only basis for the processing
- Make a complaint to the Information Commissioner’s Office (ICO), the independent body in the UK which protects information rights
In some circumstances, you may have the right to:
- Object to the processing of your personal information
- The erasure of your personal data
- Restrict the processing of your personal information
- Data portability
8. Contact details
For more information regarding this privacy notice and your rights, please contact:
Data Protection Officer
Carmarthenshire County Council
Contact details for the Information Commissioner’s Office along with further guidance on Data Protection legislation can be found on the ICO website.