Personal Data Retention Policy and Privacy Notice
NLWA has a Personal Data Retention Policy which applies to personal data within documents and a Privacy Notice which tells you what to expect when we (North London Waste Authority) collect personal data.
This is a general privacy notice which tells you what to expect when we (North London Waste Authority (referred to as "NLWA", "we", "us" or "our" in this privacy notice)) collect personal data. Personal data means any information about an individual from which that person can be identified such as a name, address or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person. Personal data does not include data where the identity has been removed (anonymous data).
2. Important information and who we are
When we collect your personal data or when you provide us with your personal data, NLWA is the controller and responsible for your personal data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Data Protection Officer
North London Waste Authority
Unit 1B, Berol House, 25 Ashley Road
London, N17 9LJ
Name and title of DPO: Hugh Peart, Data Protection Officer
Email address: firstname.lastname@example.org
Telephone number: 07870 362243
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3. The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
- Contact Data includes postal address, email address and telephone numbers.
- Employment History and Qualifications Data includes qualifications, employment history, skills and experience.
- Technical Data includes your login data, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
We will only collect your Special Category Data in the limited circumstances set out below and only with your explicit consent. Special Category Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, health, trade union membership or genetic data. It also includes biometric data where it is collected for the purpose of uniquely identifying a natural person. The Special Category Data we collect and the circumstances we collect the data are:
- We record your ethnicity when you apply for our Nappy Voucher Scheme.
- We take photographs of individuals at our events, which may be Special Category Data.
- We only collect information about criminal convictions and offences in order to carry out a check with the Disclosure and Barring Service for the purpose of employment for a position which requires staff to be checked with the Disclosure and Barring Service.
4. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact details by filling in forms or surveys/questionnaires at our events or on our websites or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- sign up to attend our events or receive our invitations;
- subscribe to our newsletters, progress reports or updates on our activities or projects;
- request for information to be sent to you, including information requests under the Freedom of Information Act 2000 (FOI) or the Environmental Information Regulations 2004 (EIR);
- enter a competition, prize draw or participate in a survey we are carrying out;
- apply for a grant from us;
- give us feedback;
- Contracts and procurement. You may provide us with your personal data as part of a tender process we are undertaking for which you want to be considered as a bidder or to fulfil a contract with us; or
- Consultation responses. You may provide us with your personal data as part of your response to a consultation we are carrying out to fulfil a legal obligation or to perform our functions as a public body.
- Our contractors. You may provide your data to one of our contractors delivering a contract on our behalf and the contractor sends us your personal data as part of the delivery of the relevant contract. For example when you participate in our Nappy Voucher Scheme.
- Third parties or publicly available sources. We may receive personal data about you from third parties and public sources as set out below:
- Technical Data from analytics providers such as Google;
- Identity and Contact Data from publicly availably sources such as the Companies House.
5. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where needed to perform our public task as a public body fulfilling our statutory functions. For example collecting vehicle registration numbers which can be linked back to the owner when people visit a reuse and recycling centre. We collect the vehicle registration details in order to prevent unauthorised entry to a reuse and recycling centre.
- Where needed to perform the contract we are about to enter into or have entered into with you. For example where we hold details of key personnel or account manager of a supplier.
- Where you have provided us with consent to do so. For example where we have sought your consent to send you information about our annual waste prevention conference.
- Where we needed to comply with a legal or regulatory obligation. For example if we are responding to a request for information under the Environmental Information Obligations (EIR) we will need the name and contact details of the person to whom we must send the information requested.
Paragraph 6 below sets out more about the types of lawful bases that we will rely on for the specific processing activities we undertake.
Where we are relying on consent to process your personal data, you have the right to withdraw consent at any time by emailing us at email@example.com
6. Purposes for which we will use your personal data
We have set out in the link below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you would like an explanation about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table in this link.
7. Recipients of personal data
We do not share personal data with third parties outside NLWA except in the following limited circumstances and for the purposes set out in the table in paragraph 6:
- To our service providers and professional advisers to deliver our contracts for the performance of our public functions or to meet a legal obligation. Any information provided to our service providers or professional advisers is subject to strict contractual confidentiality obligations;
- To our constituent borough councils and only on a need to know basis or as a result of a request from you, in order to perform our statutory functions or to meet a legal obligation or so that you can access a borough provided service. For example, we may pass on your contact details with your consent if you attend our event for which you will be eligible to receive local green points or credits from the borough for attendance. We also have contractual arrangements with some of our constituent boroughs which are explained below.
- NLWA is part of the London Borough of Haringey’s IT network. London Borough of Haringey provides all our IT and system administration services. Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used.
- NLWA staff are employed by the London Borough of Camden. Where appeals in relation to complaints are made to the London Borough of Camden, personal information held by NLWA in relation to the complaint may be shared with Camden’s Central Complaints Unit.
Details on NLWA and our relationship with our constituent boroughs can be found in this link.
- To regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
- To other public bodies to comply with any applicable law, regulation, code of practice or enforceable government guidance. Please see our National Fraud Initiative Statement below showing when we share personal data with other public bodies to prevent or detect fraud.
We require all recipients of personal data from us to respect the security of your personal data and to treat it in accordance with the law. When our service providers are processing your personal data on our behalf, we do not allow service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
NLWA National Fraud Initiative Statement
NLWA is required by law to protect the public funds it administers. We may share information provided to us with other bodies responsible for auditing or administering public funds, or where undertaking a public function, or order to prevent and detect fraud. The Cabinet Office is responsible for carrying out data matching exercises.
Data matching involves comparing computer records held by one body against other computer records held by the same or another body to see how far they match. This is usually personal information. Computerised data matching allows potentially fraudulent claims and payments to be identified. Where a match is found it may indicate that there is an inconsistency requiring further investigation. No assumption can be made as to whether there is fraud, error or other explanation until an investigation is carried out.
Working with our constituent borough councils we participate in the National Fraud Initiative: a data matching exercise to assist in the prevention and detection of fraud. We are required to provide particular sets of data to the Minister for the Cabinet Office for each matching exercise as detailed in this link.
The use of data by the Cabinet Office in a data matching exercise is carried out under Part 6 of the Local Audit and Accountability Act 2014. Data matching by the Cabinet Office is subject to a Code of Practice.
Further information on the Cabinet Office’s legal powers and reasons why it matches particular information can be found in this link.
8. Our websites and cookies
We do not make any attempt to find out the identities of those visiting any of our websites, namely nlwa.gov.uk or northlondonheatandpower.london. This privacy notice applies to all our websites. Our sites may, from time to time, contain links to and from the websites of our constituent boroughs or related organisations. We do not control these third-party websites and are not responsible for their privacy statements or policies. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
9. International transfers
We do not transfer your personal data outside the European Economic Area (EEA). However, when we share your personal data with our service providers, it may involve transferring your data outside the European Economic Area (EEA).
Whenever our service providers transfer your personal data out of the EEA, we will require all service providers that are processing your personal data to ensure a similar degree of protection is afforded to our information by ensuring at least one of the following safeguards is implemented:
- your personal data is transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- specific contracts approved by the European Commission are used which give personal data the same protection it has in Europe.
- your personal data is protected as the service provider requires all its group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules".
- Where your personal data is transferred to the US, the transfer data to them is made if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by a service provider when transferring your personal data out of the EEA.
10. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They are all subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Where we carry out research for statistical purposes, we always ensure that we anonymise the personal data we hold.
11. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Our Data Retention Policy is based on the following principles:
- compliance with data protection legislation;
- regular reviews of data we hold;
- sensible retention periods that allow us to use the data for the purposes for which it was collected; and
- active deletion of personal data that is no longer used.
Details of retention periods for different aspects of your personal data are available in our Data Retention Policy.
12. Your legal rights
- Request access to your personal data (known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove your personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with a legal obligation or where we are relying on consent as the lawful basis or processing and you withdraw your consent. Note, however, that this right is not absolute and we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. For example, you will not have this right where the legal basis for processing is the performance of a public task or compliance with a legal obligation.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Note, however, that this right is not absolute and we may not always be able to comply with your request to restrict processing for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to withdraw consent. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
- Object to processing of your personal data where there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. Note, however, that this right is not absolute and we may not always be able to comply with your request to stop processing if (i) we have compelling legitimate grounds for the processing, which override your rights and freedoms or (ii) the processing is for the establishment, exercise or defence of legal claims. We will communicate our reasons to you, if applicable, at the time of your request.
If you wish to exercise any of the rights set out above, please contact our Data Protection Officer.
No fee is usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Changes to the privacy notice
This version of the privacy notice was last updated on 22 June 2018. Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
It is important that the personal data we hold about you is up-to-date and accurate. Please keep us informed if your personal data changes during your relationship with us.