Privacy Notice
Version 2.3 (Last updated 28 July 2022)
West London Waste is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you when you make a booking to use one of the West London borough recycling centres, in accordance with the General Data Protection Regulation 2016 (GDPR) and Data Protection Act 2018 (DPA).
West London Waste is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to all data we capture when you create an account/make a booking to use a household waste and recycling centre. We may update this notice at any time.
It is important that you read this privacy notice, together with any other terms and conditions so that you are aware of how and why we are using your information.
West London Waste Authority use the Gov.Uk Notify system to send SMS text messages for booking confirmations only.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
Used lawfully, fairly and in a transparent way
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
Relevant to the purposes we have told you about and limited only to those purposes
Accurate and kept up to date
Kept only as long as necessary for the purposes we have told you about
Kept securely
What information do we hold about you?
We will collect, store, and use the following categories of personal information about you:
your first and last name
residential address
email address
telephone number
date and time of visit
vehicle registration number
username
categories of waste you are disposing of
We will not ask you for any special category (sensitive) personal data.
How is your personal information collected?
As a general rule we collect personal information directly from you when you make a booking or when somebody makes a booking on your behalf. We may cross reference the data you have provided with data provided by your borough council.
What legal basis do we rely on to process your personal information?
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
Where we need to perform the contract we have entered into with you, for example to enable you to book in and use the recycling centre
Where we need to comply with a legal obligation, for example to ensure the safe disposal of hazardous waste such as asbestos
Where it is necessary for our legitimate interests (or those of a partner) and your interests and fundamental rights do not override those interests. This includes monitoring your use of the recycling centre, to protect our staff and those who work at the recycling centre.
CCTV
We operate CCTV (Closed-Circuit Television) at all of our sites. Many of these sites also have ANPR (Automatic Number Plate Recognition) in place. These systems are in place to keep our staff and visitors safe, monitor site visits, control access to our sites and to help in the prevention and detection of crime.
What will we use your personal information for?
We use all the categories of information in the list above primarily to allow us to perform our contract with you to use the recycling centre and to enable us to comply with legal our obligations. In some circumstances we may use your personal information to pursue legitimate interests of our own or the borough, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
To create a user account
To enable you to make a booking to use a household waste and recycling centre and send a booking confirmation email or contact you by email, SMS or phone if we need to make an amendment to your booking or contact you about future bookings and use the site
Checking in residents when they arrive at site
Cancelling or amending slots
Changing account details
Monitoring visitor numbers vs capacity
Monitoring usage (frequency of visits) and identify visitors who are making too many bookings, suspected traders/landlords and stop you using the site
Monitoring no shows
Monitoring trends of visits across days/seasons
Monitoring waste types brought in to enable us to improve kerbside services and manage resources on site
Use the waste types selected to provide you with information around reuse and recycling to reduce waste
Monitoring where visitors are from to ensure they are only from within West London Waste boroughs
Flagging up aggressive/abusive visitors
Flagging up visitors booking in incorrectly e.g. large vans booking in as a car
To identify suspected traders and landlords
To ask visitors for their views and opinions on our services
We may also use aggregated data to monitor long term use of our booking system and recycling centres
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to provide the service you have requested, including visiting a recycling centre.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Who else has access to my data?
If your household waste and recycling centre is operated by your borough, we operate the Brent centre, then we will provide them with your booking information. These boroughs are; Ealing, Harrow, Hillingdon, Hounslow and Richmond upon Thames. You can find information on how your borough uses your personal data from the privacy notice on their website.
Your data may also be shared between West London Waste, Brent, Hounslow, Richmond and Ealing. This is specifically for the purpose of identifying and managing site users who are suspected of being traders or landlords, booking in incorrectly e.g. large vans booking in as a car and aggressive/abusive behaviour towards site staff.
How secure is my information with those who have access?
As you would expect each borough takes appropriate security measures to protect your personal information in line with strict information governance policies.
Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and partners who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data retention
How long will you use my information for?
We will only retain your personal information 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. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from the data protection officer. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. In most cases we will only retain your data for 12 months after your last booking.
Rights of access, correction, erasure, and restriction
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a partner) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Human Resources Manager in writing.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the data protection officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you have any questions about this privacy notice or how we handle your personal information, please contact us. 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.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. If you have any questions about this privacy notice, please contact us.
If you are unhappy
If you are unhappy about how we handled your personal data you can complain to:
The Information Commissioners Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF