How we use your information
This is a general privacy notice which tells you what to expect when the North London Waste Authority (NLWA) collects personal information.
When we carry out specific activities not mentioned in this Policy, we may give you a specific privacy notice which includes an explanation of what we intend to do with personal information.
NLWA will keep personal information it collects in accordance with its Personal Data Retention Policy (this can be read or freely downloaded below). The Personal 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;
- active deletion of personal data that is no longer used;
This policy applies to information we may collect about the following:
1. Visitors to our websites
2. People who contact us (online, or by email, fax, post or telephone)
Where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
NLWA is part of the London Borough of Haringey’s IT network. 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.
3. People who make a complaint to us
When we receive a complaint from a person we make up a file (electronic and/or hard-copy) containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We may compile and publish statistics showing information, such as the number of complaints we receive, but not in a form which identifies anyone.
If a complainant informs us that they do not want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.
Where appeals in relation to complaints are made to the London Borough of Camden in accordance with NLWA’s complaints procedure, personal information held by NLWA in relation to the complaint may be shared with Camden’s Central Complaints Unit.
If we receive queries or complaints about waste collection or other services provided by other public bodies we may refer the complaint and relevant personal details to the relevant body so that they can respond to the query or complaint.
A copy of our complaints procedure is available on our website in the Transparency section.
4. Responding to FOI, EIR or subject access requests
When we receive an information request from an individual or organisation we create an electronic file (and/or a hard-copy file) containing the details of the information request. This file(s) will normally contain the identity of the requestor.
We will use the personal information we collect to process the information request and to check on the level of service we provide. We may in addition retain the information about the requestor after the request has been completed, e.g. in case there is an appeal or complaint about the way in which the request was handled or because a number of similar requests have been received from an individual and we need to retain the request details to aggregate the information.
We may compile and publish statistics showing information, such as the number of information requests we receive, but not in a form which identifies anyone.
If a person requesting information informs us that they do not want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle an information request on an anonymous basis.
Where appeals in relation to complaints are made to the London Borough of Camden in accordance with the NLWA’s complaints procedure, personal information held by NLWA in relation to the complaint may be shared with Camden’s Central Complaints Unit.
Where an information request is received via a third party, e.g. from another local authority or an information request processing website, we may or may not receive information that identifies the requestor and the Authority will deal with such information in accordance with this Privacy Notice.
5. People who apply for or use our services
We provide services through a range of organisations. The details of these organisations change as different contracts are let.
Details of our current list of service suppliers are available from NLWA.
We will only hold the details of the people who have requested services in order to provide those services and for other closely related purposes. For example, we might use information about people who have requested a publication to carry out a survey to find out if they are happy with the level of service they received. When people do subscribe to our services, they can cancel their subscription at any time and are given an easy way of doing this.
We conduct regular user surveys of Reuse and Recycling Centres (RRCs) in our area. We may ask residents using recycling services for personal information such as their address and the borough they live in. We may also record the vehicle registration numbers of cars visiting HWRCs. This information is collected for the purposes apportioning the costs of providing HWRC services to NLWA’s constituent borough councils and monitoring the usage or quality of HWRC services.
6. People who attend our events
When we attend or deliver events we regularly collect details of the people who attend, but only with their consent. Depending upon attendees’ approvals we may either retain the personal information for assessing the level of service we have provided at the event, for providing follow-up information, or for contacting the person at a later date for research purposes.
Personal details will only be collected with the person’s consent and we will only use these details to carry out the work or to provide the information or service that the person has agreed to or requested. For example, we might use information to provide people with a relevant publication or newsletter following the event.
When people agree to us collecting their details at an event and subsequently using these details people can cancel this agreement at any time and are given an easy way of doing this.
7. People who participate in our competitions or prize draws
On occasion NLWA, either directly or via third parties, will organise competitions or prize draws. We will collect the minimum amount of personal information necessary to deliver the competition or prize draw.
We will only use the personal information we collect to run the competition and award any prizes resulting. We may compile and publish statistics showing information such as the number of entrants to the prize draw, or which areas generated most interest in the competition or prize draw, but not in a form which identifies anyone.
The exception to not identifying people who have entered the competition or prize draw is the competition or prize draw winners whose personal details may be disclosed in line with the rules of the competition and their prior consent.
8. People who participate in NLWA research
NLWA carries out a variety of research ranging from contacting people who have visited our food waste prevention stand at an event six months later to see if they are still using the information they received, to commissioning research to get feedback from resident focus groups on a new range of recycling advertisements or the NLWA website.
All research that is commissioned by the NLWA is carried out in line with industry guidelines including the Market Research Society Code of Practice to ensure that participant details are not disclosed to NLWA.
Where the participant’s details are disclosed or provided to NLWA with the participant’s consent this will only be used for the purpose for which the details were given for example in order to provide either additional information on NLWA or to check on the level of service NLWA provide.
9. Monitoring equality
NLWA has a legal duty when exercising public functions, to have due regard to the need to: eliminate discrimination, harassment, victimisation; advance equality of opportunity; and foster good relations between persons who share a relevant protected characteristic (such as age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex and sexual orientation) and persons who do not share it. NLWA may gather and analyse statistical information on protected characteristics or conduct equality impact assessments to ensure that it carries out its function in line with its legal duties. Such statistical information does not identify individuals. If your information is collected for these purposes, it will be anonymised.
10. Fraud, bribery and crime prevention
NLWA is required by law to take steps to help prevent and/or detect potential fraud and crime by both conducting our own data matching exercises as well as sharing information with other public bodies such as the Audit Commission, other local authorities, government departments or minsters, Revenues and Customs and the Police. Please see the NLWA National Fraud Initiative Statement 2013/14 on our website for more details on data matching - National Fraud Initiative
Personal Data Retention Policy
NLWA also has a Personal Data Retention Policy which applies to personal data within documents.