Who Publica is and what Publica does
We are “Publica Group Limited” and are a council owned employment company which delivers shared services between Cotswold, West Oxfordshire, and Forest of Dean District Councils and Cheltenham Borough Council (hereon known as “Clients”). Publica additionally provides services to the Cotswold Conservation Board, Cheltenham Borough Homes and UBICO (an environmental services local authority company) (hereon known as “Clients”).
We are the Corporate Communications team and we operate a drone to capture images of council services and images of our district generally.
The Councils (as referred above) are the data controllers for the work captured by the drone.
This notice explains why we ask for your personal information, how that information will be used and how you can access your records.
Any questions regarding our privacy practices should be sent to:
Data Protection Officer (DPO)
Publica Group Limited
Trinity Road, Cirencester GL7 1PX
Tel: 01993 861194
Why do we need your information and how we use it
We use drone footage to capture images of council owned facilities for promotional purposes. The team will also capture other images of the district to promote the Councils generally, and local services. Landowner permission where necessary will be obtained at all times.
In the vast majority of occasions, and as a standard practice, any images of people or vehicles that would be in breach of data protection laws will be obscured in our final edit before publication.
We do not sell your personal information to anyone else.
What is the legal process for collecting and processing this data
Under the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018, the lawful bases we rely on for processing this information are:
- UK GDPR Article 6 (1) (a) Consent – consent has been given by the data subject, yourself, for the lawful processing of your personal data.
What type of information is collected and how will we use it?
We use drone footage to capture images of councils owned facilities for promotional purposes. The images will be used on promotional channels such as social media and websites.
We do not collect or store any personal information such as names, contact details or addresses - only images.
Who your information may be shared with (internally and externally)
All information/footage will be used for promotional material on our social media platforms, e-newsletters, websites and printed materials, across our services and in partnership with third parties for marketing campaigns.
Any personal information protected by law will not be disclosed to any other organisations, except where we are required and allowed to by law, to safeguard public safety and in risk of harm or emergency situations.
How long do we keep your information (retention period)
In the majority of occasions once a final edit is produced, all raw footage containing unobscured images will be maintained on the councils secure systems. This includes images of individuals and/or property where permission has been obtained. We will only keep images containing personal information if permission is obtained in compliance with law.
Images will be kept for 3 years.
Once your data is no longer needed it will be securely and confidentially destroyed or disposed of in line with retention schedules.
How do we protect your information
Your data is stored securely on our systems and accessed only by authorised officers using their own username and password created in line with pre-defined user credentials. Personal data is also held in electronic files on our network drives. These are only accessible through personal logon credentials and access privileges to specific drives. Access to Publica and our council sites require a personal electronic pass to access staff only areas. We have strict procedures for the way this is done. Any and all information about you is treated as confidential and with respect. There are also clear rules and guidance about storing, recording and sharing information which staff receive training on.
We will not transfer your personal data outside the EU without your consent.
We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse or unauthorised alteration or destruction.
Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.
We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
You have the following rights under the Data Protection Legislations:
- To access your personal data
- To be provided with information about how your personal data is processed
- To have your personal data corrected
- To have your personal data erased in certain circumstances
- To object to or restrict how your personal data is processed
- To have your personal data transferred to yourself or to another business in certain circumstances
- To be told if the Council have made a mistake whilst processing your data and the Council will self-report breaches to the Commissioner.
How you can access, update or correct your information
The Data Protection law gives you the right to apply for a copy of information about yourself. This is called a ‘Subject Access Request'.
If you wish to see a copy of your records you should contact the Data Protection Officer. You are entitled to receive a copy of your records free of charge, within a month.
In certain circumstances access to your records may be limited, for example, if the records you have asked for contain information relating to another person.
The accuracy of your information is important to us to be able to provide relevant services more quickly. We are working hard to make our record keeping more efficient. In the meantime, if you change your address or email address, or if any of your circumstances change or any of the other information we hold is inaccurate or out of date, please email us or write to us at:
The Communication Team
Publica Group Limited
Trinity Road, Cirencester, GL7 1PX
If you would like to know more about how we use your information, or if for any reason you do not wish to have your information used in any of the ways described in this privacy notice, please contact the Data Protection Officer at email@example.com
For more information about data protection please visit: www.publicagroup.uk/privacy-notice/data-protection-act-overview
For more information about the Drone and Model Aircraft Code: https://register-drones.caa.co.uk/drone-code/protecting-peoples-privacy
If you are concerned about the way we are handling your personal information you can contact the Information Commissioner (ICO): https://ico.org.uk/make-a-complaint/
The Council reserve the right to update this privacy notice from time to time by publishing a new version on our website.