Fleet analytics privacy notice
This Privacy Notice has been created to make it easier for you to understand what personal data Warwickshire Police processes about you, how and why it will be used in connection with your employment and use of the force's vehicle fleet as is required under the UK General Data Protection Regulation (UK GDPR).
It is subordinate to, and should be read in conjunction with, the appropriate high-level Privacy Notice for Warwickshire Police.
This privacy notice is relevant to all current, prospective and former employees’ (which includes staff, officers, specials and PCSOs).
It also includes contractors, apprentices and volunteers who undertake roles similar to employees. The force collects and processes a significant amount of personal data, and we are committed to being transparent about how we collect and use that data.
For what purpose(s) is my personal data intended to be processed by Warwickshire Police?
When you drive a vehicle owned and maintained by Warwickshire Police, data will be collected via an on-board fleet analytics (telematics) device.
As this information relates to you, it is considered to be personal data.
We will use the information about you for several reasons. This includes, but is not limited, to:
- Maintain fleet optimisation with the placement or reduction of vehicle numbers and increased fleet utilisation.
- Reduce fuel usage and the number of road journeys via better utilisation of the fleet;
- Reduce maintenance costs through less component wear and tear (e.g. tyres);
- Make safety improvements, cost savings and environmental benefits through reduced carbon emissions.
- Improve the risk management of the fleet to reduce the number and value of collisions that occur.
- Investigate serious and fatal vehicle collisions;
- Assist in the investigation of a vehicle driving complaint or incident where it is deemed necessary.
- Inform / improve driving standards to enable targeted training and support, resulting in improved public confidence and service levels; and
- Support motor insurance claims.
When we process your personal information, we will comply with data protection legislation and enable you to exercise your rights contained within the legislation.
What types of information do we handle via the Fleet Analytics process?
The information that we collect about you will be collected by a telematics device fitted to the vehicle, alongside the device recognising you as the operator of the vehicle (i.e. name/collar number) the device will collect the following information:
- Records Braking
- Records Acceleration
- Records Cornering
- Monitors Speed
- Monitoring Officer time behind the Wheel
- Driver Activity Log
- Audit Trail of vehicle’s past activities
- GPS Location / Live tracking of vehicles
- Geofencing
- Crash Detection
- Vehicle Mileage
- Emergency Lights/ Siren detection
- Police Car Alarm Detection
- Engine Warning Light Detection
- Record Gun Box Opening
- Engine On/Off
- Engine Idle Time
- CO2 Emissions
- Audit – Journey Logging
- Audit – Analysis of vehicle usage
What is the lawful basis for processing my personal data?
The lawful basis for processing personal data is that it is necessary to fulfil our Contractual and Legal Obligations and to carry out tasks that are in the public interest or under our legitimate interests.
For example relevant applicable legislation includes, but is not limited to, The Health and Safety at Work Act 1974, The Road Vehicles (Construction and Use) (Amendment) (No.4) Regulations 2003, The Motor Vehicles (Driving Licences) (Amendment) (No.3) Regulations 2004 and Corporate Manslaughter Act 2007.
The information provided by you may also include personal data relating to criminal offences. The condition under which this information is processed is for the defence of legal claims, and for reasons of substantial public interest.
This includes for the purposes of insurance and preventing and detecting unlawful acts. Information from the Fleet Analytics equipment could be used in cases where the Force are required to identify a driver under the Road Traffic Act 1988, or when it is necessary for any other lawful purpose.
Where do we obtain personal information from for the Fleet Analytics process?
Your work details such as name/collar number will be linked to the Fleet Analytics system to capture you as operating or travelling in a Force vehicle, this is taken from Origin. This data is then logged against the data points mentioned above.
The system may also link to other Fleet management systems e.g. Tranman or be used by Legal for insurance purposes or managing legal claims or used in our Data Lake for analytical purposes.
Who will my personal data be disclosed to by Warwickshire Police?
See Section “What disclosures do we make of your personal data” on the high-level privacy notice on the website.
We will also disclose personal information to other bodies or individuals when required to do so by, or under, any act of legislation, by any rule of law, and by court order.
How long does Warwickshire Police retain personal information obtained for the Fleet Analytics process?
The Force keeps personal information as long as is necessary for the particular purpose or purposes for which it is held.
A copy of the Forces Records Retention Schedule is available on the intranet or on request.
What are my rights under the UK GDPR?
Full details of those rights and how to exercise them can be found in the high-level privacy notice on the website or by emailing: [email protected]
Who can I lodge a complaint with if I am unhappy about the way my personal data is processed by Warwickshire Police?
You may lodge a complaint with the Information Commissioner’s Office. Their contact details are:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: www.ico.org.uk
You may wish to initially raise any concerns with the Data Protection Officer.
Will my personal data be used for automated decision-making, including profiling?
No
Will my data be transferred abroad?
No