Privacy Policy

Who are we?

Cireco (Scotland) is an arms-length organisation of Fife Council. We were set up to provide services on behalf of the Council such as:

Commercial waste services
Recycling Points
Household Waste Recycling Centres
Skip Hire

In these circumstances, when we are acting on behalf of the Council, we are Data Processors of your data and Fife Council is the Data Controller.  You can read Fife Council’s Privacy Policy at www.fife.gov.uk/privacy

For other personal data we process, we are a Data Controller in our own right, registered with the Information Commissioners Office – registration no. ZA366759.

Cireco (Scotland) takes the issue of security and data protection very seriously, including compliance with the UK General Data Protection Regulation, the UK Data Protection Act 2018 and the Privacy and Electronic Communications Regulations.

We have a separate Privacy Notice for our employees.

How do we use your information?

This notice explains how we use and share your information by providing a general description of what categories of personal information we collect about you, why we collect it and what we use it for.

We generally collect, use and hold information about you in order to provide services and to carry out statutory functions on behalf of Fife Council. Information may be collected by Cireco (Scotland) on a paper or online form, by telephone, email, CCTV, body worn cameras, Automatic Number Plate Recognition (ANPR), or by a member of our staff.
 

Telephone calls

We will inform you if we record or monitor any telephone calls you make to us. We do not record any financial card details if you then make payments by telephone.
 

Using our website

If you are a user with general public access, the Fife Council, on behalf of Cireco (Scotland), web logs a number called your IP address which is automatically recognised by the system.

The system will record personal information if you:

• subscribe to or apply for services that require personal information,
• report a fault and give your contact details for us to respond,
• contact us and leave your details for us to respond.

 

What personal information do we use?

Your name and contact details (address, e-mail address, phone numbers)
Financial information in relation to payments you may make to us
Whether you are a domestic or commercial company
Medical conditions you have that may help us with providing a service to you
Your image from CCTV or body-worn cameras
Your voice from telephone recordings
Your car registration number.

 

Why do we collect information about you and how do we use it?

We need to collect and hold information about you, to:

• deliver the service you requested, and to monitor and improve Cireco (Scotland)’s performance in responding to your request
• understand your needs to provide the services that you request
• understand what we can do for you and inform you of other relevant services and benefits
• obtain your opinion about our services
• help us to build up a picture of how we are performing at delivering services to you and what services the people of Fife need
• process financial transactions
• collect monies owed to us
• allow us to undertake our statutory functions efficiently and effectively
• prevent and detect fraud and corruption in the use of public funds
• make sure we meet our legal and statutory obligations including those related to diversity and equalities
• where necessary, to help with law enforcement such as the prevention and/or detection of crime
• where necessary, to protect individuals from harm or injury
• for purposes connected to the delivery of the service such as IT support; legal/financial advice and support and the delivery of internal audit and risk management
• to take decisions at the appropriate level
• to allow the statistical analysis of data so we can plan the provision of services.

​​We may not be able to provide you with a product or service unless we have enough information, or your permission to use that information.

We will use the information you provide in a manner that conforms to the UK General Data Protection Regulation and the Data Protection Act 2018.  We will always have a legal purpose for processing your personal information which we consider are:

• where we are delivering services on behalf of Fife Council – processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority.
• for the normal running of our business, such as dealing with suppliers of services, or processing our financial transactions –processing is necessary for the purposes of the legitimate interests pursued by Cireco (Scotland) or by a third party; except where our interests are overridden by your interests or fundamental rights and freedoms.
• to comply with our legal obligations, including helping with prevention and detection of crime.
• when you buy a product or service from us - processing is necessary for the performance of a contract to with you or in order to take steps at your request prior to entering into a contract.
• in other circumstances we may rely on another legal purpose provided by the data protection legislation.

 

How long do we keep your information?

Cireco (Scotland) will not keep your information for longer than is necessary. In some instances, the law sets the length of time information has to be kept. Where the law does not set a period, Cireco (Scotland) will keep your information for no longer than it is required for the purpose for which it was collected. Because these periods can vary, there is no single answer to how long we will keep your information. Cireco (Scotland) follows Fife Council timescales for keeping data.

In addition, there are some other factors that can influence how long we keep your information. These include:

• your personal data rights (see below)
• where a record containing your information forms part of evidence gathered as part of an investigation*
• where a record containing your information is selected for permanent preservation*.

*Where this happens, safeguards are put in place to ensure that your information is secure.

 

Information Sharing

At times, we will share your information with Fife Council services as well as external partners, organisations and suppliers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. However, when we use these third parties, we disclose only the personal information that is necessary to deliver the services, and we have a contract in place that requires them to keep your information secure and prevents them from using it for their own direct marketing or any other purposes.

We may disclose information to other partners where it is necessary, either to comply with a legal obligation, or where permitted under the UK General Data Protection Regulation/Data Protection Act, for example, where the disclosure is necessary for the purposes of the prevention and/or detection of crime.

We may disclose information when necessary to prevent risk of harm to an individual.

Detection and prevention of fraud

Cireco (Scotland) is required by law to protect the public funds it administers. We may use any of the information you provide to us for the prevention and detection of fraud. We may also share this information with other bodies responsible for auditing, administering public funds, or where undertaking a public function, in order to prevent and detect fraud. This includes the Cabinet Office, the Department for Work and Pensions, other local authorities, HM Revenue and Customs, Audit Scotland and the Police.

Emergency Resilience

Data matching may also be used to assist Cireco (Scotland) in identifying individuals who may need additional support if an actual or potential incident impacts Fife. This information may also need to be shared with partner agencies in responding to the incident.

 

How we protect your information

All our systems where any personal data is stored are given appropriate protection.  For example, our IT systems are protected by firewalls and anti-virus systems and are limited by access controls to only those people who need to see your information to do their job; our paper-based systems are securely locked away when not in use.

We provide training to staff who handle personal information and treat it as a disciplinary matter if they misuse or do not look after your personal information properly.

We will dispose of paper records or delete any electronic personal information in a secure way.

 

International Transfers

In general, Cireco (Scotland) does not transfer personal data outside the UK; however, we may process your information overseas on occasion, such as when using web services that are hosted outside the UK but only when we are satisfied that both the party which handles the data and the country it is processing it in, provide adequate safeguards for personal privacy.

Your rights

You have a number of rights in relation to your personal data:

You have the right to object to Cireco (Scotland) processing your personal data where we are performing a task in the public interest/exercise of official authority or under our legitimate interests.

We try to ensure that any information we hold about you is correct. There may be situations where you find the information we hold is no longer accurate and you have the right to request that this is corrected.

You have the right to request that Cireco (Scotland) stop processing your personal data in relation to any service, or when you have requested a correction to your personal data, or you have objected to processing.  However, this may cause delays or prevent us delivering a service to you.  Where possible we will seek to comply with your request, but we may be required to continue to hold or process your information to comply with a legal requirement.

You have the right to request Cireco (Scotland) to erase (destroy) any personal data we hold about you.  However, if we have a legal purpose for continuing to process your data, we may be unable to comply with your request.

If we have asked for your consent in order to process your personal data, you can withdraw this consent in whole or in part at any time.

You are legally entitled to request access to any information about you that we hold, and a copy. This is known as a subject access request.  Further information can be found here, where a request can be made on-line, or email information.requests@fife.gov.uk   Alternatively, you can write to Information Management & Request Team, Fife Council, Fife House, Glenrothes, Fife, KY7 5HX.  Fife Council will process your request on behalf of Cireco (Scotland).

 

Complaints

We seek to directly resolve any queries or complaints about how we handle information and would request that they be directed, in the first instance, to FRSData.Protection@cirecoscotland.co.uk

Our Data Protection Officer is provided by RGDP LLP and can be contacted either via 0131 222 3239 or info@rgdp.co.uk

You also have the right to complain to the Information Commissioner’s Office in relation to our use of your information.  The Information Commissioner’s contact details are noted below:

Telephone: 0303 123 1113

Online: Make a complaint ICO

 

Changes to this privacy notice

We will continually review and update this privacy notice to reflect changes in our services and feedback from service users, as well as to comply with changes in the law.