We have responsibility for the management and operation of over 720 hectares of parks, formal and informal open spaces, playgrounds, allotments and lakes and marshes.
Most of the personal information we hold about you is provided by you.
Processing activity – personal information we process may include:
- enquiries and complaints on matters such as property damage, anti social behaviour or other concerns
- the provision of information about the management and maintenance of our sites
- the management of bookings for sports, activities and events
- the management of contracts, leases and agreements relating to facilities, catering, allotments and other concessions
- responses to volunteering enquiries and management of our volunteers
- administration of the allotments service database and supporting systems
- allotment plot rental payments
- allotment tenancy renewal and/or rent information
- general correspondence between you and us
Information requirements - our processing activities may include:
- your address, telephone number, email address
- recording the payment of fees (excluding bank/credit card details)
Lawful bases[1] - our lawful bases for processing your personal information are:
- UK GDPR Article 6(1)(d) - our legal obligation(s) under the Open Spaces Act 1906 (acquisition and maintenance)
- UK GDPR Article 6(1)(d) - our legal obligation(s) under the Allotments Acts 1922-1950
- UK GDPR Article 6(1)(d) - our legal obligation(s) under the Dogs (Fouling of Land) Act 1996 – Borough Of Dartford Dogs (Fouling Of Land) Order 1998 (fixed penalty notices)
- UK GDPR Article 6(1)(d) - our legal obligation(s) under the Refuse Disposal (Amenity) Act 1978 (removal of vehicles)
- UK GDPR Article 6(1)(d) - - our legal obligation(s) under the Local Government (Miscellaneous Provisions) Act 1976 (dangerous trees)
- UK GDPR Article 6(1)(e) & DPA 2018 section 8(c) - necessary for the performance of a task in the public interest or in the exercise of official authority vested in us under the above legislation
Some of the information that is collected and shared is classified as
- special category personal data e.g. health - where processing is necessary for the reasons of substantial public interest (UK GDPR Article 9(2)(g) and DPA 2018, Schedule 1, para.6(1) & (2)(a));
- criminal convictions and offences (including alleged offences) -where processing is necessary for reasons of substantial public interest (UK GDPR Article 10 as supplemented by DPA 2018 section 10(5) & Schedule 1, Part 2, paras. 6(1) and (2)(a)).
We have a Data Protection Policy that sets out how this information will be handled.
Data sharing – your information may be shared with the relevant service department. We may also share your information with a number of other organisations for example with courts and the Ombudsman (where you have complained to the Ombudsman and we are asked to investigate your complaint). We may share your information with elected Councillors and/or Member of Parliament where you have asked them to represent you.
We outsource to external service providers the maintenance of our parks and open spaces. These external service providers are our data processors and only permitted to process your personal information in accordance with our written instructions.
We may rely on a number of exemptions, which allow us to share information without needing to comply with all the rights and obligations under the Data Protection Act 2018. Please refer to the Kent & Medway Information Agreement for further details on our sharing arrangements.
Retention period – we keep you personal information for the minimum period necessary. The information outlined in this Privacy Notice will be kept in accordance with the retention periods referred to in our Parks & Open Spaces Information Asset Register. All information will be held securely and disposed of confidentially.
Right to object – where processing your personal information is required for the performance of a public interest task (see our lawful bases above), you have the right to object on ‘grounds relating to your particular situation’. We will have to demonstrate why it is appropriate for us to continue to use your personal data.
Changes to this Privacy Notice – we review this Privacy Notice regularly and will place updates on our website.
For further details of how we process your personal information and for details on your additional rights, please refer to our Corporate Privacy Notice.
[1] Note that we may process your personal information on more than one lawful basis depending on the specific purpose for which we are using your information