Devon County Council (DCC) is collecting and or processing your personal data as a data controller under Data Protection Legislation and our ICO registration number is Z6475582. This privacy notice concerns the processing of personal data that takes place when you use the Council’s public wifi service.
This notice explains what information we collect, why we collect it and how we keep it secure. It also explains your rights and our legal obligation. Should you wish to find out more about Devon County Council’s data protection policies please contact our Data Protection Officer.
We will notify you of any changes to this privacy notice
This privacy notice was last updated on 23 August 2021. If we use your personal data for any new purposes, updates will be made to the policy information and changes communicated where necessary, in accordance with current data protection legislation. For any queries relating to this privacy notice please contact the Data Protection Officer.
What information are we processing?
We may collect, store or otherwise process information about you which may include:
- your name
- your telephone number (to deliver an access code to you)
- the IP address (network address) of your device
- the details of websites and internet services that you use whilst connected to our public wifi service
- details of your authentication to the service, activation dates and last login dates
Purpose of collecting or processing your personal data
DCC may need to collect or otherwise process your personal data so that we can provide staff and visitors to our buildings with a safe and secure public wifi service.
The legal basis for us collecting your personal data
Where we are collecting personal data about you for the provision of one of the purposes outlined in this privacy notice, we rely upon Article 6(1)(a) – consent.
Personal data that is collected for any of the purposes outlined in this notice is never used for direct marketing purposes and is not sold on to any other third parties.
Recipients or categories of recipients that we may share your personal data with
When processing your personal data, it may be necessary for us to share personal data with third-party organisations such as the Government Digital Service (GDS) where you choose to use GovWiFi to connect to our wifi service.
If we feel that it is necessary to share your personal data with professionals to ensure you or someone you work with is safeguarded from harm, we rely upon the provisions of the Safeguarding Vulnerable Groups Act 2006 and Children Act 1989 & 2004.
Where it is necessary to share medical or social care information for these purposes, we rely upon article 9(2)(h) of the General Data Protection Regulation (information necessary for medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems).
We may also need to share some personal data about you so that we can support third-party organisations to discharge their regulatory requirements. This includes organisations such as:
- The Data Protection Regulator (the Information Commissioner’s Office)
- The Care Quality Commission
- The police (in the unlikely event of an investigation identifying that our public wifi service may have been used for the purpose of criminal activity).
We may also share information to enable us to comply with court orders and other legal obligations. If this is necessary, we will only share the minimum amount of personal data needed for this purpose.
Your information will not be transferred outside of the UK for the purposes of processing as described in this privacy notice.
How long will we hold your personal data?
Devon County Council will retain your personal data for a maximum of 90 days from the last date your device connected to the public wifi service.
Your data protection rights
Under Data Protection Legislation, you have the right to obtain a copy of their personal records held by us, this is called a subject access request (SAR). Details of how to make an SAR can be found here.
If you have any comments, queries or complaints about this privacy notice or the processing of your personal data please contact our Data Protection Officer.
Alternatively, if you are not happy with the way that DCC is handling your personal data, you are entitled to appeal to the Information Commissioners Office (ICO). The Information Commissioners Office enforces and oversees the Data Protection Regulations.
Contact details are below:
Information Commissioner’s Office