Bypass to Killaloe New Shannon Bridge Crossing & R494 Upgrade, Drone & Time Lapse Camera Usage Clare County Council Privacy Statement March 2023

1.0 Introduction

This privacy statement concerns the use of time lapse cameras within the bridge construction site, and use of a drone, monthly, in connection with surveying the Killaloe Bypass, New Shannon Bridge Crossing & R494 Upgrade project. Further, it concerns the making available of the visual survey results (footage, photography) to the public, via the Council’s website. 

2.0 The Personal Data involved

Personal data processed by Clare County Council’s use of a drone and time lapse cameras may consist of the following:

• Images of construction workers passing the timelapse cameras;
• Indirectly identifiable personal data, such as private properties;
• Indirectly identifiable personal data, such as vehicle registration numbers; 

The control measures being implemented will ensure that personal data is not in fact involved. Directly and indirectly identifiable personal data will eliminated through a variety of measures, such that data is anonymised and no individual will be able to be identified. Footage and photographs used by the Council for progress reporting will not include directly or indirectly identifiable personal data. 

3.0 The Legal Basis

The legal basis for the Council’s monthly use of a drone, and two time-lapse cameras within the construction site is provided by article 6(1)e of the GDPR, namely:

• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of an official authority vested in Clare County Council, in this case, the construction of a new bridge and road under the Roads Act 1993.
• The provision of access to the progress survey results via the Council’s website, is based also on article 6(1)(e) - the processing is necessary for the performance of a task carried out in the public interest or in the exercise of an official authority vested in Clare County Council, namely facilitating and promoting interest in local government and civil affairs generally, under the Local Government Act, 2001. 

4.0 The purposes of the processing

The purposes of the processing are:

1. To survey & visually show monthly progress on the construction project;
2. To survey & visually show progress on the building of the new bridge over time;
3. Placement of the progress footage/photography/videography on the Council’s website so that the public can see the progress.
4. Show the start to finish progress on the construction project via a PR video after the project is substantially completed.  

5.0 The processing involved

Two time lapse cameras directed at the east and west abutment construction points of the new bridge and within the construction site will take a photo from a height every 6 minutes but between camera height and personal protective equipment worn by workers, identifiable images of individuals will not be involved.  Once a month, on the first Tuesday or Wednesday of each month (weather permitting), Shannon Images Ltd will overfly a drone to survey the construction site and record footage/photographs of progress. Shannon Images Ltd will supply footage and photographs to the Council’s project team. Footage and photographs from the visual survey will be put on the Council’s website so that the community can visually see progress on the construction site.

No directly identifiable personal data is involved, due to various control measures, such as altitude, angles of photography, flight plan of drone.  

6.0 Recipients

A time lapse camera and drone service provider is engaged under contract, namely Shannon Images Ltd. A data processing agreement is in place. Access to footage from the time lapse cameras will be restricted to a small number of authorised persons in the project team. Anonymised footage and photographs will be received from the processor and made available on the Council’s website for the community to be able to see the progress as the construction of the new road and bridge advances. 

7.0 Records Retention Policy

Footage will be retained by the processor until one month after the official opening of the new bridge.  The Council implements the national retention policy for local authority records. 

8.0 Data Subject Rights

You have the right to request access to personal data held about you, rights of rectification and erasure, rights of restriction and objection and rights of portability. To exercise these rights please see details in the attached link and the sample application forms on our website https://www.clarecoco.ie/your-council/governance/data-protection/ (or available on request from the Data Protection office, see contact details above).

To exercise these rights or if you have any questions on data protection compliance, you should contact Clare County Council Data Protection Officer at the following address:

Data Protection Officer, Clare County Council, Áras Contae an Chláir, New Road, Ennis, Clare V95 DXP2, Telephone number: (065) 6846405 or email: dpa@clarecoco.ie.

9.0 Right of complaint to the Office of the Data Protection Commissioner

If you are not satisfied with the outcome of the response you received from Clare County Council in relation to your request or in relation to exercising your data rights, then you are entitled to make a complaint to the Data Protection Commissioner who can investigate the matter for you.

The Data Protection Commissioner’s website is: www.dataprotection.ie.

Contact number: (01) 7650100 or 1800437737 . Email: info@dataprotection.ie. Postal address: Data Protection Commissioner, Canal House, Station Road, Portarlington, Co Laois, R32 AP23.  

10.0: Further Information

Further information and advice on the operation of this privacy statement is available from the Data Protection Officer, Clare County Council. Contact details are as follows:

Phone:065 – 6846405.      E-mail: dpa@clarecoco.ie. Website: www.clarecoco.i.e. Clare County Council, New Road, Ennis, Co Clare.

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