Tourism Promotion and Development Use of a Drone Privacy Notice

1.0 The Personal Data involved

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

• Directly identifiable images of persons;
• 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 identifiable personal data will be eliminated through a variety of measures, such that data is anonymised and no individual will be able to be identified.

2.0 The Legal Basis

The legal basis for the Council’s use of a drone in connection with aerial photography and videography to promote the county as a tourism destination 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 official authority vested in the controller. The official authority in this case is provided by the Council’s tourism and economic development functions under the Local Government Act 2001 (as amended and updated by the Local Government Reform Act 2014).

Section 63(1)(d) – the functions of a local authority are “to take such action as it considers necessary or desirable to promote the community interest in accordance with section 66..”

Section 66 (3) – a local authority may take measures and activities “deemed to promote the interests of the local community if it promotes, directly or indirectly, (ii) the general development, including enterprise and economic development of the administrative are of the local authority concerned..” Section 66(4)(e) - a local authority may “provide any service or other thing or engage in any activity that, in the opinion of the authority, is likely to benefit the local community..”

Section 67(1) - “In accordance with and subject to section 66, a local authority may take such measures, engage in such activities, or do such things…as it considers necessary or desirable to promote the interests of the local community in relation to the matters indicated”. The matters indicated include general recreational and leisure activities, general environmental and heritage protection and improvement, the public use of amenities, both natural and made or altered by human intervention.

Further, the Council relies for this processing on the public interest and official authority as set out in the delivery of the targeted actions of various plans (e.g. the County Clare Tourism Strategy 2030, the Clare Rural Development Strategy, Clare Local and Economic and Community Plan and Clare County Development Plan 2017-2023 (as amended).

3.0 The purposes of the processing

The purpose of the processing is to promote county Clare as a tourism destination and for tourism development purposes.

4.0 The processing involved

For the duration of 1 or 2 days during the months of April, May and September 2023 – Big Wheel Marketing will overfly a drone to supply footage and photographs to the Council’s tourism department. On 8 to 10 days during May and June 2023, AirSwing Media, t/a AirSwing Ltd. Will overfly a drone at tourist attractions to supply footage and photographs to the Council's tourism department. 

Footage and photographs will be produced into videos and placed on the Council’s website and distributed within the domestic and international tourism trade, so as to promote the county’s tourism economy.

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

5.0 Recipients

Drone service providers are engaged under contract, namely Big Wheel Marketing Ltd and Air Swing Media, t/a Air Swing Ltd. A data processing agreement with each provider is in place. Footage and photographs will be received from the processor and made available on the Council’s website and to domestic and international tourism partners, by way of promoting the county. The full privacy notice of the tourism department of the Council is available on www.visitclare.ie.

6.0 Records Retention Policy

Footage will be retained by the processor until one month after the final editing of the promotional video. Footage will be retained by the Council as a tourism asset, and reviewed every 10 years to assess whether it is still of sufficient quality to use. If deemed out-of-date, it will be deleted, otherwise it will be retained. 

7.0 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 Data protection | Governance and compliance | Council | Clare County Council (clarecoco.ie) (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.

8.0 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.

9.0 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.ie. Clare County Council, New Road, Ennis, Co Clare.

Page last reviewed: 26/06/23

Content managed by: Tourism

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