Privacy policy - general

Repsonsible information recording

When carrying out any inspection, it is sometimes possible to inadvertently capture personal information. This is known as  ‘collateral intrusion'. 

This is a particular issue with drones, due to the height they operate and the need to capture a large angle photo. 

Our commitment:

We have considered whether there is a genuine need for us to use a drone, if alternative systems or methods of surveillance are not suitable to solve a particular problem.

Our justification

Drones allow inspection of locations which would otherwise require work at height. The provision of work at height systems (scaffoldings, MEWPs) can present more risk to the inspector, be cumbersome and be expensive, compared to the use of a drone. As a rule, the use of video capture will not be used. This will limit the chance the operator has of inadvertently capturing personal information. The operator will need to consider the framing of the photo image before capturing it an saving it. 

We have conducted a Data Protection Impact Assessment (DPIA) which includes the risks associated with recording at altitude, and capturing footage of individuals that are not intended to be the focus of our surveillance.

We have registered our drone with the Civil Aviation Authority (CAA).

We have robust policies and procedures in place for the use of drones, and our operators are appropriately trained, with documented credentials.

We inform individuals that we are using a drone where possible, and we have an accessible privacy notice that individuals can read to learn more about our use. Clients will also know in advance whether a drone is to be used. We will advise they inform neighbours and to let Smartdale know if there are objections or additional measures (for example, a representative to be present during the inspection) to be put in place.