Road Traffic Survey Active Travel Scheme Privacy Notice

1.0 Purpose of the short term localised cameras

Personal data may be processed as part of the localised and short term traffic camera installation in order to identify turning movement counts at 6 no. key junctions in relation to the new proposed Active Travel Scheme on the Limerick Rd Ennis. The counts will be of vehicles, pedestrians and cyclists. The cameras will operate at a resolution such that identifiable images will not be recorded, so personal data is not being gathered in the survey. In the event that any personal data is processed through the cameras, the Council is obliged to protect it in accordance with the Data Protection Act 2018 and the provisions contained in the General Data Protection Regulation (GDPR). The purpose of the processing of personal data under this project is to:

Create data about traffic volumes and turning patterns at 6 no. junctions to:

• generate anonymised traffic profile information to inform a detailed traffic model.
• The traffic model results will inform the correct design process to follow.
• The collection of road traffic survey data will inform the design which will lead to a scheme which will provide safer segregated pedestrian and cycling facilities 

Twelve traffic survey cameras will be installed at 6 no. junction locations (2 cameras at each junction) on the R458 Limerick Rd/ L-4506-0/R475/L-4508-0/L-4525-0 for a duration of 12 hours from 07:00-19:00. GPS coordinates for the camera locations are shown in the table below, as per the map attached below.

Survey Type	Ref	Coordinates
Video Junction Turning Counts (JTC) including pedestrian and cyclist movements.		Longitude (Degrees East)	Latitude (Degrees North)
	1	52.8142	-8.9649
	2	52.8288	-8.9791
	3	52.8328	-8.9810
	4	52.8313	-8.9922
	5	52.8305	-8.9961
	6	52.8330	-8.9917

2.0 Legal basis

The legal basis to process personal data in the case of the road traffic survey is the following:

• Article 6(1) e of the GDPR - 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. The official authority in this case derives from the Roads Act, 1993 - Section 13 - Responsibility of road authorities for the maintenance and construction of local roads and Section 78 - Powers of inspection & survey.
• The processing is necessary to comply with a legal obligation to which the Council is subject, namely, Health, Safety and Welfare at Work Acts.

3.0 The categories of personal data concerned

Personal data processed in the traffic survey is:

• Vehicles, cyclists and pedestrians. Images of vehicles, cyclists and pedestrians will be processed at a distance, angle and resolution that would prevent individuals from being identifiable. No ANPR being used for this survey.

4.0 Processing and recipients of the data

Access to the data is limited to the company engaged by Clare County Council to do the survey, who will record images of traffic (including pedestrian and cyclist traffic) such that individual persons are not identifiable. No personal data will provided to the Council and anonymised traffic movement data only will be provided to the Council.

Third party access to personal data is not allowed, except in the very limited circumstances permitted by law. Access requests shall be processed in accordance with the Data Protection Act 2018, the GDPR and the Council’s data protection policies and procedures.

There are no plans to transfer the personal data to a third country or international organisation.

5.0 The retention period for the data

Clare County Council subscribes to the national policy for retention and destruction of Local Authority records.

6.0 Data subjects have a range of data rights

• Right of access by the data subject
• Right to rectification
• Right to erasure (‘right to be forgotten’)
• Right to restriction of processing
• Right to data portability
• Right to object and automated individual decision-making

The Council’s data access request policy and procedures are available on www.clarecoco.ie or please contact dpa@clarecoco.ie.

7.0 The right to lodge a complaint with the supervisory authority

If you are not satisfied with a decision on your request for access to data or have concerns about personal data processing, you have the right to make a complaint to the Data Protection Commission, Canal House, Station Road, Portarlington, Co. Laois, Ireland. Before doing so it is recommended that you contact Clare County Council (DPA@clarecoco.ie) to establish the circumstances. We may be in a position to resolve the problem in a timely manner. 

The Data Protection Commission website www.dataprotection.ie has further details and the forms that are required to be completed if you wish to raise a concern or make a complaint.

8.0 Contact details for the data controller and data protection officer

The identity and the contact details of the controller:

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

Telephone: (065) 6821616
Email: roads@clarecoco.ie

The contact details of the data protection officer:

Data Protection Office,
Clare County Council,
New Road,
Ennis,
Co. Clare

Telephone: (065) 6846405
Email: DPA@clarecoco.ie

Page last reviewed: 28/11/23

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