Operation PING: Detection of fleet drivers’ unsafe driving - privacy notice
This privacy notice sits beneath our top level privacy notice and provides information about how personal data is used with regards to Operation PING.
Who are the data subjects?
The project involves the collection of information about fleet drivers employed by participating fleet operators.
What personal data is collected, and how?
Specially designed pieces of detection equipment are mounted on vans and trailers along certain sections of our motorways. The equipment or “camera” has a specially designed “sensor” which detects and collects images of “unsafe driving practices” from inside the fleet vehicles of participating fleet operators.
The equipment also captures the time and date of detection, and images of the vehicle registration.
For the purposes of this operation, the “unsafe driving practices” are:
- the use of handheld mobile devices while at the wheel; and/or
- drivers and/or their passengers not wearing seat-belts.
We are focusing on these practices as they have been shown to be a key factor in the traffic incidents on our roads which result in serious injuries and deaths.
Images of drivers holding phones to their ears will include some or all of their faces.
We recognise that this is personal data which could be used by others to identify individual fleet drivers. However, this is not the purpose of National Highways’ collection of the data. We restrict access to the images described above to a limited number of expert technicians who have been trained to conduct a “human review” of the automatically collected images of potentially unsafe driving practices.
Who do we share the personal data with?
Our PING database stores the vehicle registrations of all participating fleet operators. The personal data described above will be shared only with the fleet operator which is matched with the vehicle registration detected. This means that the fleet drivers’ data will only be shared with their own employer.
What do we use the data for?
The unsafe driving practices described above are associated with incidents causing fatalities and serious injuries on our strategic roads network.
The overall purpose of Operation PING is to improve safety on our roads.
In particular our aims are:
- to expand our evidence base on the prevalence of unsafe driving practices, and our understanding of such behaviour on our roads
- to share data on such driving behaviour with the associated fleet operators so that they may identify and contact their offending drivers about this behaviour; and take action, as they see fit, in order to prevent and deter re-occurrence
- to facilitate fleet operators’ improved understanding of their drivers’ unsafe behaviours while on the road
- to enable comparative research and analysis of the effectiveness of different measures taken by Fleet operators to prevent and deter unsafe driving by their drivers. Such measures are likely to include contact and communications with those responsible for detected unsafe driving practices; improved and enhanced driver induction training; and review of content and effectiveness of their policies for fleet drivers.
What legally allows us to collect and handle information about you?
As a public authority, National Highways’ licence conditions state that it must "protect and improve the safety of the network".
Therefore, we can confirm that the processing of this personal data described in this notice is for the exercise of a public task.
This meets the lawful condition established by UK GDPR Article 6.1.(e)
How long will we keep the data?
In accordance with the UK GDPR principle of “storage limitation”, the data will be retained for no longer than is necessary for the purpose/s of processing specified above. The data retained shall be the minimum necessary for the specified purpose. It shall be securely destroyed after the end of the retention period.
Any driver images picked up by our sensors which are not matched with vehicle registrations from our PING database are automatically and immediately deleted and destroyed.
All driver images collected automatically by our sensors are reviewed by specially trained staff who will judge whether the images constitute evidence of “unsafe driver behaviour”. Images which are rejected in this human review process are automatically and immediately deleted and destroyed.
Driver images which are confirmed as evidence of unsafe driving, and sent to the relevant fleet operator, will be held by National Highways for up to one year in order that they may contribute to our research purposes. Neither facial images nor vehicle registrations will be used by National Highways to identify or contact individual fleet drivers. Nor will they be used to take decisions which could directly impact individual fleet drivers.
What rights do you have as a data subject?
Data subjects are the individuals whose personal data is being processed. In this case the data subjects are the fleet drivers employed by fleet operators participating in operation PING.
If you are a data subject you have the right to be informed about the way we are using your data and for what purposes. This is the purpose of this privacy notice.
You also have the right to request the exercise of the following data subject rights:
- to access your personal data
- to rectify your personal data
- to restrict our processing of your personal data
National Highways would advise data subjects wishing to exercise any of these rights to, in the first instance, contact the data protection officer of the fleet operation they are employed by. This is because only your employer can identify your name with the information in question (i.e. facial images and vehicle registration).
For any questions about this privacy notice you may email our Data Protection Officer.
