We collect and process personal data relating to our harbour users in order to manage the harbour license relationship we may have with you or to provide services to you as a harbour user. We are committed to being transparent about how we collect and use that data in order to meet data protection obligations.

 

What information do we collect?

We collect and process a range of information about you. This includes:

 

• Your full name,
• Date of birth,
• Contact details (phone, e-mail or correspondence address),
• Particulars of your vessel
• Details of anyone authorised to act on your behalf, if applicable,
• Payment information including credit card details if you pay by card (however card details are not stored),
• Other personal information that will vary on a case by case basis to help us resolve breach of license, alleged anti-social behaviour or fraud,
• Your image or vehicle details if captured on one of our CCTV cameras.

 

The information we may collect from you includes:

 

• To evidence that you meet the eligibility criteria for a mooring we require proof of boat ownership and proof of local residency. This will include documents which contain your personal details such as a driving licence, council tax, utility bill, boat insurance policy or bill of sale.

 

How do we collect information from you?

We may collect this information in a variety of ways:

 

• From you telling us verbally when you agree to take a service or mooring with us.
• From you completing and/or providing documentation when you agree to take a service or mooring with us. This may be in paper or electronic format.
• From you when you contact us with an enquiry or in response to a communication from us.
• If you or your vehicle passes within the field of view of one of our cameras.

 

We may also receive information about you from third parties including:

 

• Other harbours you may have visited but have left with fees outstanding,
• If you are a passenger or crew on a ship which we have been asked to provide pilotage for in our waters we may receive a copy of the ship’s manifest including passenger/crew information from your ship or ship’s agent.

 

Data will be stored in a range of different places, including in your mooring file, on our harbour management system and in other IT systems (including email).

 

Why do we collect it?

We need to process data to enter into a license agreement with you and to meet our obligations and exercise our rights under that agreement. For example we need to process your data where you agree to enter into a contract or take a product or service from us such as an annual or temporary mooring licence; a visitor mooring, long term licences or leases of buildings or property, pilotage and miscellaneous services.

 

In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, any authorised activity in our capacity as Statutory Harbour Authority such as the investigation and recording of incidents or accidents, and prosecution of offences committed under harbour legislation.

 

Other processing of your personal data is necessary for our ‘legitimate interests’, including reuniting passengers/crew with their ships, contacting you about an incident involving your vessel or protecting our property and staff.

 

How do we use your information?

The information we require from you is used to manage your licence agreement or other contract between you and us, or to provide a service to you as a harbour user.

We process your personal data in order to:

• Identify you when you contact us;
• Internal record keeping;
• Identify if you meet our eligibility criteria (where applicable) for taking products or services we provide;
• To administer and contact you about accounts and records related to your application to take products or services we have provided before, or provide now or in the future;
• Help to prevent and detect fraud or loss;
• For maintaining the security of our property and premises and for preventing and investigating crime;
• To contact you about an incident or accident in the harbour that you were directly involved in or have witnessed;
• Where you give us information on behalf of someone else (for example if a boat is in shared ownership), you confirm that you have provided them with the information set out in this privacy notice, and that they agree to the uses of their personal information described in it;
• To reunite you with your ship if you come on shore without your security pass.
• Comply with relevant legislation and regulation.

 

Who do we pass it to?

We may need to share personal information with government departments and agencies, with our regulator, auditors and debt collectors, or with other organisations and agencies where we are legally allowed to do so.

We also share your data with third parties that process data on our behalf such as for the provision of IT systems and services. This includes:

• Our harbour management system to record and manage harbour activities including the management of products and services we provide. This includes processing of payments for products and services we provide including online purchases and recording of incidents and accidents occurring in the harbour,
• Credit and debit card processing,
• Standing order or BAC’s processing.
• Email communications.
• Offsite back up of information at secure data centres in the UK.

 

How do we protect your data?

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

 

How long do we keep it?

We hold personal data for as long as is necessary to provide products or services, complete transactions that you have taken or requested, and for other essential purposes such as complying with our legal obligations, and resolving disputes and enforcing our agreements.

If you license a mooring from us we will hold your personal data for the duration of your licence. After the end of your licence period your data will be kept for a further 6 years in accordance with The Limitation Act 1980 and then confidentially destroyed. Some of your personal data for example your name and the type of license(s) you may have held with us may be transferred to our archive for historical reference.

If you are a visitor or passenger/crew on a ship we provide pilotage for we will hold your data for the duration of your visit and then destroy it unless you tell us you are happy for us to keep your information for future visits.

Images captured by CCTV will be kept for a period of up to 28 days whilst they are pending review or further investigation. On occasion there may be a need to keep images for longer, for example where a crime is being investigated. In such instances images may be kept for a period of up to 3 years.

 

What are my rights?

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;
• ask us to change incorrect or incomplete data;
• ask us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
• object to the processing of your data where we are relying on our legitimate interests as the legal ground for processing,
• to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that data to another data controller; and
• where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal.

 

Please note that none of these rights are absolute and we may be entitled to refuse requests where exemptions apply.

 

What if you do not provide personal data?

If you do not provide the information we need then we may not be able to provide all our services to you, and ultimately you may not be able to hold a mooring license or dock with us.

 

Automated decision-making

Our license decisions are never based solely on automated decision-making.

 

Contact information and further advice

The Secretary and Keeper of Records of the Duchy of Cornwall is the registered Data Controller.

If you would like to contact us please do so via one of the methods below:

The Data Protection Administrator, Duchy of Cornwall, 10 Buckingham Gate, London. SW1E 6LA

 

If you have concerns about the use of your personal data, the Information Commissioners Office is an independent body set up to uphold information rights in the UK. They can be contacted through their website: www.ico.org.uk, or their helpline on 0303 123 1113, or in writing to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF