A local authority collects their residents’ waste. On their website, they publish information relating to collections. This service allows you to enter an address and find out:
> When the waste collection is due
> When the last collection was completed
> If the last collection was missed and why (e.g. the bin was not presented at the curbside)
Does this information fall under the definition of personal data?
HellenB
Looking at this in a granular fashion:
> When the waste collection is due
No. This is service level information and applies equally to all households in the area regardless of the address searched.
> When the last collection was completed
Depends. If this is service level information, i.e. the service operated as normal in the area as opposed to being disrupted by weather etc. then No. However, if it is data that pertains to a specific property then Yes.
> If the last collection was missed and why (e.g. the bin was not presented at the curbside)
Yes. This identifies the specific actions of a specific household. The householder would not have an expectation that their information was being processed in this manner. The council cannot use legitimate interests to justify publication of this information and it is unlikely that they have collected consent to do so.
Simon
Yes, it can be used to indirectly identify someone by combining it with other data. If I were the LA I would only be publishing aggregate statistical data rather than individual household data.