Information about your Personal Data
Your privacy is important to us. This Privacy Notice explains how Greater Manchester Police Drone Unit known as Op Pathfinder processes personal data. It also outlines the steps we take to ensure that personal data is protected and describes the rights individuals have in relation to the data we process.
Personal data is any data that can be used to identify a living individual, on its own or in combination with other available information. References to names, identification numbers and location data would all be personal data. Processing means anything we do with the data and includes collecting, storing, and sharing.
What we need:
The Chief Constable of Greater Manchester Police is the controller for any personal data processed by GMP.
Op Pathfinder collects personal data through the use of an Aerial Platform (drone) fitted with a High Definition zoom camera and a Thermal camera, in the course of the exercise of its statutory Law Enforcement functions.
The drones will be proactively used to help target criminals in areas where we see a rise in crime reports. We will also continue to deploy the drones to major crime scenes and to help monitor pre-planned and spontaneous events. In general terms, deployment may be deemed to be necessary at the following types of incident:
- Serious incidents, including firearms incidents
- Public Order including lawful protests
- Serious road traffic collisions
- High Risk Missing from Home
- Serious Assaults and Murder investigations
- Violent Offenders
- Thieves on to premises
- Major Incidents
- Anti-Social Behaviour i.e. Off –Road Motorcycles or incidents on the Metrolink
- Contingency Planning
Such recording or taking of photographs will only be necessary in the pursuit of a legitimate aim – such as the prevention, investigation and detection of crime, with the necessity test being satisfied by the presence of a pressing social need.
The personal data we collect and use will include imagery that will identify a person, their clothing and their actions. Video footage will also identify their movements. Types of personal data we process may include information such as identifying features, actions, vehicles driven, interactions with other people and property.
When our operators are using the drones, they will record footage of each flight. The drones will only record footage when they are at a location of interest, and the camera on the craft will capture scenes that are of importance to the policing operation in question. The recording of all other scenes involving members of the public, property, buildings and vehicles will be kept to a minimum, although it is recognized that some imagery will be captured as a by-product of the investigation being conducted. GMP will only retain relevant footage, and will adhere to strict retention schedules.
Why we need it:
Operational Pathfinder processes personal data for law enforcement purposes as outlined in Part 3 of The Data Protection Act 2018 which are the purposes of the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security. We also process data for the purposes of safeguarding National Security.
The legal basis for processing law enforcement data is that it is necessary for the performance of functions. Operation Pathfinder's functions are established in the main under the Police and Criminal Evidence Act 1984 and the Police Act 1996, The Police Reform Act 2002 and include any powers or duties conferred by an enactment, and include:
- protecting life and property
- preserving order
- prevention and the detection of crime
- bringing offenders to justice
- any duty or responsibility arising from common or statute law
- We will only use personal information when the law allows us to and where it is necessary and proportionate to do so.
The information that we process may sometimes be considered to be sensitive. In these cases, we would be relying on one or more of the conditions for sensitive processing under part 3 of the Data Protection Act 2018. These include processing for statutory purposes (necessary due to an enactment or rule of law) or for the protection an individual’s vital interests (Schedule 8(1) and (3), DPA 2018).
Asking for your consent to process personal data
Occasionally Operation Pathfinder may ask for your explicit consent in order to lawfully process your data. This will only happen in specific and limited circumstances and won’t usually be relevant to law enforcement data. When we do require consent, we will explain clearly what we are asking for and how we will use it. Consent must be freely given, specific and informed and there must be a genuine choice about offering your data. Where we are processing data based on your consent, you have the right to withdraw that consent at any time.
When we ask for your consent, we will specify why we want your data, and what we are going to do with it, how long we will keep it for and the steps we will take to delete it. We will also explain how you can withdraw consent.
What we do with it:
All the personal data we process is processed by our staff in the UK for the purposes outlined above however for the purposes of IT hosting and maintenance this information is located on servers within the European Union. No third parties have access to your personal data unless the law allows them to do so.
We have a Data Protection regime in place to oversee the effective and secure
processing of your personal data. More information on this framework can be found on our website.
How long we keep it:
Any footage recorded by the drones that is deemed to be relevant to an investigation will be downloaded onto police systems when the craft lands. This will be stored with any associated information, and retained in line with that information; Records will be retained in accordance with the NPCC endorsed guidance on the Management of Police Information (MoPI) 2006, (this can be found on the College of Policing’s website www.app.college.police.uk) and the National Retention and Disposal Schedule, (this can be found on the National Police Chief’s Council website www.npcc.police.uk).
Where a recording is not deemed to be of use to policing, it will either be immediately deleted directly from the drone storage, or downloaded to police systems and not ‘marked’ for retention. Such footage will be automatically deleted within 90 days of download.
What we would also like to do with it
From time to time we may use the footage in training presentations, media engagement and other areas that may benefit our capability to deploy our drones and protect the communities of Greater Manchester. Where footage is used in this way, it will be assessed to ensure that no identifiable information can be seen.
Will this information be used to take automated decisions about you?
No. The information recovered, recorded and live streamed by the drones will only be used to make real time decisions by police and other emergency service commanders.
What are your rights?
GMP complies with all UK law as determined by the Civil Aviation Authority with regards to the use of the drones. As part of the governance of such aircraft, GMP has to obtain permission to fly from the CAA as any other commercial organisation. We also have to comply with strict rules to how and where the drone is flown in relation to other parties including people on the ground and other airspace users.
Under the Data Protection Act 2018 you have a number of rights that you can exercise in relation to the data we process about you. Under certain circumstances, by law you have the right to:
- request access to your personal information (commonly known as a right of access request). This enables you to receive a copy of the personal information we hold about you and check that we are lawfully processing it and that it is accurate
- request rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected
- request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no lawful reason for us to continue to process it
- request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we are allowed under the law to charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we can refuse to comply with the request in such circumstances.
We sometimes need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Further information about these rights can be found within the Data Protection Act 2018 and on the Information Commissioner’s Office website: www.ico.org.uk
To exercise any of these rights please contact the GMP:
The Information Compliance and Records Management Unit at: firstname.lastname@example.org, telephone: 0161 856 2529, or via post:Information Compliance and Records Management Unit,
Greater Manchester Police,
Information Services Branch,
Manchester, M11 2NS
Making a complaint about your personal data
You can complain directly to the Greater Manchester Police's Data Protection Officer via email or in writing to: -
Email: email@example.comData Protection Officer
Information Compliance and Records Management Unit
Greater Manchester Police
You also have the right to complain to the Information Commissioner’s Office using the following details:The Information Commissioner's Office
Cheshire SK9 5AF
Telephone: 08456 30 60 60 or 01625 54 57 45