Regional Refuse Disposal District # 1

Privacy Policy

Regional Refuse Disposal District #1 (RRDD1)
Effective Date: May 1, 2026

Regional Refuse Disposal District #1 (“RRDD1,” “we,” “our,” or “us”) is committed to protecting the privacy of visitors to this website, regionalrefusedistrict1ct.gov (also reachable at RRDD1.com, which forwards here). This Privacy Policy explains what information we collect, how we use it, and your rights when using our website.

Information We Collect

Information Collected Automatically

When you visit this website, certain non-personal information may be collected automatically by our web server or website hosting provider. This information may include:

Internet Protocol (IP) address
Browser type and version
Operating system
Date and time of your visit
Pages viewed
Referring website
General geographic location based on IP address
Device type

This information is used only to improve website performance, monitor security, diagnose technical issues, and better understand how visitors use our website.

Information You Voluntarily Provide

You may voluntarily provide personal information when you:

Send us an email
Submit permit requests

The information you provide may include:

Name
Email address
Telephone number
Mailing address
Business name (if applicable)
Any additional information you include in your communication

We collect only the information necessary to respond to your request or provide the requested service.

How We Use Your Information

Information collected through this website may be used to:

Respond to inquiries
Process requests
Improve customer service
Improve website functionality
Maintain website security
Comply with applicable federal, state, and local laws

RRDD1 does not sell, rent, or lease personal information to third parties.

Information Collected at Our Physical Location

In addition to information collected through this website, Regional Refuse Disposal District #1 may collect information from individuals who visit our transfer station or administrative office.

Information collected at our physical location may include:

Name, address, telephone number, and email address
Driver’s license or other government-issued identification to verify identity and residency
Vehicle registration or license plate information to verify residency and permit eligibility
Proof of residency, such as utility bills, tax bills, lease agreements, or other documentation, when required
Payment information for permits, disposal fees, or other services (payment card information is processed by secure third-party payment processors and is not retained by RRDD1 except as necessary for transaction records)
Photographs or video recordings captured by security cameras located on District property
Information related to customer accounts, permits, waste disposal transactions, and recycling services
Communications with District staff, including written correspondence and customer service inquiries

The information collected is used to:

Verify residency requirements for access to Regional Refuse Disposal District #1 facilities and services.
Confirm eligibility to purchase or renew residential and commercial permits.
Verify identity and prevent the unauthorized use or transfer of permits.
Process permit applications, payments, and waste disposal transactions.
Maintain accurate customer and financial records.
Protect the safety of employees, customers, and District property.
Prevent fraud, theft, vandalism, and misuse of District facilities.
Investigate accidents, incidents, or violations of District policies.
Comply with applicable federal, state, and local laws, regulations, and recordkeeping requirements.

Video surveillance is used solely for security, operational, and safety purposes. Recorded footage may be reviewed by authorized personnel and may be disclosed to law enforcement or other governmental agencies as required by law or as necessary to investigate incidents occurring on District property.

Records created during the normal course of District operations, including residency verification documents, permit records, transaction records, surveillance recordings, correspondence, and other documents, may constitute public records under the Connecticut Freedom of Information Act (FOIA) and may be subject to disclosure unless exempt under applicable law.

Public Records

As a Connecticut public entity, RRDD1 is subject to the Connecticut Freedom of Information Act (FOIA). Communications submitted to the District, including emails, may constitute public records and may be subject to disclosure unless exempt under applicable law. Visitors should avoid submitting confidential or sensitive personal information unless specifically requested.

To request records under the Connecticut Freedom of Information Act, email the Administrator at Administration@RRDD1.com, or write to the District office at the address listed at the end of this policy.

Cookies

This website may use cookies or similar technologies to improve website functionality and analyze website traffic.

Cookies do not provide us with personal information unless you voluntarily provide it.

You may disable cookies through your browser settings; however, some portions of the website may not function properly.

Third-Party Services

Our website may use third-party services for website hosting, analytics, mapping, payment processing, or other functions.

These providers may collect limited technical information necessary to perform their services. Their use of information is governed by their own privacy policies.

External Links

This website may contain links to other government agencies, municipalities, contractors, or external websites.

Once you leave this website, this Privacy Policy no longer applies. RRDD1 is not responsible for the privacy practices or content of external websites.

Website Security

RRDD1 employs reasonable administrative, technical, and physical safeguards designed to protect information submitted through this website.

While we strive to protect personal information, no method of electronic transmission or internet storage is completely secure. Therefore, we cannot guarantee absolute security.

Children’s Privacy

This website is not directed toward children under the age of 13. We do not knowingly collect personal information from children.

AUTOMATED LICENSE PLATE READER SYSTEM

USAGE AND PRIVACY POLICY

Effective Date: October 1, 2026
Adopted By: Board of Directors, Regional Refuse Disposal District No. 1
Responsible Official: District Administrator

SECTION 1 — PURPOSE

Regional Refuse Disposal District No. 1 (“RRDD1” or “District”) operates automated license plate reader (“ALPR”) technology at the RRDD1 Transfer Station for the limited purpose of assisting in the control of access to the District’s secured facility and administering authorized facility access.

RRDD1 currently utilizes two UniFi AI-LPR cameras integrated with the District’s UniFi Protect video-security system.

The primary purpose of the ALPR system is to identify the license plate of a vehicle approaching or entering the Transfer Station and compare that license plate against RRDD1’s authorized permit information to determine whether the vehicle is authorized to use the facility.

This policy establishes requirements for the collection, access, use, retention, disclosure, security and destruction of ALPR data.

This policy shall be interpreted and administered consistently with Connecticut Public Act 26-14, as amended, and all other applicable federal and Connecticut law.

SECTION 2 — AUTHORITY AND APPLICABLE LAW

RRDD1 recognizes that it is a public agency for purposes of Connecticut’s Freedom of Information Act, as applicable under Connecticut General Statutes § 1-200.

Connecticut Public Act 26-14 regulates the operation and use of automated license plate reader systems and automated license plate reader data by public agencies.

Beginning October 1, 2026, a public agency may operate an ALPR system or use ALPR data for specified purposes, including assisting in the control of access to a secured area.

RRDD1’s operation of ALPR technology is limited to the District’s authorized facility-access and permit-administration functions.

SECTION 3 — DEFINITIONS

3.1 Automated License Plate Reader System

“Automated License Plate Reader System” means a fixed or mobile electronic image-recording device that, in combination with computer programs or algorithms, converts images of license plates or vehicle descriptors into computer-readable data.

For purposes of this policy, RRDD1’s UniFi AI-LPR cameras constitute an automated license plate reader system.

3.2 Automated License Plate Reader Data

“Automated License Plate Reader Data” includes information captured, recorded, held, stored, processed or derived from the ALPR system, including, but not limited to:

License plate characters;
Vehicle still or video images captured by the ALPR system;
Vehicle attributes;
Location information;
Date and time information;
Metadata;
ALPR detection records;
Information derived from an ALPR detection; and
Other information that constitutes ALPR data under applicable Connecticut law.

3.3 Permit Database

“Permit Database” means RRDD1’s separate administrative records identifying vehicles or permit holders authorized to use the Transfer Station.

The Permit Database is maintained for facility administration and is separate from ALPR event data.

3.4 Authorized User

“Authorized User” means an RRDD1 employee or official who has been specifically authorized by the District Administrator to access the ALPR system or ALPR data as part of the person’s assigned duties.

SECTION 4 — AUTHORIZED PURPOSE

RRDD1 shall operate its ALPR system solely to assist in controlling access to the secured RRDD1 Transfer Station and administering authorized facility access.

Authorized functions include:

Reading license plates of vehicles approaching or entering designated RRDD1 access points;
Comparing a detected license plate with RRDD1’s authorized permit information;
Determining whether a vehicle appears to have a valid RRDD1 permit;
Identifying vehicles that appear to lack authorization to use the facility;
Assisting gatehouse personnel with permit verification;
Assisting RRDD1 in enforcing its lawful facility-access and permit requirements;
Protecting the security of RRDD1 employees, facilities, equipment and property; and
Documenting access-control events when otherwise permitted by law.

RRDD1 shall not operate the ALPR system for general surveillance or unrelated tracking of individuals or vehicles.

SECTION 5 — PROHIBITED USES

RRDD1 employees and officials shall not use ALPR technology or ALPR data:

For personal purposes;
To monitor or track an individual for personal reasons;
To investigate an individual’s private activities unrelated to RRDD1’s authorized functions;
To investigate suspected immigration violations or assist with civil or criminal immigration enforcement;
To investigate or prosecute an individual for seeking, receiving or providing reproductive health care services or gender-affirming health care services protected by Connecticut law;
For political purposes;
For harassment, retaliation, intimidation or discrimination;
To search for vehicles unrelated to a legitimate RRDD1 purpose;
To sell ALPR data;
To provide unrestricted access to ALPR data to another agency or person;
To participate in an ALPR data-sharing network unless expressly authorized by the District Administrator and permitted by Connecticut law; or
For any purpose prohibited by Connecticut or federal law.

SECTION 6 — PERMIT DATABASE

RRDD1 may maintain a separate database of authorized permit holders and authorized vehicle license plates for the purpose of administering Transfer Station access.

The Permit Database shall be maintained separately from historical ALPR event data whenever reasonably practicable.

Access to the Permit Database shall be limited to employees whose duties require access.

Employees shall use permit information only for legitimate RRDD1 business purposes.

RRDD1 shall establish reasonable procedures for:

Adding authorized vehicles;
Removing expired or revoked permits;
Correcting inaccurate license plate information;
Updating vehicle changes;
Handling duplicate or transferred permits;
Identifying expired permits; and
Documenting administrative changes to the permit database.

A license plate appearing in the Permit Database does not, by itself, authorize an employee to access historical ALPR information for unrelated purposes.

SECTION 7 — ALPR DATA RETENTION

Except where a longer retention period is specifically authorized by applicable Connecticut law, RRDD1 shall not retain ALPR data for more than twenty-one (21) days.

RRDD1 shall configure its UniFi Protect system so that ALPR data subject to the statutory 21-day limitation is automatically deleted or otherwise rendered inaccessible at the expiration of the applicable retention period.

The District Administrator shall periodically verify that the system’s retention settings remain consistent with this policy and applicable law.

7.1 Exceptions

ALPR data may be retained beyond twenty-one (21) days only when a specific statutory exception permits continued retention, including where applicable:

A judicial warrant or court order requires preservation;
The data is being retained pursuant to applicable court rules governing preservation of evidence;
The data constitutes evidence in an active criminal investigation or prosecution and the statutory requirements for such retention are satisfied; or
Another specific statutory exception authorizes retention.

When ALPR data is retained under a statutory exception, the District shall document:

The date of retention;
The specific legal authority for retention;
The purpose for retention;
The person authorizing retention;
The expected disposition date; and
The date the information is ultimately destroyed or otherwise lawfully disposed of.

SECTION 8 — ORDINARY VIDEO SURVEILLANCE

This policy governs ALPR data generated by RRDD1’s ALPR system.

Ordinary video recordings generated by cameras that do not function as an ALPR system may be governed by RRDD1’s separate video-surveillance retention policy and applicable law.

Where a UniFi camera produces both ordinary video and ALPR data, RRDD1 shall treat information that constitutes ALPR data under Connecticut law in accordance with the ALPR requirements of this policy.

SECTION 9 — EMPLOYEE ACCESS

Access to the ALPR system shall be based upon job responsibility and the principle of least privilege.

The District Administrator shall establish the list of employees authorized to access ALPR information.

At a minimum:

Each user shall have an individual account;
Shared user accounts shall not be permitted for administrative access;
Passwords shall not be shared;
Administrative privileges shall be limited to personnel who require them;
Former employees shall have access immediately revoked upon separation;
Employees transferred to duties not requiring access shall have unnecessary access removed;
Access shall be reviewed periodically; and
RRDD1 shall maintain appropriate system access logs.

The District Administrator may suspend an employee’s ALPR access pending investigation of suspected misuse.

SECTION 10 — ACCESS LOGGING AND AUDITING

RRDD1 shall maintain appropriate records of access to ALPR data when such logging is available through the UniFi Protect system or other system used by the District.

The District Administrator shall periodically review available access logs for unauthorized or unusual activity.

RRDD1 may conduct an audit of:

User access;
Searches of ALPR data;
Data exports;
Data disclosures;
System configuration;
Retention settings;
Administrative changes; and
Security incidents.

Audits shall be retained in accordance with applicable records-retention requirements.

ALPR data contained within audit records shall remain subject to the confidentiality requirements of Connecticut law.

SECTION 11 — FREEDOM OF INFORMATION ACT

ALPR data maintained by RRDD1 is confidential and shall not be treated as a public record subject to disclosure under Connecticut’s Freedom of Information Act to the extent provided by Connecticut Public Act 26-14.

RRDD1 shall not release ALPR data in response to an ordinary public-record request unless disclosure is specifically authorized or required by applicable law.

The following information may be subject to FOIA disclosure to the extent provided by law:

Locations of recording devices used as part of the ALPR system, except where a statutory exception applies; and
Certain non-ALPR information contained in audits, system usage logs and logs documenting access to ALPR data, provided ALPR data is redacted as required by law.

All FOIA requests seeking ALPR information shall be referred to the District Administrator or the District’s designated FOIA officer before any response is made.

No employee shall independently release ALPR information in response to a public-record request.

SECTION 12 — REQUESTS BY VEHICLE OWNERS

A person who seeks ALPR data concerning a motor vehicle registered in that person’s name shall be directed to the District Administrator.

RRDD1 shall process such requests in accordance with the applicable requirements of Connecticut Public Act 26-14 and other applicable law.

Where a vehicle is jointly registered, RRDD1 shall require the consent or participation required by applicable law before releasing ALPR data.

The District Administrator may require reasonable documentation establishing the requester’s identity and legal interest in the vehicle before releasing information.

SECTION 13 — LAW ENFORCEMENT REQUESTS

RRDD1 is not a law enforcement agency.

ALPR information shall not be routinely provided to law enforcement agencies.

Any request by a law enforcement agency for ALPR data shall be directed to the District Administrator.

RRDD1 shall release ALPR data to a law enforcement agency only when the disclosure is authorized by Connecticut law.

Depending upon the requesting agency and circumstances, this may require:

A documented case-specific request;
A written request identifying the specific investigation or lawful purpose;
A written declaration required by Connecticut law;
A judicially issued warrant or other court order; or
Another specific statutory authorization.

RRDD1 shall not provide law enforcement agencies with unrestricted, real-time, bulk or automatic access to its ALPR database unless expressly authorized by applicable Connecticut law.

RRDD1 shall not establish an automatic feed of ALPR data to a law enforcement agency.

All law enforcement requests and disclosures shall be documented.

The documentation shall include, when applicable:

Requesting agency;
Name and title of requesting officer;
Date and time of request;
Specific information requested;
Legal authority asserted;
Case or incident number, if applicable;
RRDD1 employee approving disclosure;
Date of disclosure; and
Information actually disclosed.

SECTION 14 — DATA SHARING

RRDD1 shall not participate in a multistate, statewide, regional or national ALPR data-sharing network without prior approval of the Board of Directors or District Administrator, as appropriate, and a determination that the proposed sharing complies with Connecticut law.

RRDD1 shall not permit another public agency to obtain unrestricted real-time, bulk or automatic access to RRDD1 ALPR data.

Any authorized sharing shall be documented and limited to the specific lawful purpose for which the information is being shared.

SECTION 15 — PRIVATE VENDORS AND CONTRACTORS

RRDD1 shall require any private vendor providing ALPR-related services to comply with Connecticut Public Act 26-14 and this policy.

Any contract involving ALPR system operation, ALPR data storage, processing, maintenance, hosting, support or access shall address, at a minimum:

The vendor shall not sell RRDD1 ALPR data;
The vendor shall not share or transfer RRDD1 ALPR data to a third party without RRDD1’s prior express written authorization for a specific purpose;
The vendor shall not use RRDD1 ALPR data for its own commercial purposes;
The vendor shall maintain appropriate security safeguards;
The vendor shall comply with RRDD1’s retention and deletion requirements;
The vendor shall promptly notify RRDD1 of any security incident involving ALPR data;
The vendor shall return or securely destroy ALPR data upon termination of services when legally permitted;
The vendor shall not establish independent access to RRDD1 ALPR data;
The vendor shall cooperate with RRDD1 audits and lawful investigations; and
The contract shall prevail over any conflicting vendor terms of service to the extent permitted by law.

No vendor agreement shall authorize a use or disclosure prohibited by Connecticut law.

SECTION 16 — UNIFI PROTECT CONFIGURATION

RRDD1 shall configure its UniFi Protect system to support this policy.

To the extent technically available, RRDD1 shall:

Enable individual user accounts;
Limit administrator privileges;
Enable multi-factor authentication where supported;
Maintain current UniFi OS, Protect application and camera firmware;
Configure ALPR retention consistent with the 21-day statutory requirement;
Disable unnecessary external sharing;
Limit remote access to authorized personnel;
Enable encryption features supported by the system;
Maintain appropriate network security controls;
Regularly review connected devices and user accounts;
Disable accounts no longer required; and
Periodically verify that ALPR data is being deleted in accordance with this policy.

UniFi states that Protect recordings are stored locally on the UniFi OS Console by default and that AI processing occurs locally rather than requiring the video stream to be sent to the cloud. RRDD1 shall nevertheless periodically verify its actual configuration, including remote access, backups, archiving and integrations, to ensure that the District’s configuration remains consistent with this policy.

SECTION 17 — DATA SECURITY

RRDD1 shall use reasonable administrative, technical and physical safeguards to protect ALPR information against unauthorized access, disclosure, alteration, copying, loss or destruction.

Security measures shall include, as appropriate:

Individual user credentials;
Role-based permissions;
Strong passwords;
Multi-factor authentication where available;
Network segmentation or other appropriate network controls;
Encryption where supported;
Physical security of the UniFi console and network equipment;
Protection of exported files;
Secure deletion;
Periodic access reviews;
Software and firmware updates; and
Incident-response procedures.

Employees shall not save ALPR data to personal computers, personal cloud-storage accounts, personal email accounts, removable media or personal devices except where specifically authorized for a legitimate RRDD1 purpose and consistent with applicable law.

SECTION 18 — EXPORTING ALPR DATA

Employees shall not export ALPR data from UniFi Protect unless the export is necessary for an authorized RRDD1 purpose.

When an export is authorized, the employee shall document:

The reason for the export;
The date of export;
The employee making the export;
The information exported;
Where the information is stored; and
The required destruction date.

Exported ALPR data remains subject to the same confidentiality and retention requirements as the original ALPR data.

Exporting ALPR data does not extend the statutory retention period.

SECTION 19 — INCIDENT RESPONSE

Any employee who becomes aware of unauthorized access, disclosure, copying, loss, theft or suspected compromise of ALPR data shall immediately notify the District Administrator.

The District Administrator shall:

Secure the affected system;
Determine the nature and scope of the incident;
Preserve appropriate evidence;
Determine whether unauthorized access occurred;
Document the incident;
Take corrective action;
Determine whether notification is required under applicable law; and
Consult legal counsel or appropriate governmental authorities when necessary.

SECTION 20 — EMPLOYEE RESPONSIBILITIES

All employees with access to the ALPR system shall receive instruction regarding:

The authorized purpose of the system;
Prohibited uses;
Confidentiality requirements;
FOIA requirements;
Law enforcement requests;
Data-retention requirements;
Data-security requirements;
Proper use of the permit database;
Unauthorized disclosure; and
Consequences of violating this policy.

Employees shall acknowledge in writing that they have received and understand this policy before receiving ALPR access.

SECTION 21 — DISCIPLINE FOR MISUSE

Unauthorized access, use, copying, disclosure or retention of ALPR information may result in disciplinary action, up to and including termination of employment, consistent with applicable law and RRDD1 policy.

Where appropriate, RRDD1 may refer suspected unlawful conduct to the appropriate law enforcement or governmental authority.

SECTION 22 — SYSTEM ADMINISTRATION

The District Administrator shall be responsible for the day-to-day administration of this policy.

The District Administrator shall maintain:

A current inventory of ALPR cameras;
A list of authorized users;
System access records;
Retention settings;
Vendor information;
Data-disclosure records;
Security-incident records;
Training records; and
Periodic compliance-review records.

The Board of Directors retains authority over major changes to the District’s ALPR program.

SECTION 23 — PERIODIC REVIEW

RRDD1 shall review this policy at least annually and whenever:

Connecticut law governing ALPR systems changes;
RRDD1 changes ALPR hardware or software;
RRDD1 begins using a new ALPR vendor;
The District changes its permit system;
A significant security incident occurs; or
The District Administrator determines that policy revision is necessary.

The District shall also periodically verify the actual UniFi Protect configuration against the requirements of this policy.

SECTION 24 — PUBLICATION

RRDD1 shall publicize this policy in a manner reasonably calculated to make the policy available to members of the public, including by posting the policy on the RRDD1 website or otherwise making it available at the Transfer Station and administrative office.

The policy shall be updated when necessary to remain consistent with Connecticut law.

SECTION 25 — SEVERABILITY

If any provision of this policy is determined to be invalid or unenforceable, the remaining provisions shall remain in effect to the fullest extent permitted by law.

SECTION 26 — CONFLICT WITH LAW

If any provision of this policy conflicts with a mandatory provision of Connecticut or federal law, the applicable law shall control.

Nothing in this policy shall be interpreted to authorize RRDD1, its employees, officials or contractors to use or disclose ALPR information in a manner prohibited by law.

Changes to This Privacy Policy

RRDD1 reserves the right to modify this Privacy Policy at any time. Any revisions will be posted on this page with an updated effective date.

Continued use of this website after changes have been posted constitutes acceptance of the revised Privacy Policy.

Contact Information

Questions regarding this Privacy Policy may be directed to:

Regional Refuse Disposal District #1
Administrator’s office
31 New Hartford Road
Barkhamsted, Connecticut 06063

Email: Administration@RRDD1.com

Website: regionalrefusedistrict1ct.gov