CCTV and other surveillance systems have a role in helping to maintain a safe and secure environment for visitors to our locations. We recognise that this may raise concerns about the effect on individuals and their privacy. Images recorded by surveillance systems are personal data and are processed in accordance with data protection laws.
About this policy
We currently use CCTV cameras to view and record individuals on our premises. We do not intentionally record images from public areas, although may do so incidentally. This policy outlines why we use CCTV, how we will use CCTV and how we will process data recorded by CCTV cameras to ensure we are compliant with data protection law and best practice.
This policy covers all visitors, customers and anyone else who may visit our locations.
Reasons for the use of CCTV
We currently use CCTV on our premises as outlined below. We believe that such use is necessary for legitimate business purposes, including:
- to prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime;
- for the personal safety of our team members, visitors and other members of the public and to act as a deterrent against crime;
- to support law enforcement bodies in the prevention, detection and prosecution of crime;
- to assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings;
- to assist in the defence of any civil litigation, including employment tribunal proceedings
This list is not exhaustive and other purposes may be or become relevant.
Camera locations are chosen to minimise the viewing of spaces which are not relevant to the legitimate purpose of the monitoring. As far as practically possible, CCTV cameras will not focus on private homes, gardens or other areas of private property.
Surveillance systems are not used to record sound and team members using surveillance systems will be given appropriate training to ensure they understand and observe the legal requirements related to the processing of relevant data.
How we will operate any CCTV
Where CCTV cameras are placed in our locations, there will be signage to alert individuals that their image may be recorded. Images captured will only be viewed by approved team members whose role requires them to have access to this information. Recall of recorded images will only take place in designated, secure offices.
Use of data gathered by CCTV
In order to ensure that the rights of individuals recorded by the CCTV system are protected, we will ensure that data gathered from CCTV cameras is stored in a way that maintains its integrity and security. This may include encrypting the data, where it is possible to do so.
We may engage data processors to process data on our behalf. We will ensure reasonable contractual safeguards are in place to protect the security and integrity of the data.
Retention and deletion of data gathered by CCTV
Data from CCTV cameras will not be retained indefinitely and will be permanently deleted once there is no reason to retain the recorded information. Exactly how long images will be retained for will vary according to the purpose for which they are being recorded. For example, where images are being recorded for crime prevention purposes, data will be kept long enough only for incidents to come to light.
At the end of their useful life, all images stored in whatever format will be erased permanently and securely. Any physical matter such as tapes or discs will be disposed of as confidential waste. Any still photographs and hard copy prints will be disposed of as confidential waste.
We will never engage in covert monitoring or surveillance (that is, where individuals are unaware that the monitoring or surveillance is taking place) unless, in highly exceptional circumstances, there are reasonable grounds to suspect that criminal activity or extremely serious malpractice is taking place and, after suitable consideration, we reasonably believe there is no less intrusive way to tackle the issue.
The decision to carry out covert monitoring will be fully documented and will set out how the decision to use covert means was reached and by whom.
Ongoing review of CCTV use
We will ensure that the ongoing use of existing CCTV cameras in our locations is reviewed periodically to ensure that their use remains necessary and appropriate, and that any surveillance system is continuing to address the needs that justified its introduction.
Requests for disclosure
No images from our CCTV cameras will be disclosed to any third party apart from as described. Data will not normally be released unless satisfactory evidence that it is required for legal proceedings or under a court order has been produced. In other appropriate circumstances, we may allow law enforcement agencies to view or remove CCTV footage where this is required in the detection or prosecution of crime.
We will maintain a record of all disclosures of CCTV footage.
You have rights under data protection laws, in certain circumstances, including to:
- request access to personal information that we may process about you
- receive a copy of certain of your personal data in a computer readable format that can be transferred to another controller without hindrance
- require us to correct any inaccuracies in your information
- to require us to erase personal data that we may process about you where this is no longer required to be processed by us
- to object to or restrict our processing of some of your personal information in certain circumstances
For more information
For further information about how to exercise any of these rights please call our Customer Contact Centre, ask in branch, or email our Data Protection Officer directly at firstname.lastname@example.org