The below policy sets out the use and management of the CCTV equipment and images in compliance with the Regulation (EU) 2016/679 of the European Parliament and of the Council, GDPR (General Data Protection Regulation) 2018, and the CCTV code of practice ICO.
https://www.legislation.gov.uk/eur/2016/679/contents
https://www.legislation.gov.uk/ukpga/2018/12/contents/enacted
https://ico.org.uk/for-the-public/home-cctv-systems/
The CCTV cameras will comply with privacy and other legislative requirements by ensuring the following:
That CCTV cameras for this property will be used for security and safety purposes only.
They were activated: 01/01 2020
Whether they will record footage continuously or intermittently: Continuously
The period of surveillance: 24hrs
Who has access to the footage: Data Protection Officer, who will be referred to as the DPO herein.
The DPO will ensure the correct legislation is used and within compliance.
The DPO role it is to maintain or delete the video, or when and how the footage will be used for the purpose of which it is implemented.
To assist in the prevention or detection of crime.
To assist in the identification and prosecution of offenders.
To monitor the security of the property.
The DPO is responsible for the day-to-day operation and complies with the GDPR and ICO policy of the CCTV system. Any complaints about the operation should be directed to them.
Displaying signs at each entrance telling people that CCTV cameras are in use and they may be recorded: Front and Rear of property.
Retention of recorded images:
Images produced by the CCTV are intended to be clear as possible so they are effective in the purpose set out above, and maintenance checks are carried out by the DPO on a regular basis. As recording system generates digital content, any recordings are deleted by overwriting the hard drive on a normal basis of 21 days. If any content is required to be stored on removeable storage this will be deleted after a period of 31 days. However, should the police request a copy for crime investigation they may require this for a longer period.
Images that are recorded are held in a secure location and may be viewed by authorised operators at any time.
Disclosure of the images to a third part will only be made in the accordance with the purposes for which the system is intended for: The police force and local authority, where images recorded could assist in the prevention or detection of a crime, or identification and prosecution of an offender.
Prosecution agencies such as Crown Prosecution Service.
Relevant legal representatives such as solicitors.
Data Protection - Subject Access Request:
All requests for disclosure will be documented.
Access to and disclosure of the images on the CCTV is restricted, which will ensure the rights of individuals are retained. Images can only be disclosed with the purpose for which they were originally collected for.
Before you make your request in writing to the DPO
Two forms of ID are required, one of these should be a driving licence, birth certificate, or passport; the other should be a recent utility bill.
If you are not the applicant, you will need to upload written consent from the applicant.
CCTV footage is only held for a period of 21 days, please consider this before submitting your request.
Your request must include the date the approximate time when the images were recorded and the location of the particular CCTV camera, so that the image can be located.
The DPO is entitled to charge £15 for this service and retains the right to do so if extensive resources are required to supply the images.
The DPO will always check the identity of the requestor making the request before processing, Photo ID will be required.
The DPO will respond to the request within 21 Days of receiving the request.
The DPO will first determine whether disclosure of the image will reveal a third-party information, as you have no right to access CCTV images relating to other people. In this case images will be obscured (if at all possible) if it would otherwise involve an unfair intrusion into their privacy.
Due to UK GDPR, we are unable to disclose any CCTV footage or images to members of the public as this is classed as personal information unless they are part of the request. Any such disclosure may put others at risk and/or breach third party data.
If you require CCTV footage regarding a road traffic collision or theft, this should be requested on your behalf, through your insurance provider or the police force investigating the incident. We can request your photographic ID (for example, a valid passport or driving licence) from the insurance provider or police force if required.
All requests must include a signed letter of consent, for them to act on your behalf. Any requests submitted without meeting this requirement will be declined.
Contact: dpo.larry@gmail.com
DPO Rev 1.3 01-01-2020