Heartcibo@thecourtyardcafe uses closed circuit television (CCTV) images to protect the Company’s property and to provide a safe and secure environment for employees and visitors to the Company’s business premises. This policy sets out the details of how the Company will collect, use and store CCTV images.
The Company’s CCTV facility will only record images. There is no audio recording i.e. conversations are not recorded on CCTV.
Purposes of CCTV
The Company has carried out a data protection impact assessment and on the basis of its findings it considers it necessary and proportionate to install and use a CCTV system. The data collected from the system will assist in:
· Prevention or detection of crime or equivalent malpractice.
· Identification and prosecution of offenders.
· Monitoring of the security of the Company’s business premises.
· Ensuring that health and safety rules and Company procedures are being complied with.
Location of cameras
Cameras are located at strategic points throughout the Company’s business premises, principally at the entrance and exit points and at self serve areas. The Company has positioned the cameras so that they only cover communal or public areas on the Company’s business premises and they have been sited so that they provide clear images. No camera focuses, or will focus, on toilets, shower facilities, changing rooms, staff kitchen areas, staff break rooms or private offices.
All cameras are also clearly visible.
Appropriate signs are prominently displayed so that employees, clients, customers and other visitors are aware they are entering an area covered by CCTV.
Recording and retention of images
Images produced by the CCTV equipment are intended to be as clear as possible so that they are effective for the purposes set out above. Maintenance checks of the equipment are undertaken on a regular basis to ensure it is working properly and that the media is producing high quality images.
Images are recorded in constant real-time (24 hours a day throughout the year).
As the recording system records digital images, any CCTV images that are recorded will be held for 3 months and then deleted.
Access to and disclosure of images
Access to, and disclosure of, images recorded on CCTV is restricted. This ensures that the rights of individuals are retained. Images can only be disclosed in accordance with the purposes for which they were originally collected.
The images that are filmed are recorded centrally and held in a secure location. Access to recorded images is restricted to the operators of the CCTV system and to those line managers who are authorised to view them in accordance with the purposes of the system. Viewing of recorded images will take place in a restricted area to which other employees will not have access when viewing is occurring. If media on which images are recorded are removed for viewing purposes, this will be documented.
Disclosure of images to other third parties will only be made in accordance with the purposes for which the system is used and will be limited to:
· The police and other law enforcement agencies, where the images recorded could assist in the prevention or detection of a crime or the identification and prosecution of an offender or the identification of a victim or witness.
· Prosecution agencies, such as the Crown Prosecution Service.
· Relevant legal representatives.
· Individuals whose images have been recorded and retained (unless disclosure would prejudice the prevention or detection of crime or the apprehension or prosecution of offenders).
The Owner and operator of the Company is the only person who is permitted to authorise disclosure of images to external third parties such as law enforcement agencies.
All requests for disclosure and access to images will be documented, including the date of the disclosure, to whom the images have been provided and the reasons why they are required. If disclosure is denied, the reason will be recorded.
Individuals’ access rights
Under the UK’s data protection laws, including the General Data Protection Regulation (GDPR), individuals have the right on request to receive a copy of the personal data that the Company holds about them, including CCTV images if they are recognisable from the image.
If you wish to access any CCTV images relating to you, you must make a written request to the the owner James Townsend. This can be done by using this email address firstname.lastname@example.org. The Company will usually not make a charge for such a request, but we may charge a reasonable fee if you make a request which is manifestly unfounded or excessive, or is repetitive. Your request must include the date and approximate time when the images were recorded and the location of the particular CCTV camera, so that the images can be easily located and your identity can be established as the person in the images.
The Company will usually respond promptly and in any case within one month of receiving a request. However, where a request is complex or numerous the Company may extend the one month to respond by a further two months.
The Company will always check the identity of the employee making the request before processing it.
James Townsend will always determine whether disclosure of your images will reveal third party information, as you have no right to access CCTV images relating to other people. In this case, the images of third parties may need to be obscured if it would otherwise involve an unfair intrusion into their privacy.
If the Company is unable to comply with your request because access could prejudice the prevention or detection of crime or the apprehension or prosecution of offenders, you will be advised accordingly.
For more guidance and information relating to GDPR visit the information commissioner’s office.