Our CCTV Policy

1. Introduction

2. About this policy

3. Why we use CCTV

4. How we monitor CCTV

5. How we use the Data

6. Access and disclosure of images

7. Individual’s access rights

8. Implementation

9. Data protection

1. Introduction

This Company believes in maintaining a safe and secure work environment for our employees, guests, customers, employees of Plymouth Science Park and contractors. To do this we have installed 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 business premises. The images recorded by CCTV are Personal Data and we acknowledge the legal rights of our employees, guests, customers, employees of Plymouth Science Park and contractors in compliance with the Data Protection Act.

2. About this policy

We currently use CCTV to access and monitor our business premises, 24 hours per day, 7 days a week. This policy sets out the details of why we use CCTV, how we monitor CCTV, and how we use the data, access and disclosure of images, individual’s access rights, implementation, and data protection. CCTV collects personal data therefore it is subject to the Data Protection Act, please refer to our privacy policy. This Company is the data controller of all CCTV data captured on site. This CCTV Policy covers all the employees, guests, customers, employees of Plymouth Science Park and contractors.

3. Why we use CCTV

We currently use CCTV in our office for the following business purposes:

• To prevent or detect criminal activity and protect our assets from damage, disruption, theft, vandalism, other crimes, and equivalent malpractice.
• To identify and prosecute offenders.
• To monitor the security of the business premises.
• To protect the personal safety of employees, guests, customers, employees of Plymouth Science Park and contractors.
• To support any internal investigations as part of a staff disciplinary procedure.

4. How we monitor CCTV

• The location of the security cameras is in relevant viewing spaces that are legitimate for the purpose of the monitoring as specified in section 5.2.
• All cameras are clearly visible.
• CCTV images are produced as clear as possible so that they are effective for the purpose set out in 5.2.
• Our CCTV will only record images and does not record audio.
• Our CCTV is a live feed that can be accessed and monitored continuously and is revisited when an incident has occurred.
• We will ensure that live feeds from the CCTV are only viewed by the data controller who is an authorised member of staff.
• Viewing of CCTV will take place in a restricted area where no other employees have access to as the viewing occurs.

5. How we use the Data

• To ensure the legal rights of the individuals recorded by our CCTV are protected, we ensure that the data we collect is stored in a way that maintains integrity and security.
• We will ensure that the data is used for the purposes specified in section 5.2.
• We will not use the data collected for another purpose in compliance to the Data Protection Act.
• Data will be kept for as long as is needed when establishing that a crime has been committed.
• Data will be kept for as long is needed when a staff disciplinary procedure is in place until the process is complete.
• The CCTV system records digital images that are digitally stored on a hard drive of a PC or server and are deleted and overwritten on a recycling basis.
• The data collect is permanently deleted after an appropriate period of time.

6. Access and disclosure of images

• Access and disclosure of CCTV images are restricted to retain the rights of individuals. Images can only be disclosed in accordance with the purposes for which they were originally collected as stated in section 5.2.
• Disclosure of images to other third parties will only be made in accordance with the purposes for which the systems is used and will be limited to:
• The police and other law enforcements agencies, where the images recorded could assist in the prevention or detection of 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 representative.
• Line managers involved with company disciplinary and performance management processes.
• Individuals whose images have been recorded and retained (unless disclosure would prejudice the prevention of detection of crime or the apprehension or prosecution of offenders).
• The managing director of the Company (or another person acting in their absence) is the only person who is permitted to authorise disclosure of images to external third parties such as law enforcement agencies.
• All requests for access and disclosure for CCTV images will be documents, including the date of the disclosure, to whom the images have been provided, the reasons why they are required, and if the disclosure is denied and the reason.

7. Individual’s 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 the company holds about them, including CCTV images if they are recognisable from the image.

If you wish to access the CCTV images relating to you, you must make a written request to the company’s managing director Daryl McMullan. This can be done by using his email address Daryl.McMullan@completecommsltd.com.

Your request must include the date and approximate time when the images were recorded and the location of the CCTV camera, so that the images can be easily located, and your identity can be established as the person in the images. We will always check the identity of the individual making the request before processing it.

8. Implementation

The Company’s managing director is responsible for the implementation of the compliance with this policy and the operation of the CCTV system. Regular review of the use and processing of CCTV images and always ensure that it remains compliant with the laws regulating data protection and privacy. Any complaints or enquiries about the operation of the CCTV system should be addressed to Daryl McMullan.

9. Data protection

The Company will process the personal data collected in connection with the operation of the CCTV policy in accordance with its data protection policy and any interval privacy notices in force at the relevant time. Inappropriate access of disclosure of this data will constitute a data breach and should be reported immediately to Daryl McMullan in accordance with the company’s data protection policy. Reported data breeches will be investigated and may lead to sanctions under the company’s disciplinary procedure.