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Closed Circuit Television (CCTV) - Privacy notice

Your personal data
“Personal data” is any information about a living individual, which allows them to be identified from that data (for example a name, photographs, videos, email address, or address).

Identification can be by directly using the data itself or by combining it with other information, which helps to identify a living individual.

The processing of personal data is governed by legislation relating to personal data, which applies in the United Kingdom including the General Data Protection Regulation (the “GDPR) and other legislation relating to personal data and rights such as the Human Rights Act.

What personal information is being processed and what for
CCTV recordings are used for public safety interests and the prevention and detection of crime. Recordings also provide enforcement agencies with evidence of criminal activity, for formal actions including prosecutions in court and identification of offenders in investigations.

These recordings contain images of the public going about their daily business as well as offenders, persons wanted and missing.

We also share with Insurance Companies if required, under strict Data Protection

Why we are allowed to use your information
The legal basis for using the information you provide us is:
• for the interest of public safety, the prevention and detection of crime, apprehension and prosecution of offenders and for legal proceedings

The lawful basis for holding and processing the data comes under:
• Section 163 of the Criminal Justice and Public Order Act 1994
• Crime and Disorder Act 1998
• Protection of Freedoms Act 2012
• In certain Circumstances - Regulation of Investigatory Powers Act

We will usually seek your consent prior to processing or sharing your information, however, if there is a legal reason, we may not require your consent, e.g. where the disclosure is necessary for the purposes of the prevention and/or detection of crime.

Where we need to disclose sensitive or confidential information such as medical details to other partners, we will do so only with your prior explicit consent or where we are legally required to.

Who we will share CCTV images with
Information will be shared with:
• Internal/External enforcement agencies Trading Standards, HMRC .
• Police Forces
• Fire and Rescue Services
• with members of the public under very strict Data Protection or Freedom of Information conditions
• we will also share information with Insurance Companies, but only under very strict Data Protection

Who has access to CCTV images at LFO?
• Employees at LFO who are on the call out list, should the alarm go off when the building is empty may access the Blink app at that time. Otherwise access is restricted to Practice Managers, the Operations Director, and Lynne and Gerard Fernandes

How long we will keep CCTV Images
CCTV images are held for 1.5-10 days for non-requested footage, and are over-written on a rolling basis. Video images are only retained if any footage is requested within the parameters stated above in this document. Currently (11.2.2020) all footage is being overwritten on a rolling basis and we are not retaining any footage. Please ask Lynne Fernandes for up to date information.

How your information is stored
CCTV video images are recorded in real time onto a secure CCTV system and onto the Blink App system

Your rights
You have a number of rights regarding your personal data, including withdrawing your consent where we have asked for it. You can also ask for a copy of the information we hold about you and ask us to correct anything that is wrong.

For detailed information about your rights please see our privacy notice

When is CCTV covered by the Data Protection Act?
Most uses of CCTV will be covered by the Data Protection Act.

The Data Protection Act gives you the right to see information held about you, including CCTV images of you, or images which give away information about you (such as your car number plate).

It also sets rules which CCTV operators must follow when they gather, store and release CCTV images of individuals. The Information Commissioner can enforce these rules.

If you are concerned that CCTV is being used for harassment, anti social behaviour or other matters dealt with under the criminal law, then these are matters for the police.

CCTV filming carried out by others

What can I expect?
The CCTV operator must let people know they are using CCTV. Signs are the most usual way of doing this. The signs must be clearly visible and readable, and should include the details of the organisation operating the system if not obvious.

CCTV should only be used in exceptional circumstances in areas where you normally expect privacy - such as in changing rooms or toilets, and should only be used to deal with very serious concerns. The operator should make extra effort to ensure that you are aware that cameras are in use.

Conversations between members of the public should not be recorded on CCTV. (There are some specific exceptions to this, such as a panic button in a taxi cab or the charging area of a police custody suite).

What must a CCTV operator do?
• Make sure someone in the organisation has responsibility for the CCTV images, deciding what is recorded, how images should be used and who they should be disclosed to.
• Have clear procedures on how to use the system and when to disclose information.
• Make regular checks to ensure the procedures are followed.

When can CCTV images be disclosed?
You have the right to see CCTV images of you and to ask for a copy of them. The organisation must provide them within 30 calendar days. This is called a Subject Access Request. You will need to provide details to help the operator to establish your identity as the person in the pictures, and to help them find the images on their system.

• CCTV operators are not allowed to disclose images of identifiable people to the media - or to put them on the internet - for entertainment. Images released to the media to help identify a person are usually disclosed by the police.
• An organisation may need to disclose CCTV images for legal reasons - for example, crime detection. Once they have given the images to another organisation, then that organisation must adhere to the Data Protection Act in their handling of the images.
• Public authorities are subject to the Freedom of Information Act 2000, or the Freedom of Information (Scotland) Act 2000. This Act allows members of the public to request official information by writing to the public authority, who must respond within 20 working days. If the images are those of the person making the request, then the request would be handled under the Data Protection Act as a Subject Access Request. If, however, other people are identifiable in the CCTV pictures, then the images would be considered personal information and it is likely they would be exempt from the Freedom of Information Act.

How long can an organisation retain CCTV images?
Organisations should have a retention policy. They should only keep the images for as long as necessary to meet the purpose of recording them.