CCTV Policy

Created on 15 September 2021

1. Policy Statement

• This policy seeks to ensure that the Close Circuit Television (CCTV) system used at Gamma Construction Ltd (“Company”, “we”, “our” or “us”) is operated in compliance with the Data Protection Act 2017 (DPA).
• The purpose of this policy is to set out the position of Gamma Construction Ltd as to the management, operation and use of the CCTV.
• The Company uses CCTV only where it is necessary for the pursuit of legitimate aim as set out in point 2, and only if it is proportionate to that aim.
• This policy applies to all members of our workforce, visitors and to all other persons whose images may be captured by the CCTV system.

2. Purposes of CCTV

The Company uses the CCTV system for the following purposes:

• To monitor access to the server room.
• To monitor office entrance access, workshop and plant & equipment yard.
• To protect the Company’s premises and assets.
• To prevent, reduce, detect and investigate crime and other incidents.
• To prevent unauthorised access.

3. Scope

• The CCTV system is owned and operated by Gamma Construction Ltd.
• The CCTV cameras have been installed at the following places:

a.         Server room

b.         Reception waiting room

c.         Management floor  - Entrance stairs

d.         Workshop

e.         Plant & Equipment parking yard

• The CCTV cameras are operating on a 24/7 basis.
• The cameras are not installed in areas in which individuals would have an expectation of privacy such as toilets.
• We will not engage in covert surveillance (i.e. recording which takes place without the individual’s knowledge). However, a covert recording will only be undertaken in exceptional circumstance for example to prevent or detect an unlawful act or other serious misconduct and if it's proportionate i.e. where there are no other reasonable less intrusive means for achieving those purposes.
• All images recorded by the CCTV System remain the property and copyright of the Company.

4. Signage/Notification

• A sign is prominently displayed at the entrance of the building to inform individuals entering the premises that they are entering an area covered by CCTV cameras.

5. Security Measures

• All images are recorded centrally on our server which is password protected.
• Recorded footage and equipment will be securely stored in a restricted area.
• Access to the CCTV system and stored images will be restricted to authorised personnel only.

6. Management and Access

• The following persons are authorised to access the CCTV Footage:

a. The IT Administrator for the camera in Server Room, Entrance and Waiting room.

b.The Workshop Manager for the camera(s) at Workshop and Plant & Equipment yard.

• The Security Team will be viewing the live footage of the entrance daily.
• A log of any access to the CCTV images, including time and dates of access,
• and a record of the individual accessing the images, will be maintained by the Company.

7. Retention Period

• Images/recordings will be kept for a minimum of 1 month.  The system automatically deletes the data after 1 month.
• Any footage that shows a crime will be kept as long as it is needed to undertake criminal proceedings.

8. Disclosure of CCTV Footage

In relevant circumstances, CCTV footage may be disclosed to:

• The police where we are required by law to do so.
• The police where a crime or suspected crime has taken place.
• Individuals (or their legal representatives) subject to a court order.

9. Request for Access to CCTV footage

• Individuals have the right to request access to CCTV footage relating to themselves under the Data Protection Act.
• Individuals submitting a request for access will be asked to send an email to the Data Protection Officer and to provide sufficient information to enable the footage relating to them to be identified. For example, date, time and location.
• On receipt of the request, the Data Protection Officer will liaise with the IT Department and will communicate the decision within one month of receiving the request from the data subject. (As provided above CCTV footage are kept for 1 month only)
• The period for responding the request may be extended by a further month where necessary taking into account the complexity and number of requests.
• The company reserves the right to refuse access to CCTV footage where this would prejudice the legal rights of other individuals or jeopardise an on-going investigation.
• The following information will be recorded where access is provided:

a. the reason for disclosure;

b. the details of the image disclosed i.e. the date, time and location of the image;

c. who was present when the images were disclosed;

d. whether any images were disguised/blurred to prevent identification of individuals other than the data subject.

• In giving an individual a copy of their data, the company will provide still/series of still pictures on a disk with relevant images.
• Where footage contains images of third parties, the company will take appropriate steps to mask/blur and protect the identities of those individuals.
• If it is impossible to obscure/mask images of other individuals/third parties, the individual will then only have the right to view the footage and he/she will not be provided with a copy in this case.

Note: Data will be provided to those requests authorised where possible. Otherwise, the data subject will be offered the opportunity to view the footage.

10. Procedures to handle Incidents

Any complaints relating to the CCTV system should be directed in writing to the Data Protection Officer and in any event within 3 days of the date the incident giving rise to the complaint. A complaint will be responded to within a month following the date of its receipt.

Records of all complaints and follow up action will be maintained by the Company. If a complainant is not satisfied with the response, they may complain to the Data Protection Office.

11. Policy Review

This policy will be reviewed annually by the Data Protection Officer and the IT Team to assess compliance with clauses 1 and 2 and to determine whether the use of the CCTV system remains justified.