CCTV Privacy Policy

We care about your privacy. This notice explains how we collect, use, store and protect personal data captured
through our Closed-Circuit Television (CCTV) systems.

1. Who We Are

responsible for the personal data captured by these systems.

2. Purpose of CCTV Use

We operate CCTV in accordance with the ICO’s CCTV Code of Practice for the following purposes:
• Protecting the health and safety of employees, customers and visitors.
• Preventing and detecting crime and anti-social behaviour.
• Protecting our premises, vehicles and other assets.
• Assisting with investigations into incidents, accidents, disputes or insurance claims.
• Supporting law enforcement and licensing agencies where legally required.
CCTV is not used for monitoring staff performance and is not used for any purpose incompatible with those
listed above.

3. Lawful Basis for Processing

Our lawful basis for processing CCTV footage under UK GDPR Article 6 is:
• Legitimate Interests – to ensure safety, security and crime prevention.
• Legal Obligation – where footage must be available for disclosure to law enforcement or regulatory
bodies.
A legitimate interests assessment has been carried out to ensure CCTV use is necessary, proportionate and
balanced against individuals’ rights.

4. What Personal Data We Collect

CCTV may capture:
• Images of individuals.
• Vehicle registration numbers.
• Date, time and location data.
CCTV systems do not record audio.

5. Transparency

Clear and visible signage is displayed at all CCTV locations, informing individuals that CCTV is in operation and
directing them to this privacy notice.

6. Access and Disclosure of CCTV Footage

Access to CCTV footage is:
• Restricted to authorised personnel only.
• Granted strictly on a need-to-know basis.
We may disclose footage:
• To law enforcement agencies, where required by law.
• In connection with legal proceedings, insurance claims or investigations.
• To professional advisers (e.g. insurers or solicitors).
We do not share CCTV footage with third parties for marketing purposes.

7. Retention of CCTV Data

In line with ICO guidance:
• CCTV footage is retained for no longer than necessary.
• Footage is retained for a maximum of 12 months, although may be shorter at some locations.
• Where footage is required for an investigation, legal claim or insurance matter, it may be retained for
longer until the issue is resolved.
All footage is securely deleted once it is no longer required.

8. Security of CCTV Data

We implement appropriate technical and organisational measures to protect CCTV data, including:
• Secure, password-protected systems.
• Limited access controls.
• Secure storage of recordings.
While we take reasonable steps to protect data, no electronic system can be guaranteed to be completely
secure.

9. Your Rights

Under UK GDPR, you have the right to:
• Request access to CCTV footage in which you appear (Subject Access Request).
• Request rectification, erasure or restriction of processing where applicable.
• Object to processing in certain circumstances.
• Lodge a complaint with the Information Commissioner’s Office (ICO).
Subject Access Requests
• Requests are free of charge.
• We will respond within one month of receiving a valid request.
• Proof of identity will be required.
• We may lawfully refuse or restrict access where disclosure would adversely affect the rights of others
or prejudice crime prevention.

10. Third-Party Processors

Where CCTV systems are installed or maintained by third-party providers, those providers act only on our
instructions and are subject to contractual data protection obligations.

11. Policy Review

12. Contact Details