Daventry Contact will use closed circuit television (CCTV) system including Automatic Number Plate Recognition (ANPR) capturing images to identify any individuals coming onto Daventry contacts private property. The purpose of using the CCTV system is to improve the security and to protect the property of Daventry Contact and all those who have a relationship with Daventry Contact as described within the procedures. CCTV images are monitored and recorded in strict accordance with this policy and procedures detailed therein.
- The CCTV system and all associated equipment is owned and managed by Daventry Contact.
- Daventry contact is responsible for the CCTV system and all associated equipment and for ensuring that adequate signage is securely fitted in compliance with the ICO CCTV code of practice.
- Organisations that process personal data are subject to the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. Daventry Contact is the data controller. Daventry contact is registered with the information commissioner’s office and the registration number is ZA221489. The CCTV system operates to meet the requirements of GDPR based on the Information Commissioner’s guidance.
- The CCTV system is operational and will monitor 24 hours a day, every day of the year.
- The system will use a motion detector (only when it is working) to only record when motion has been detected.
The use of the motion detector and careful positioning of the cameras will help capture images which are relevant to the intended purposes detailed in these procedures.
- Cameras are fitted and positioned to cover the car park of Daventry contact, to improve the security and protect the property for all the reasons in section 8. Purpose of the CCTV system.
- Signs are fixed to the building which are visible when entering onto the private property of Daventry Contact. The signs make it clear that CCTV is in operation, the purpose is for the prevention of crime, provides a QR code and how to obtain contact details if anyone would like to find out who is responsible for the CCTV system.
Purpose of the CCTV system
- The purpose of the CCTV system is:
a) For the prevention of crime
b) To assist with the investigation of crime and or other incidents.
C) To ensure the safety and security of the building, employees, customers, visitors, vehicles, contents, and belongings which include.
i. The protection of Daventry Contact property including the building, car park, contents, belongings, assets, vehicles, and anything else that belongs to Daventry Contact.
ii. The protection of all the individuals who have a relationship with Daventry Contact including trustees, staff, volunteers, customers, visitors and including all those who have an agreement to use the car park and or part of the building within Daventry Contact whether it is a one-off occasion or a regular attendance which includes the charity known as men’s shed or community shed.
iii. The protection of the property, contents, vehicles, and all belongings that is owned by those as described in 8(c) ii.
d) To prevent fly tipping.
- All staff and volunteers will be made aware of the CCTV policy and only management and trustees should fully understand the procedures to ensure that it details and covers all aspects of the use of the CCTV system and that it is compliant with GDPR.
- Only management staff will be authorised to access the CCTV system and equipment. Unauthorised access is strictly prohibited.
- All users of the CCTV system will have relevant training to operate the system in accordance with GDPR regulations and in accordance with Daventry Contact CCTV policy and procedures at all times.
- The CCTV system installer or other appointed CCTV contractor will be authorised to access the system when repairs, upgrades, maintenance, or any changes to the CCTV system and or equipment are required.
- The use of the CCTV system will be conducted in a professional, ethical and legal manner.
- This policy will be available on our website.
- We will let people know about our policies by having a message on our phone system and our policies can be viewed on our website or can be requested by email firstname.lastname@example.org
Monitoring and recording
- Cameras are monitored from a secure room and will only be reviewed should there be the need to do so. The need to review CCTV footage will include.
- Security reasons.
- There is damage to property or belongings to any of those mentioned within this policy and procedures.
- Any form of violence or threatening behaviour.
- We have a legal reason to do so.
- System checks for quality, functionality, software updates or any other reason to ensure the system is working correctly and efficiently.
- To manually delete any unwanted data such as backup data.
- To assist a request from any emergency service such as police ambulance or fire service.
- There has been a request to do so for any reason detailed within this policy and procedures or for any reason Daventry Contact feel is necessary.
- The CCTV system will provide footage of a suitable quality to meet the specified purposes for which it was installed.
- The system is checked regularly for quality, functionality, camera angles, the date and timestamp recorded on the footage is accurate and any other required system checks as necessary.
- Any information not obtained in accordance with this policy will not be used against any trustee, staff, volunteer, customer, or visitor of Daventry Contact.
- Data that is collected by the CCTV system will only be backed up for the reasons described in point 8. of the procedures section “Purpose of the CCTV system”.
- Cameras will be checked regularly to ensure that they are capturing for the purposes detailed within these procedures, adjustments will be made if necessary, providing that they continue to meet the requirements set out in these procedures.
- All those authorised to access the CCTV system must have adequate training on the CCTV system and must comply with Daventry Contact’s CCTV policy and procedures.
- When carrying out maintenance checks, this shall be recorded on the CCTV data log and any issues found should be addressed appropriately.
- CCTV images may only be accessed by authorised personnel of Daventry Contact or authorised contractor carrying out repairs or maintenance on the CCTV system and or equipment associated with the CCTV. Any unauthorised personnel are strictly prohibited.
Compliance with Data Protection
- Daventry contact’s use of the CCTV system complies with general data protection regulations and the Data Protection Act 2018.
- The CCTV system is subject to a Data Protection Impact Assessment (DPIA) to identify any risks related to the installation or use of a CCTV system and to comply with Data Protection legislation.
- The DPIA will be reviewed regularly and where there are to be any upgrades, modifications to the system, a new DPIA will be carried out.
- To ensure the protection of data collected from CCTV, the following security measures will be followed at all times
a. Only authorised management will be able to monitor, record, backup and disclose CCTV. Unauthorised access is strictly prohibited.
b. The main hard drive to the CCTV system will be password protected, to prevent unauthorised access.
c. The CCTV system will have security software to protect the system.
Disclosure of CCTV images
- Individuals can request footage relating to themselves, this is known as subject access request (SAR), if an individual would like to request this, then this should be submitted in writing to Daventry contact, Units 1&2 South March, Long March Industrial Estate, Daventry, NN11 4PH.
- Where Daventry Contact is unable to disclose personal data without identifying another individual, then Daventry Contact are not obliged to comply with the request unless the individual has provided their written consent to the disclosure.
- In some circumstances we may disclose footage to a third party such as when there has been an incident related to section 8. Of these procedures which involves and investigation or a disclosure is required by law in relation to crime or in other circumstances where an exemption applies under relevant legislation.
- Any disclosure will be at the discretion of Daventry Contact management of CCTV and in some circumstances may include the board of trustees and or Daventry Contact appointed solicitors should this be necessary.
- Daventry Contact may disclose CCTV images to third parties in reference to relevant legislation and where necessary following professional advice from the Information Commissioner’s Office and or solicitors should there be the need to do so.
- A record of any disclosure will be kept on a CCTV data log stored on Daventry Contact system.
Storage and retention period
- CCTV images will be stored on the CCTV system hard drive for no longer than 31 days from the date of recording, where the footage will be automatically overwritten. Unless it is required for evidence purposes, or the investigation of an offence or as required by law, then the data will be backed up to ensure that it is kept for as long as it is needed.
- Where an image is required to be held longer than the retention period, the data will be backed up onto a CD, USB or by other suitable means which allows us to safely store the data.
- Any data held longer than the retention period will be held for as long as there is a need to do so. Once the data is no longer required it will then be deleted.
- Any data that is backed up will be logged onto the CCTV data log stored on Daventry Contact system.
Lawful basis for collecting CCTV data.
- We process personal data for the prevention, detection and investigation of crime and we have a legitimate interest as our lawful basis for doing so.
- We may also collect criminal offence data under schedule 1, paragraph 10 of the DPA 2018 “preventing or detecting unlawful acts”.
All complaints concerning Daventry Contact use of CCTV must be in writing by email to email@example.com or
Units 1&2 South March,
Long March Industrial Estate,
This policy and the procedures detailed herein will be reviewed annually and approved by the board of Trustees.
This page was last updated January 2024