CCTV Privacy Policy

CCTV Privacy Policy

Overview

Purposes

Crime detection and prevention, occupant safety, safe delivery of packages and post.

Personal information collected

Identifiable images of people within and adjacent to property boundaries.

Lawful basis for processing

Legitimate interest to detect and prevent crime, detect and prevent risk to the safety and well being of occupants, and facilitate delivery of goods and services to the address.

Statutory rights

Rights to access and erasure.

This address uses security cameras and other video/audio recording devices inside and outside the buildings to detect and prevent crime, ensure the safety of the occupants, as well as facilitate the safe delivery of packages and post intended for the address or neighbouring addresses.

The system installed at the premises consists of a number of fixed field security cameras and a video doorbell featuring audio recording capability and night vision (IR). The cameras are installed so as to primarily capture activity within the boundaries of the property but despite implementing reasonable technological measures such as privacy masking may also include limited incidental recording of public and private spaces beyond the boundary of the premises.

Recordings

The security cameras record video footage 24/7/365. Recordings are retained for a period of 30 days. The video doorbell recordings audio and video footage upon activation by motion or button push for a period of 30 days.

Security camera recordings are stored digitally on a secure server in an alarmed section of the premises, and constantly backed up remotely to a cloud service located within the USA. In the interests of security the exact off-site location cannot be revealed. Video doorbell recordings are stored digitally by Nest in the USA.

Audio

Audio recordings are taken when an individual interacts with the video doorbell installed to the front of the premises. Interaction includes entering the doorbell field of view, or by activating the device with the push button. Video recordings including audio taken by the video doorbell are retained for 30 days on a server located in the USA and then erased permanently.

Security cameras on the premises are equipped with microphones but the audio they detect is not recorded.

Access to footage

Any long term occupant of the premises has access to the security camera live footage at any time either when in or out of the premises.

Any occupant of the premises can use the video doorbell to hold a real time conversation with any person(s) present on the premises who has interacted with the doorbell in any way. This interaction will be recorded (including audio) and retained for 30 days and accessible to any occupant of the house.

Only specified individuals have access to recordings taken by the security cameras installed on the premises, these recordings can be securely accessed locally and remotely.

Access by neighbours

In the event that a neighbour requests access to footage in the interests of investigating a crime or event that has occurred elsewhere beyond the field of view of security cameras then we will go to reasonable lengths to assist in confirming or denying whether the security cameras and/or video doorbell have captured footage of practical use to that neighbour. In order to obtain that footage though the request must come from a relevant enforcement agency such as the police.

For example, a neighbour requests footage of someone fleeing a crime. We will endeavour to confirm or deny that we do have footage of that person fleeing the crime, the neighbour must then notify the police that we have footage who can then request it from us. The footage will not be released to the neighbour as it includes personally identifiable information about a third party who may or may not have committed a crime.

Law enforcement

In the event that recordings made by the security cameras or video doorbell capture a crime or event either on the premises or beyond the boundaries of the premises that is of interest to law enforcement or other enforcement agencies then this footage will be released to the relevant organisation upon a reasonable verbal or written request for that footage.

We may also pro-actively notify law enforcement of a crime or suspicion of a crime that has been captured by the security cameras and/or video doorbell.

Statutory rights

Under the General Data Protection Regulations (GDPR) / Data Protection Act 2018 (DPA) individuals who are identifiable in recorded footage have a right to access that footage and request it be erased.

Requests must be received in writing with sufficient information to identify the footage in question, i.e. date, time, and a photograph of yourself to match against. If other identifiable individuals are present in footage that you are requesting then the footage will not be released to you in order to preserve the rights of the other individuals in the footage. You can however still request the erasure of that footage.

An erasure request will not be processed if during the course of analysing footage, you or a person in the requested footage is committing an act for which the installation of the system was intended to detect and/or prevent such as a crime.

You can request access to or erasure of footage that you are identifiable in by writing delivered to the address.

Lawful basis for processing

Under the General Data Protection Regulations (GDPR) / Data Protection Act 2018 (DPA) we are processing your personal information as part of a legitimate interest to detect and prevent crime, detect and prevent risk to the safety and well being of the occupants of the premises, and to facilitate the delivery of goods and services to the address.

Data breach

In the extremely unlikely event that there is a data breach that may have exposed your personal information you will be notified as soon as practically possible using any information available to identify you. Due to the nature of the personal information gathered it may not be possible to notify every person affected by a breach. If necessary we will notify law enforcement and the Information Commissioner of a data breach.

Questions?

If you have questions about this policy or wish to exercise your statutory rights in relation to your personal information you can do so in person by writing delivered to the address.