CCTV Privacy Notice
Version 1 | JANUARY 2020
This notice sets out how Winstones Ice cream Limited, head office Greenacres, Rodborough Common, Stroud, Gloucestershire GL5 5BX, uses your personal information which may be recorded on our CCTV system. This notice explains how we comply with the law on data protection and what your rights are and for the purposes of data protection we will be the controller of any of your personal information recorded on our CCTV system.
We have appointed Data Protection Officers to oversee our compliance with data protection laws, and contact details are set out in the “Contacting us” section at the end of this privacy notice.
1. What information may we hold/process that will relate to you?
We may collect from you video recordings and still pictures which feature you if you are in the field of vision of any of our CCTV system. This personal information may include your activities, your face, vehicle registration details and other visual information about you which is recorded on our CCTV system.
We may also collect personal information about you if you, your representative or a person authorised by you contacts us regarding an enquiry, complaint or other communication.
2. What do we do with your personal information?
As the data controller we will collect personal information on our CCTV system and use it for the following purposes:
• For the prevention and detection of crime
• For evidence in any civil or criminal legal proceedings
• To assist in investigations
• For safety and security
• Dealing with any queries, complaints or enquiries
• Retaining records
• We may also use in disciplinary hearings depending on circumstances
As well as being the purposes for which we use your personal information, all of the above are also legitimate reasons for us to use and store personal information relating to you which is captured on our CCTV system and legitimate interests is our legal basis for processing your personal information.
We may anonymise any of the personal information we hold on our CCTV system (so that it does not directly identify you, for example by obscuring your face) and it therefore ceases to be your personal information. We may use this anonymised information for any other purposes.
3. Who we share your personal information with
We share your personal information with the following parties:
• Suppliers and service providers: to manage and operate the CCTV system as our data processor.
• The police and other law enforcement agencies: to carry out policing, assist investigations, trace missing people and investigate alleged criminal activities.
• The security services: where relevant for matters of national security.
• People who have been injured, attacked or had property damaged or stolen and their insurance providers: to assist them with any criminal or civil investigations or legal proceedings.
• People who have been involved in Workplace traffic accidents and their insurance providers: to assist with insurance claims, legal claims and investigations.
• Private and other investigators: to aid their investigations.
• Any relevant regulators: where we are required to do so by law or to assist with their investigations or initiatives, and this includes but is not limited to the Information Commissioner’s Office.
We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell your data.
4. Transferring your personal information internationally
The personal information we collect about you is not transferred to or stored in countries outside of the UK or European Union except as set out in this section.
Our directors and other individuals working for us may in limited circumstances access personal information outside of the UK and European Union if they are on holiday abroad outside of the UK or European Union. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK.
In limited circumstances the people to whom we may disclose personal information from our CCTV system as mentioned in the section “Who we share your personal information with” above may be located outside of the UK and European Union. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.
If you require more details on the arrangements for any of the above then please contact us using the details in the “Contacting us” section below.
5. How long do we keep your personal information for
We will keep your personal information for up to approximately 30 days after the recording was made. After this time the recording stored on the hard drive of our CCTV system will usually be overwritten.
However if we receive an enquiry about a particular recording on our CCTV we will generally then retain that part of the recording until it is no longer required. This period can vary as it will depend upon the circumstances of the particular case, but for criminal or civil legal proceedings this could mean that the personal information is retained until after the legal case and any appeals have been concluded, which may be many years. As soon as it is no longer required we will then delete the personal information.
Your rights in relation to your personal information
You have the following rights in relation to your personal information:
• the right to be informed about how your personal information is being used;
• the right to access the personal information we hold about you;
• the right to request the correction of inaccurate personal information we hold about you;
• the right to request the erasure of your personal information in certain limited circumstances;
• the right to restrict processing of your personal information where certain requirements are met;
• the right to object to the processing of your personal information;
• the right to request that we transfer elements of your data either to you or another service provider;
• the right to object to certain automated decision-making processes using your personal information.
You should note that some of these rights may not always apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored in our CCTV system and also other of these rights will not be relevant to personal information stored in a CCTV system.
There is no legal, contractual or other requirement or obligation for you to provide our CCTV system with your personal information.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.
To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.
If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator in the European Union if you are based outside the UK or bring a claim in the courts. However we are here to help and would encourage you to contact us to resolve your complaint first.
6. Changes to this notice
We may update this privacy notice from time to time. You are encouraged to regularly check for any updated version of this privacy notice.
7. Contacting us
In the event of any query or complaint in connection with the personal information we hold about you or if you would like more information about or to exercise your rights, you can contact our Data Protection Officers. Please email firstname.lastname@example.org or write to us at: Data Officer, Winstones Ice Cream Ltd, Greenacres, Rodborough Common, Stroud, Gloucestershire, GL5 5BX
A notice of the type below should appear in prominent locations around the perimeter and within the area under CCTV surveillance so that any individual coming into and moving around within the CCTV area has the opportunity to see the signs. The image is an example, only the wording is specific. The notice should be clearly visible and legible bearing in mind the different individuals in the area, e.g. pedestrians or car drivers. Careful consideration will be required if there is also audio recording, in which case the sign and notice would both need to changed.
The controller of the images and personal information captured using the CCTV covered by this notice is Winstones Ice Cream Ltd, Greenacres, Rodborough Common, Stroud, Gloucestershire, GL5 5BX
The images and personal information are captured using our CCTV system for the purpose of security, crime detection, public safety and other legitimate reasons set out in our privacy notice which can be found online at www.winstonesicecream. co.uk or copies are available upon request.
Please contact our Data Protection Officer by email at email@example.com or by post at Winstones Ice Cream Ltd, Greenacres, Rodborough Common, Stroud, Gloucestershire, GL5 5BX if you would like a copy of this privacy notice sent to you, you have any queries or wish to exercise any of your rights in relation to your personal data. Please see the privacy notice for further details.