1.
General Information
1A. The
installation of CCTV surveillance has been completed to deter
and reduce vandalism, fly tipping, theft, littering and
anti-social behaviour in and around the area of Whiteloch Farm,
Farmhouse & the Angling Facilities.
1B. The CCTV system is a standalone fixed system with 9 cameras
recording video images.
1C.
Registration with the
ico,
(Information Commissioner’s Office) in accordance with legal
requirements has been carried out and complies with the GDPR
/ Data
Protection Act 2018. This policy will be revisited annually and
updated when required to comply with any new legislation
introduced. The reference number for registration is ZB283006.
1D. Farm CCTV operators comply with
ico,
Code of Practice and are aware of their responsibilities in
compliance with GDPR regulations.
1E. Each person having access to the system will use it in a
responsible manner without disclosing images to unauthorised
persons.
2.
Justification for Installation
2A.
The camera system has been installed for the following reasons:
To
protect the assets, buildings and properties including their
contents in the immediate area 24 hours per day.
To
improve the safety and security of all persons using the paths,
as well as anglers and other authorised visitors vehicles, their
possessions & contents.
To
support the Police in an effort to detect and deter criminal
activities and to assist in apprehending, identifying and
prosecuting offenders.
The CCTV images
recorded will only be used for the prevention, reduction and
identification of those committing crimes whilst present on the
locations noted above.
The camera system
will help provide a safe and secure environment for members of
the public, farm visitors, residents, anglers and farm workers.
3.
Camera Locations & coverage.
3A. Whiteloch Farm
Buildings, Whiteloch Farmhouse, Whiteloch Pier Area, Fingask
Boathouse (Inside & Out), Fingask Pier, Car Parks, Paths and
Roads in close proximity.
3B. The images recorded are from 9 cameras sited to record
activities in and around the above locations.
3C. The privacy expectations of persons present will not be
compromised as images will only be viewed where justified if an
incident occurs at locations as per description in item 2.A .
4.
Covert Surveillance.
4A.The system has
no cameras which will be used to engage in covert surveillance.
5.
Public Notification
5A.
The CCTV GDPR Policy will be available to view by the general
public on the Angling Association website http://www.brdaa.co.uk/
on Facebook Angling Association site, (Members only) and by
request to Whiteloch Farm.
5B. Signage is clearly located in areas where cameras are
operating with contact details on larger signs (4).
5C. The cameras in use are all clearly visible by persons
present in the areas under observation.
6.
Images Retention and Storage
6A.
The CCTV images are stored for a period of 30 days and are then
automatically deleted from the system.
6B. If images are
requested by the Police they will then be supplied as a section
of recorded images with date / time verification. These images
may be held where Police request identification of issue in
association with investigation or prosecution.
6C. Images recorded are transmitted by cable or WIFI to remote
recording units (2) which are both securely located. Access to
these units and the images stored therein is securely restricted
to 3 persons.
6D. Each person represents the interests of the Farm, Angling
Association or Farmhouse but collectively all 3 can access
images if or when there is a justifiable reason to do so.
6E. The viewing of images will normally be instigated by the
reporting or discovery of an incident
which has
occurred and may have been recorded by the cameras present. The
vast majority of images recorded will not be viewed at all and
will be deleted at the end of a 30 day period unless there is
valid reason to keep them. Images that are viewed will not be
released to other persons unless they qualify as per following
qualifying descriptions contained in notes 7 & 8.
7. Access.
7A. At certain
times images may be viewed where identification of persons,
vehicles, times etc. are justified to achieve the objectives of
CCTV installation as listed in 2.0 . At these times the
observers of images will have their access and comments logged
and their authority to view images verified.
7B. On receipt of a disclosure request then details of the
disclosure must be recorded and records kept.
Information
required includes,
but is not limited to,
the following.
Date,
time, data subject of request.·
Name of person who
is making request.·
Organisation
they represent.·
Verified authority
to make request.·
Reason why request
was made (may not always be required).·
Method
of providing data e.g. by recorded video disc, by observation of
recorded data.
7C. Where relevant on request the recorded images may be
accessed or viewed by;·
The Police or their
authorised agents where a crime or suspected crime is being
investigated on the request of the operators of CCTV or has been
reported by a data subject.·
The
Police where investigating a crime or suspected crime that has
been reported to them as taking place at this location.·
Where a complaint
of illegal or anti-social behaviour is being investigated by the
Police as occurring within the area covered by the CCTV
coverage.·
The HSE (Health and
Safety Executive) where children are involved.·
Police or CCTV
operators to assist in recognition and identification of
juveniles so that unacceptable behaviour can be reported to
their parents, or guardians. ·
Data
subjects and their legal representatives pursuant to a
legitimate SAR (Subject Access Request).·
Where
individuals or their legal representatives request access
subject to a court order.·
Insurance company
where they are in pursuit of evidence to substantiate a claim
where damage has occurred to insured property at this location.
8. (
SAR ) Subject Access Requests
(Recorded images of
yourself)
8A.
The Data Protection Act gives individuals the right to request
access of CCTV footage which relates to themselves but not to
others unless approved by legitimate bodies as covered in
section 7A to 7C.
8B. Whiteloch Farm operators of CCTV will respond to these
requests within 30 days of receipt of request.Required
information will include location, date, time of presence,
subject data / description and name of person making request.
Provided information will be recorded.
8C. Access to view requested images may be denied where they
might prejudice an authorised active investigation or the legal
rights of third parties.
8D. Where data is supplied in the form of either a still
picture, a series of pictures, a video or disc format then
details of other parties may be obscured if not relevant to
request. At time of release of this data then details of
authorised viewing body, reason for request and name of person
making request will be recorded.
8E. Where 3rd parties are present their images may
be obscured prior to release in any form.
8F.
Where a request to view data images recorded concerns other
persons present to prove criminal activity, vandalism,
anti-social behaviour etc. then the incident may require to be
reported to the Police before images are permitted to be
accessed.
9.
Complaints Procedure.
In first instance
complaints should be directed to Whiteloch Farm. PH10 6QN.
All complaints will be investigated and discussed, if resolution
of the complaint is not achieved to the complainer’s
satisfaction then they are encouraged to contact the
ico, (Information
Commissioner’s Office) to discuss the matter as required.
Helpline Number
03031231113
Website
https://www.ico.org.uk
10. Review.
10.A The policy will
be reviewed ;
·
On an annual basis.
·
Where there have
been changes to updated legislation .
·
If there is
requirement to review through changes to system or its
controllers.
·
After an investigation or a SAR
has been conducted to test the capability and suitability of the
system and its requirements.
·
Where a complaint has been made
whether upheld or not.
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Policy Creation date February 2022,. Name… For P. Lock (BRDAA
Sec.) Changes N.
Policy Review dates………………………………. Name……………………………………………………….
Changes Y / N.
Details;
