1. This Policy Outlines:

• Why and how CCTV is used in Kings Court
• How data recorded by CCTV is processed to ensure compliance with legislation.
• How to make a subject access request (SAR) in respect of personal data captured.

2. Introduction

• The Kings Court Management Company Limited (KCML) Board recognise that CCTV has a legitimate role to play in helping maintain a safe and secure environment for lessees, residents, visitors, and contractors. It is acknowledged that this may raise concerns about the effect on individuals and their privacy. This policy is intended to address such concerns. Images recorded by CCTV are personal data and will be processed in accordance with data protection laws.
• Prior to installation, an assessment has been undertaken to ensure a balance of the need for CCTV and related security with the impact on personal privacy.
• This policy has due regard to the Data Protection Act (DPA) 2018 and the General Data Protection Regulation (GDPR).
• The Data Protection Officer (DPO) has overall responsibility for data protection compliance.
• Signage is displayed in each location where personal data is captured using CCTV.
• CCTV operates twenty-four hours a day, seven days a week.
• The CCTV data and images are under the control of the KCML Board and their Managing Agents (Bartholomews) who are committed to transparency about how data is collected and used and to meeting data protection obligations.
• Information captured by CCTV will be viewed only by authorised personnel.
• If you have any queries on this policy or how your personal information is managed, you should contact the DPO by email.

3. Personnel

• The Data Controller (DC) is the Board of Kings Court Management Company Limited.
• The Data Protection Officer (DPO) is The Chairman who can be contacted at enquiries@kcml.co.uk.

4. CCTV – Purpose

• To support in the safety of Lessees, Tenants, Visitors and Contractors
• To enhance building, and physical asset, security.
• To increase the security within, and outside, the Bike Cage and Car Parking area (commonly known as the under croft)
• To prevent and detect crimes.
• To identify, apprehend, and prosecute offenders.
• To support with queries, complaints, or enquiries.
• To enhance the security of our, and your, property and that of our contractors.
• To ensure that our policies are being adhered to.
• To assist in any investigation.
• To monitor the security of our premises.
• To monitor adherence to health & safety and fire provisions.
• The above are legitimate reasons for using and storing personal data. Images captured by CCTV may be monitored and reviewed. They will be kept for up to thirty-one days after the recording was made. After this time, the images will usually be overwritten on the storage facility.
• The KCML Board will ensure that the use of CCTV cameras is reviewed periodically to ensure that their use remains necessary and appropriate for Kings Court.

5. CCTV – Monitoring & Recording

• Images are stored electronically within Kings Court. The equipment in which the images are stored are physically secured and are accessible to designated individuals only.
• All recorded images remain the property of KCML.

6. CCTV – Your Rights

• It is a criminal offence to misuse CCTV.
• You have the following rights in relation to your personal information:
  
  • to access the personal information held.
  • to be informed how your personal data is being used.
  • to request the correction of inaccurate personal information held.
  • to request the erasure of your personal information in certain limited circumstances.
  • to restrict processing of your personal information where certain requirements are met.
  • to object to the processing of your personal information.
  • to request that elements of your data are transferred either to you or another person.

Note that a right to object may not always apply. 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 them, contact the DPO enquiries@kcml.co.uk. If you are unhappy with the way your personal information is used, you can contact the ICO.

7. CCTV – Application for Disclosure of Images – Right of Access.

• You have the right to view any personal data recorded by our CCTV (see 6 above).
• It may take time to redact the personal data of anyone else on the recordings.
• We may be able to supply you with a copy of the recording unless that is not technically possible or to do so puts us to disproportionate effort. This is known as subject access request (SAR).
• SAR’s must be made in accordance with the guidance issued by the Information Commissioner’s Office (ICO) www.ico.org.uk/for-the-public/. All requests must be made to the DPO. A failure to follow this process may result in the request being rejected.
• To locate relevant footage, all requests for copies of CCTV images must include the reason for the request, date and time of the recording, the location where the footage was captured and the individual’s name.
• A record of all CCTV footage disclosures will be made itemising the date, time, camera, requestor, authoriser and the reason for disclosure.

8. CCTV – Third party access

• Our CCTV system may be maintained by a third-party contractor who may have access to the data on a periodic basis when the system is subject to maintenance. The contractor will not remove any data off site during the maintenance.
• Data stored may be shared with third parties, for example Police, Insurers etc, in the event of an incident. Information shared is limited to that required for the purpose of dealing with the investigation or claim and will conform to current legislation.

9. CCTV – Retention of Images

• Unless required for evidential purposes, the investigation of an offence or as required by law, images will be retained for a maximum of thirty-one days from the date of recording. At this point images will be automatically overwritten.
• Images will be retained for an extended period if an incident has occurred which has led to the image being used to progress a prosecution, in which case the images will be retained for as long as the prosecution is in progress plus up to a further ten years.

10. CCTV – Changes to Policy

• This Privacy Policy may occasionally be amended.  You are encouraged to check for updates regularly.