Key Publishing Group GDPR CCTV Privacy Notice

 

At Key Publishing Group we are committed to protecting and respecting your privacy.

This notice explains how we regulate the management, operation and use of the closed circuit television (CCTV) systems at our head office in Stamford, UK.

The system comprises of a number of fixed cameras located at strategic points throughout the premises.

Cameras are linked to two dedicated systems and access to these systems are restricted to the Head of Web and IT and Company Directors.

This notice should be read in conjunction with our General Privacy Notice which can be viewed at https://privacy.keypublishing.com/gdpr-privacy-notice.

Objectives of the CCTV Notice

The objectives of the use of CCTV are:

  • To help protect Key Publishing Ltd’s buildings and equipment
  • To support the Police in a bid to deter and detect crime
  • To assist in identifying, apprehending and potentially prosecuting offenders
  • To assist in investigation on health and safety related matters

Statement of intent

The CCTV Scheme has been registered with the Information Commissioner under the terms of the GDPR and will seek to comply with the requirements both of the

Data Protection Act and the Surveillance Commissioner’s Code of Practice. Key Publishing Group will treat the system and all information, documents and recordings obtained and used as data protected by the Act.

Cameras will be used to monitor activities within the buildings and grounds near the Entrances and exits to identify adverse activity occurring, anticipated or perceived.

Static cameras are positioned to ensure they do not focus on private homes, gardens and other areas of private property. At no time will a camera be directed to follow or track an individual.

Images will only be released for specific legitimate purposes including:

  • Use in the investigation of a specific crime and with the written authority of the police
  • Use in the investigation of a health and safety incident
  • Use in a complaint or grievance procedure

Images will never be released to the media for purposes of entertainment.

The planning and design has endeavoured to ensure that the CCTV Scheme will give maximum effectiveness and efficiency within available means, but it is not possible to guarantee that the system will cover or detect every single incident taking place in the areas of coverage. Warning signs, as required by the Code of Practice of the Information Commissioner, have been placed at all access routes to areas covered by the office’s CCTV system.

Operation of the System

The CCTV system will be administered and managed by Key Publishing Ltd in accordance with the values and objectives expressed in the code. The day to day management will be the delegated responsibility of the Head of Web and IT. The CCTV system will operate using motion sensors 24 hours each day, every day of the year, recording all activity.

Control and Liaison

The Head of It and Web will periodically check and confirm the efficiency of the system and that the equipment is properly recording and that cameras are functional.

Monitoring procedures

Camera surveillance may be maintained at all times and footage recorded using motion detection. Up to 30 days of footage is held on the system memory.

To maintain and preserve the integrity of any DVD or other storage medium used to store data from the hard drive and the facility to use them in any future proceedings, the following procedures for their use and retention will be strictly adhered to:

(a) Each storage medium must be identified by a unique reference number

(b) Before using, each medium must be cleared of any previous recording

(c) The Head of Web and IT responsible for recording and will register the date and time of the recording, including the storage reference number

(d) Each storage medium required for evidential purposes must be sealed, witnessed, signed by the appropriate officer, dated and stored securely in a safe. Images may be viewed by the Police for the prevention and detection of crime. A record will be maintained of any storage medium released to the Police or other authorised applicants. A register will be maintained for this purpose.

Viewing of footage by the Police or any external individual must be recorded in writing and entered in the register. Requests by the Police can only be authorised under the General Data Protection Regulation 2016. Should images be required as evidence, a copy may be released to the Police under the procedures described in this paragraph of this Code.

Images will only be released to the Police on the clear understanding that the storage medium remains the property of Key Publishing Ltd, and both it and images on it are to be treated in accordance with this code. Key Publishing Ltd also retains the right to refuse permission for the Police to pass to any other person the storage medium or any part of the images contained thereon.

The Police may require Key Publishing Ltd to retain any stored storage medium/images for possible use as evidence in the future. Such storage medium/images will be properly indexed and securely stored until the Police need them.

Applications received from outside bodies (e.g. solicitors) to view or release footage stored on storage mediums will be referred to the Compliance Officer. In these circumstances storage mediums/Images will normally be released where satisfactory documentary evidence is produced showing that they are required for legal proceedings, or in response to a Court Order.

Lawfulness of Processing

We process CCTV footage as to comply with our legal obligations with regards to Health and Safety as well as our Legitimate Interests in ensuring the safety and security of staff, visitors, plant and equipment.

Review of this Notice

We keep this notice under review. This Notice was last updated in May 2018.