This notice sets out how Calthorpe Group Management Limited of 76 Hagley Road, Edgbaston B16 8LU (we, us our) 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 sub-contract aspects of our CCTV system to Watch Systems Limited, and given the degree of control that they may have over our CCTV system, in certain circumstances they may also be a joint controller of any of your personal information recorded on our CCTV system. This privacy notice also covers Watch Systems Limited and so references to “we”, “us” and “our” are where appropriate also references to Watch Systems Limited of 49 Frederick Road, Edgbaston, Birmingham, B15 1HN.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws, but contact details of the person responsible for data protection matters 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, car registration details including make model and colour as well as other visual information about you which is recorded on our CCTV system.
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, reduction, detection and investigation of crime
- For evidence in any civil, disciplinary or criminal proceedings
- To assist in investigations
- For safety and security
- The monitoring, enforcement of and dealing with traffic related incidents
- Dealing with any queries, complaints or enquiries
- Retaining records
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 main 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 road 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 obtained using our CCTV system to anyone else except as set out above except where we are permitted or required to do so by law.
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 Economic Area 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 Economic Area if they are on holiday abroad outside of the UK or European Economic Area. 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 section 3 above may be located outside of the UK and European Economic Area. 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 31days 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 (which will be reviewed on a three monthly basis). 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.
6. Your rights in relation to your personal information
You have the following rights in relation to your personal information: (i) the right to be informed about how your personal information is being used; (ii) the right to access the personal information we hold about you; (iii) the right to request the correction of inaccurate personal information we hold about you; (iv) the right to request the erasure of your personal information in certain limited circumstances; (v) the right to restrict processing of your personal information where certain requirements are met; (vi) the right to object to the processing of your personal information; (vii) the right to request that we transfer elements of your data either to you or another service provider; (viii) the right to object to certain automated decision making processes using your personal information; and (iix) the right to withdraw any consent previously given by you.
You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not 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. For example we do not use automated decision making in relation to your personal data in our CCTV system. However some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights, though we do not rely on consent as a lawful basis for processing and direct marketing is not relevant to our CCTV system.
There is no legal, contractual or other requirement or obligation for you to provide our CCTV system with your personal information.
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.
We are here to help and would encourage you to contact us to resolve any complaint first. However 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 Economic Area if you are based outside the UK or bring a claim in the courts.
7. 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.
8. 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 Head of Legal. Please email email@example.com or write to us at: Head of Legal , Calthorpe Estates, 76 Hagley Road, Edgbaston, B16 8LU. You can use these contact details for both Calthorpe Group Management Limited and Watch Systems Limited.