Introduction
Cardiff Masonic Hall uses closed circuit television in order to provide a safe and secure environment for brethren, those who come to the premises, such as members, visitors, staff, contractors, suppliers and to protect the our property.
This policy sets out the use and management of the CCTV equipment and images in compliance with the Data Protection Act 2018.
CMH’s system records images only. There is no audio recording i.e. conversations are not recorded on CCTV.
Purposes of CCTV
The purposes our installing and using CCTV systems include:
- To assist in the prevention or detection of crime or malpractices.
- To assist in the identification and prosecution of offenders.
- To monitor the security of our property and premises.
- To ensure that health and safety procedures are being complied with.
- To assist with the identification of unauthorised actions or unsafe working practices.
- To promote productivity and efficiency.
Location of cameras
Twenty cameras are located at strategic points throughout the premises, the car park and the surrounds. We have positioned the cameras so that they only cover communal or public areas on our premises and they have been sited so that they provide clear images. No camera focuses on the interior of the temples or the toilets.
Appropriate signs are displayed so that employees, brethren and visitors are aware that we have CCTV.
Recording and retention of images
Images produced by the CCTV equipment are intended to be as clear as possible so that they are effective. Maintenance checks of the equipment are undertaken on a regular basis to ensure everything is working properly and that the equipment is producing high quality images.
Images may be recorded either in constant real time or only at certain times, as the needs of the business dictate.
As the recording system records digital images, any CCTV images that are held are deleted and overwritten on a recycling basis and, in any event, are not held for more than the period requested by Cardiff city police.
Images are erased or destroyed once the purpose of the recording is no longer relevant. In normal circumstances, this will be a period of about one month. However when necessary images may need to be retained for a longer period.
Access to and disclosure of images
Access to, and disclosure of, images recorded on CCTV is restricted. This ensures that the rights of individuals are retained. Images will only be disclosed in accordance with the purposes for which they were originally collected.
Disclosure of images to other third parties will only be made in accordance with the purposes for which the system is used and will be limited to:
- The police and other law enforcement agencies, where the images recorded could assist in the prevention or detection of a crime or the identification and prosecution of an offender or the identification of a victim or witness.
- Prosecution agencies, such as the Crown Prosecution Service.
- Relevant legal representatives.
- Directors of the company and those to whom they assign specific duties to investigate disciplinary and performance related matters.
- Individuals whose images have been recorded and retained, unless disclosure would prejudice the prevention or detection of crime or the apprehension or prosecution of offenders.
The Managing Director of the Company or his delegate is the only person who is permitted to authorise disclosure of images to external third parties such as law enforcement agencies.
All requests for disclosure and access to images will be documented, including the date of the disclosure, to whom the images have been provided and the reasons why they are required. If disclosure is denied, the reason will be recorded.
Individuals’ access rights
Under the Data Protection Act 2018, individuals have the right on request to receive a copy of the personal data that the Company holds about them, including CCTV images if they are recognisable from the image.
If you wish to access any CCTV images relating to you, you must make a written request to the compliance director and the Company reserves the right to charge you a fee for the supply of the images requested. Your request must include the date and approximate time when the images were recorded and the location of the particular CCTV camera, so that the images can be easily located and your identity can be established as the person in the images. The Company will endeavour to respond promptly and in any case within 30 days of receiving the request.
The Company will always check the identity of a person making the request before processing it.
The Compliance Director will first determine whether disclosure of your images will reveal third party information as you have no right to access CCTV images relating to other people. In this case, the images of third parties may need to be obscured if it would otherwise involve an unfair intrusion into their privacy.
If the Company is unable to comply with your request because access could prejudice the prevention or detection of crime or the apprehension or prosecution of offenders, you will be advised accordingly.
Covert recording
The Company will only undertake covert recording with the written authorisation of the Managing Director, or another director acting in his absence, where there is good cause to suspect that criminal activity or equivalent malpractice is taking, or is about to take, place and may inform the individuals concerned that the recording is taking place.
Covert monitoring will only take place for a limited and reasonable amount of time consistent with the objective of assisting in the prevention and detection of particular suspected criminal activity or equivalent malpractice. Once the specific investigation has been completed, covert monitoring will cease.
Information obtained through covert monitoring will only be used for the prevention or detection of criminal activity or equivalent malpractice. All other information collected in the course of covert monitoring will be deleted or destroyed unless it reveals information which the Company cannot reasonably be expected to ignore.
Staff training
The Company will ensure that all those handling CCTV images or recordings are trained in the operation and administration of the system and on the impact of the Data Protection Act 2018 with regard to that system.
Implementation
The Compliance Director is responsible for the implementation of this policy and the operation of the CCTV system. The company will periodically review of CCTV policy. Any complaints or enquiries about the operation of the Company’s CCTV system should be addressed to the board.
The Data Protection Officer is the Compliance Director who can be contacted by e-mailing to compliance@cardiffmasonichall.co.uk.