CCTV Privacy Policy

This notice explains how we comply with the law on data protection and what your rights are in relation to our use of CCTV.

References to “we”, “our” or “us” in this privacy notice are to FreelanderSpecialist.com. Details of our main trading entity is as follows: FreelanderSpecialist.com, Glebewood Lodge, Brandon Road, Methwold, Norfolk, IP26 4RH. FreelanderSpecialist.com is a trading name operated as a partnership by Sue Maddock and Nobert Ngwenya. Our Data Protection Representative has overall responsibility for data protection compliance in our organisation. If you have any questions about this privacy notice or how we handle your personal information, use the contact details set out in the “Contacting us” section at the end of this privacy notice.

For the purposes of data protection, FreelanderSpecialist.com is acting as Controller in its processing of any personal data in its CCTV data.

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 and other visual information about you which is recorded on our CCTV system. We may also collect personal information about you if you, your representative or a person authorised by you visits our premises.

2. What do we do with your personal CCTV information?

As the data controller we will collect personal information on our CCTV system and use it for the following purposes:

For the prevention and detection of crime
For evidence in any civil or criminal legal proceedings
To assist in investigations
For safety and security

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 legal basis for processing your personal information.

We may anonymize 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 anonymized information for any other purposes.

3. Who we share your personal CCTV information with

We share your personal information with the following parties:

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 may 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 may 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 to anyone else except as set out above, or as is detailed in our Privacy Policy, unless we have your consent, or we are legally obliged to do so. We do not sell your data.

4. Transferring your personal CCTV information internationally

The personal information we collect about you is transferred as follows:

We use Netgear (Arlo) to help us administer our CCTV system. As such, your video information may be transferred outside the EEA, including but not limited to the United States. To keep your information secure, Netgear utilises AES and TLS encryption (more details can be found on their website) together with password protected access controls. Contractual protections for the transfer of Personal Information to third parties, such as the European Commission’s Standard Contractual Clauses are also used (full details of these and other protections are contained in Netgear’s Privacy Policy).
Our partners and other individuals working for us may in limited circumstances access personal information outside of the UK and European Union if they are on holiday abroad outside of the UK or European Union. 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 Union. 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.

How long do we keep your personal CCTV information for

We will keep your personal information for up to approximately 7 days after the recording was made. After this time the recording stored on the Netgear Cloud 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. 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.

Your rights in relation to your personal information

You have the following rights in relation to your personal information:

the right to be informed about how your personal information is being used;
the right to access the personal information we hold about you;
the right to request the correction of inaccurate personal information we hold about you;
the right to request the erasure of your personal information in certain limited circumstances;
the right to restrict processing of your personal information where certain requirements are met;
the right to object to the processing of your personal information;
the right to request that we transfer elements of your data either to you or another service provider;
the right to object to certain automated decision-making processes using your personal information.

You should note that some of these rights may not always 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.

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.

If you are unhappy with the way we are using your personal information you can also complain to the Information Commissioner’s Office. However, we are here to help and would encourage you to contact us first to help resolve your issue.

6. 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.

7. 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 Data Protection Representative. Please email Sue Maddock at privacy@freelanderspecialist.com or write to us at FreelanderSpecialist.com, Glebewood Lodge, Brandon Road, Methwold, Norfolk, IP26 4RH.

This document was created by Data Compliance Specialists on behalf of FreelanderSpecialist.com, 5th Dec, 2018.