Last Updated: March 2024 Version 1.0
As we are committed to the safety of our staff and visitors we use a closed-circuit television system (âCCTVâ) and video and audio recording at our sites. The purpose of this document is to set out how the CCTV system, and video and audio recording will be managed and used, and to inform individuals whose personal data may be captured, about how and why that personal data may be processed by Creature Comforts.
Creature Comforts Pets Limited (âCompanyâ, âweâ, âusâ, or âourâ), are the data controllers of personal information collected about you. This means that we are responsible for deciding how we hold and use personal information about you and that we are required to notify you of the information contained in this Notice. It is important that you read this Notice so that you are aware of how and why we are using your personal information and how we will treat it.
We are aware that images of recognisable individuals, such as staff and site visitors, captured by the CCTV system, or video and audio recording constitute âpersonal dataâ, use of which is governed by data protection law. We will ensure that the use of the CCTV system and video and audio recording and the personal data that they capture complies with the law.
This document has been drafted in accordance with the Information Commissionerâs Office (ICO) CCTV Code of Practice and the Home Office Surveillance Camera Code of Practice. Copies of these codes can be found at www.ico.org.uk and https://www.gov.uk/government/publications/surveillance-camera-code-of-practice respectively.
The legal basis for the Companyâs use of any personal data which is captured by the CCTV system, or video and audio recordings is that the processing is necessary for the legitimate interests set out above (provided that those interests are not overridden by individualsâ rights and interests). We may also need to use this personal data in order to establish, exercise or defend against legal claims.
CCTV cameras are located at strategic points on our sites, primarily access points, such as door entrances to the sites, in waiting areas and in consultation rooms.
Signs are displayed prominently around the sites to inform staff and visitors that CCTV cameras are in operation and who to contact for further information.
The cameras are in operation 24 hours a day, 7 days a week.
Creature Comforts manages all the footage from the CCTV cameras. We also use a third party provider who will regularly check and confirm the efficiency of the system, including that the equipment is properly recording, that the cameras are functional, that the time and date are correct and that that footage is being deleted or retained in accordance with this document.
The CCTV system is regularly maintained in accordance with the manufacturerâs instructions.
We have put in place appropriate security measures to help prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Access to recorded CCTV footage and any video and audio recordings is restricted to a limited number of staff as authorised by our Data Protection Officer from time to time (âAuthorised Personsâ) and all requests for disclosure of CCTV footage must be submitted to one of these Authorised Persons.
CCTV footage and video and audio recordings may only be accessed or disclosed to the extent necessary in order to deal with an incident which falls within the purpose identified above or in order to respond to a request made by an individual under the law. CCTV footage and any video and audio recordings will not be accessed or used for any other purpose.
External disclosure of CCTV footage will usually not be permitted other than to law enforcement agencies or to regulators, or in order to comply with a court order.
All staff who may be involved in the management or operation of the CCTV system will be trained in how to comply with this document and to ensure that the system is used in accordance with the law.
We may share your personal information with the third parties set out below for the purposes described above:
We require all service providers that we share your personal information with to respect the privacy and security of your personal information and to treat it in accordance with the law.
We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
Most of the personal information we collect about you is based in the United Kingdom or in some cases, a service provider or their sub-processor may be based in the European Union (EU) and so, they are required to comply with European data protection law. On occasion, we may appoint a third-party service provider whose operation or a server or sub-processor may be based outside of the EU.
The images captured by the CCTV System will not be stored for any longer than is required in order to achieve the purposes identified above. CCTV footage will automatically be deleted on a 30-day rolling basis, unless specific images are required in order to deal with an incident or in order to respond to a request by an individual made under the law.
Data protection laws provide you with the following rights where we are processing your personal information to:
You will not have to pay a fee to access your personal information (or to exercise any of the other rights above). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
We reserve the right to update this Notice at any time, and we will provide you with a new Notice when we make any material updates.
If you wish to make an individual request, or you have any queries, please contact us by email, or post (details below):
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), or the equivalent regulatory authority in your country. However, we would like to deal with your concerns before you approach the ICO (or other regulator) so please contact us in the first instance.
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