CCTV & Data Retention Policies
Introduction
Community Aid Thrift Shop (C.A.T.S) uses closed circuit television (CCTV) images to protect it property and to provide a safe and secure environment for employees and customers at a business premise. This policy sets out the details of how the C.A.T.S will collect, use and store CCTV images. The (C.A.T.S) CCTV records only images. There is no audio recording i.e. conversations are not recorded on CCTV. The System is wholly owned by the (C.A.T.S).
Purposes of CCTV
The (C.A.T.S) has carried out a data protection impact assessment and on the basis of its findings it considers it necessary and proportionate to install and use a CCTV system. The data collected from the system will assist in:
· Prevention or detection of crime or equivalent malpractice (mainly illegal dumping
outside (C.A.T.S) premises)
To increase safety of staff, customers and visitors
· Monitoring of the security of the (C.A.T.S) business premises.
· Ensuring that health and safety rules and Company procedures are being complied with.
Location of cameras
Cameras are located at strategic points throughout the (C.A.T.S) business premises, principally at the till area and the main entrance (2 cameras, 1 pointing to the street view other to the window display area), remaining 2 cameras are located upstairs mainly monitoring access to (C.A.T.S) mini office & storage area). The (C.A.T.S) has positioned the cameras so that they only cover communal or public areas on the (C.A.T.S) business premises and they have been sited so that they provide clear images. No camera focuses, or will focus, on toilets or changing rooms. All cameras (with the exception of any that may be temporarily set up for covert recording) are also clearly visible.
Appropriate signs are prominently displayed so that employees, clients, customers and other visitors are aware they are entering an area covered by 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 for the purposes set out above. Maintenance checks of the equipment are undertaken on a regular basis to ensure it is working properly and that the media is producing high quality images. Images may be recorded either in constant real-time (24 hours a day throughout the year), or only at certain times, as the needs of the business dictate. As the recording system records digital images, indoor CCTV images that are held on the hard drive of a PC are deleted and overwritten on a recycling basis (10 days) and, in any event, once the hard drive has reached the end of its use, it will be erased prior to disposal.
Images that are stored on the App cloud for the outdoor camera are erased or destroyed once the purpose of the recording is no longer relevant. In normal circumstances, this will be a period of 12 months. However, where a law enforcement agency is investigating a crime, 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 (only the owner of the (C.A.T.S) has access to both CCTV systems). This ensures that the rights of individuals are retained. Images can only be disclosed in accordance with the purposes for which they were originally collected.
The images that are filmed are recorded centrally and held in a secure location. Access to recorded images is restricted to the operators of the CCTV system (Agata Prinii). Viewing of recorded images will take place in a restricted area to which other employees will not have access when viewing is occurring. If media on which images are recorded are removed for viewing purposes, this will be documented.
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.
· Relevant legal representatives.
· 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 owner of the (C.A.T.S) (or another senior staff member acting in their absence) is the only person who is permitted to authorize 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 Irish data protection laws, including the General Data Protection Regulation (GDPR), 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 (C.A.T.S) owner Agata Prinii. This can be done by using this email address community.aid.gort@gmail.com. (C.A.T.S) will usually not make a charge for such a request, but we may charge a reasonable fee if you make a request which is manifestly unfounded or excessive, or is repetitive. 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. (C.A.T.S) will usually respond promptly and in any case within one month of receiving a request.
However, where a request is complex or numerous the Company may extend the one month to respond by a further two months.
(C.A.T.S) owner Agata Prinii will always 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 (C.A.T.S) 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 is aware that covert recording can only be done in exceptional circumstances for example where (C.A.T.S) suspects criminal activity taking place. On this basis the (C.A.T.S) will only undertake covert monitoring if it has carried out a data protection impact assessment which has addressed the following:
· the purpose of the covert recording;
· the necessity and proportionality of the covert recording;
· the risks to the privacy rights of the individual(s) affected by the covert recording;
· the time parameters for conducting the covert recording
· the safeguards and/or security measures that need to be put in place to ensure the
covert recording is conducted in accordance with the data protection laws, including the GDPR.
If after undertaking the data impact assessment the (C.A.T.S) considers there is a proportionate risk of criminal activity, or equivalent malpractice taking place or about to take place, and if informing the individuals concerned that the recording is taking place would seriously prejudice its prevention or detection, the (C.A.T.S) will covertly record the suspected individual(s). In doing this the (C.A.T.S) will rely on the protection of its own legitimate interests as the lawful and justifiable legal basis for carrying out the covert recording.
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 (C.A.T.S) cannot reasonably be expected to ignore.
Staff training
(C.A.T.S) will ensure that all employees handling CCTV images or recordings are trained in the operation and administration of the CCTV system and on the impact of the laws regulating data protection and privacy with regard to that system.
Implementation
The (C.A.T.S) owner Agata Prinii is responsible for the implementation of and compliance with this policy and the operation of the CCTV system and they will conduct a regular review of the (C.A.T.S) use and processing of CCTV images and ensure that at all times it remains compliant with the laws regulating data protection and privacy. Any complaints or enquiries about the operation of the (C.A.T.S) CCTV system should be addressed to Agata Prinii.
Data Protection
(C.A.T.S) will process the personal data collected in connection with the operation of the CCTV policy in accordance with its data protection policy and any internal privacy notices in force at the relevant time. Inappropriate access or disclosure of this data will constitute a data breach and should be reported immediately to the (C.A.T.S) owner Agata Prinii in accordance with the (C.A.T.S) data protection policy. Reported data breaches will be investigated and may lead to sanctions under the (C.A.T.S) disciplinary procedure.
Copies of the Policy will be available to the public from the Company Office and on its official website.
Community aid thrift Shop , Church street, Gort, Co. Gawlay H91A586
Tel:0831755230
VAT Number: IE 2567533S
DATA RETENTION POLICY
Community Aid Thrift Shop (C.A.T.S) seeks to ensure that it retains only data necessary to effectively conduct itsprogram activities and work in fulfillment of its mission.
The need to retain data varies widely with the type of data and the purpose for which it was collected. (C.A.T.S) strives to ensure that data is only retained for the period
necessary to fulfill the purpose for which it was collected and is fully deleted when no longer required. This policy sets forth (C.A.T.S)’s guidelines on data retention and is to be consistently applied throughout the organization.
Scope
This policy covers all data collected by (C.A.T.S) and stored on (C.A.T.S) owned or leased systems and media, regardless of location. It applies to both data collected and held electronically (including photographs, video and audio recordings) and data that is collected and held as hard copy or paper files. The need to retain certain information may be mandated by federal or local law, federal regulations and legitimate business purposes, as well as the EU General Data Protection Regulation (GDPR).
Reasons for Data Retention
(C.A.T.S) retains only that data that is necessary to effectively conduct its program activities,
fulfill its mission and comply with applicable laws and regulations.
Reasons for data retention include:
• Providing an ongoing service to the data subject (e.g. sending a newsletter,
publication or ongoing program updates to an individual, ongoing training or participation in (C.A.T.S)’s programs, processing of employee payroll and other benefits)
• Compliance with applicable laws and regulations associated with financial and programmatic
reporting by (C.A.T.S) to its funding agencies and otherdonors
• Compliance with applicable labor, tax and immigration laws
• Other regulatory requirements
• Security incident or other investigation
• Intellectual property preservation
• Litigation
Data Duplication
(C.A.T.S) seeks to avoid duplication in data storage whenever possible, though there may be instances in which for programmatic or other business reasons it is necessary for data to be held in more than one place. This policy applies to all data in (C.A.T.S)’s possession, including duplicate copies of data.
Retention Requirements
(C.A.T.S) has set the following guidelines for retaining all personal data as defined in the Institute’s data privacy policy.
• Website visitor data will be retained as long as necessary to provide the service
requested/initiated through the (C.A.T.S) website.
• Contributor data will be retained for the year in which the individual has contributed and then for 3 months after the date of the last contribution. Financial information will not be retained longer than is necessary to process a single transaction.
• Event participant data will be retained for the period of the event, including any follow up activities, such as the distribution of reports, plus a period of 3 months
• Program participant data (including sign in sheets) will be retained for the duration of the grant agreement that financed the program plus any additional time required under the terms of the grant agreement.
• Personal data of subgrantees, subcontractors and vendors will be kept for the duration of the contract or agreement.
• Employee data will be held for the duration of employment and then 6 months after the last day of employment.
• Data associated with employee wages, leave and pension shall be held for the period of employment plus 6 months which shall be kept for 6 months.
• Recruitment data, including interview notes of unsuccessful applicants, will be held for 1 month after the closing of the position recruitment process.
• Data associated with tax payments (including payroll, corporate and VAT) will be held for 6 months.
Data Destruction
Data destruction ensures that (C.A.T.S) manages the data it controls and processes it in an efficient and responsible manner. When the retention period for the data as outlined above expires, (C.A.T.S) will actively destroy the data covered by this policy. If an individual believes that there exists a legitimate business reason why certain data should not be destroyed at the end of a retention period, he or she should identify this data to his/her supervisor and provide information as to why the data should not be destroyed. Any exceptions to this data retention policy must be approved by [ (C.A.T.S)’s data protection offer in consultation with legal counsel.
In rare circumstances, a litigation hold may be issued by legal counsel prohibiting the destruction of certain documents. A litigation hold remains in effect until released by legal counsel and prohibits the destruction of data subject to the hold.