Data Protection – CCTV Privacy notice

This notice sets out how Blick Rothenberg Limited of 16 Great Queen Street, Covent Garden, London, WC2B 5AH (we, us, our) uses your personal data 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 laws we will be the controller of any of your personal data recorded on our CCTV system.

We have appointed a Data Protection Officer to oversee our compliance with data protection laws. Contact details 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 data 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 data about you if you, your representative or a person authorised by you contacts us regarding an enquiry, complaint or other communication.

2. What do we do with your personal data?
As the data controller we will collect personal data 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
• Dealing with any queries, complaints or enquiries
• Retaining records

As well as being the purposes for which we use your personal data, all of the above are also legitimate reasons for us to use and store personal data relating to you which is captured on our CCTV system and legitimate interests is our legal basis for processing your personal data.

We may anonymise any of the personal data 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 data. We may use this anonymised information for any other purposes.

3. Who we share your personal data with
We share your personal data with the following parties:

•  Suppliers and service providers: to manage and operate the CCTV system as our data processor.
• Joint controllers: who may jointly operate and maintain the CCTV system with us.
• 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 data to anyone else except as set out above unless we have your consent or we are legally obliged to do so.

4. Transferring your personal data internationally
The personal data we collect about you is not transferred to or stored in countries outside of the UK or European Union except as set out in this section.

Our directors and other individuals working for us may in limited circumstances access personal data 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 data 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 data 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 data for
We will retain your personal data for 35 days after the recording was made. After this time the recording stored on the hard drive of our CCTV system will be automatically erased. 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 data 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 data.

Your rights in relation to your personal data
You have the following rights in relation to your personal data:

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

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 data recorded and stored in our CCTV system and also other of these rights will not be relevant to personal data stored in a CCTV system.

There is no legal, contractual or other requirement or obligation for you to provide our CCTV system with your personal data.

More information about your legal rights can be found on the Information Commissioner’s website .

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 data you can also complain to the UK Information Commissioner’s Office or bring a claim in the courts. However we are here to help and would encourage you to contact us to resolve your complaint first.

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 data we hold about you or if you would like more information about or to exercise your rights, you can contact our Data Protection Officer. Please email DPO@azets.co.uk or write to us at:

The Data Protection Officer
Azets Opco Limited
2nd Floor, Regis House
45 King William Street
London EC4R 9AN
United Kingdom

Blick Rothenberg Limited, 16 Great Queen Street, Covent Garden, London, WC2B 5AH

Registered number 10238654