Cork Chamber CCTV Policy
This Policy sets out the basic conditions of use for Closed Circuit Television (CCTV) system by Cork Chamber. It describes the purpose and location of CCTV monitoring, a contact for those wishing to discuss CCTV monitoring and guidelines for its use.
The purpose of this policy is to regulate the use of CCTV in the monitoring of the external environs of Cork Chamber. The aim is to ensure that CCTV is used transparently and proportionately in accordance with data protection legislation.
This policy relates directly to the location and use of CCTV and the monitoring, recording and subsequent use of such recorded material.
Ownership of the CCTV System:
Cork Chamber is the data controller, and all recorded material is the property of Cork Chamber.
Purpose of CCTV:
Cork Chamber uses video-surveillance equipment for security and access control purposes, which is an action necessary for the management and functioning of the Chamber. Surveillance is performed using devices that are visible and obvious and which are notified by easily read signs in prominent positions. The lawful basis permitting the processing of images of individuals for the above purposes is Article 6(1)(f) of the GDPR i.e. the processing is necessary for the legitimate interests pursued by Cork Chamber.
Signage is displayed at prominent locations throughout the grounds of the Chamber so that staff and visitors are aware that CCTV cameras are in use.
Management, Storage & Retention of CCTV Footage:
The system is managed by the following CCTV administrators
• Naoimh Frawley Operations Manager (firstname.lastname@example.org)
• Jessie O Brien Receptionist (email@example.com)
Recordings are securely stored in a locked server room. Viewing is restricted to authorised personnel only. CCTV footage is not viewed remotely/off-site. In accordance with data protection legislation, CCTV footage is retained for no longer than is necessary. All recordings are retained for a maximum of 28 calendar days.
Disclosure of CCTV to Third Parties:
On occasion, Cork Chamber may be asked to disclose CCTV recordings to third parties for a purpose other than that for which they were originally obtained. This may arise, for example, where a request is received from An Garda Síochána or another law enforcement body to provide footage to assist in the investigation of a criminal offence.
In these circumstances, requests for copies of CCTV footage will only be acceded to where a formal written request is provided stating that An Garda Síochána (or other law enforcement body) is investigating a criminal matter. For practical purposes, and to expedite a request speedily in urgent situations, a verbal request may be sufficient to allow for the release of the footage sought. However, any such verbal request need to be followed up with a formal written request. For accountability purposes a record of all Garda Síochána requests will be maintained by Cork Chamber detailing any provision of footage.
Providing Access to CCTV to Data Subjects:
Data protection law provides for a right of access to their personal data by individuals. This applies to any individual whose identifiable image has been recorded by a CCTV system. When Cork Chamber receives a request from an individual to access CCTV data, we will endeavour to respond withing the one-month timeframe.
To facilitate the processing of the request we will ask the individual to give a reasonable indication of the date and time of the footage they are looking for. If the recording has already been deleted on the date on which the request is received, the defined retention period having expired, the individual will be informed that the footage no longer exists however If an access request has been received within the timeframe, the footage will not be deleted until the request has been fulfilled.
Where images of parties other than the requesting data subject appear on the CCTV footage the Chamber will pixelate or otherwise de-identify, as appropriate, the images of other identifiable parties before supplying a copy of the footage from the footage to the requester.