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Privacy Impact Assessment

CCTV cameras  

Name: Felpham Allotment and Gardens Society. (FAGS)

Address: Felpham Way, Felpham, PO22 7PW

E-mail: enquiries@felphamallotments.org.uk

Why are the cameras being considered for installation at the Felpham Allotments and Garden Society location? – to protect the assets of allotment tenants. To provide security for tenants working alone. To provide a deterrent against vandalism and theft. To assist in possible identification of suspects.

Has consultation taken place? – the proposal was an item on the agenda of the AGM held on the 20^th November 2023. The proposal was discussed at length and a vote was taken to proceed with the installation of CCTV. A majority approved to proceed with CCTV.

What types of cameras are being considered? – A security system consisting of cameras, recorder and monitor to be installed by a specialist security company.

Is audio recording an available feature? – No.

Do the cameras have any other specific or software related features? – No.

Do the cameras have the capacity to record personal data? – Yes, the cameras are installed to protect against vandalism and theft. The cameras will be read only by officers of the FAGS committee.

Is there any chance of images being released in the public domain? – Yes, the Police will be given access to the images if evidence was considered relevant and the Police may choose to release the image further.

Is there a Data Protection Act compliant sign clearly displayed in close proximity of the cameras to make people aware that CCTV is in operation? – Yes, three signs have been erected.

Do the cameras cover any part of any property where there is an expectation of privacy? – No

Does any additional action need to be taken to reduce the impact on privacy by these camaras? – No.

Data Protection Policy 

The following information provides details on how Felpham Allotment and Gardens Society (“FAGS” or “the Society”) may collect, use, and where appropriate share personal information for the administration and management of our allotments in accordance with the General Data Protection Regulations (GDPR).

Our contact details.

Name: Felpham Allotment and Gardens Society. 

Address: Felpham Way, Felpham, PO22 7PW

E-mail: enquiries@felphamallotments.org.uk 

The type of personal information we collect.

We currently collect and process the following information:

• Names
• Addresses
• Email Addresses
• Phone Numbers
• Commencement date of the tenancy
• Plot Rental Details

How we get the personal information and why we have it

We collect personal information by email and through face-to-face contact with you, or on occasion an agreed representative nominated by you.

We will use your personal data for the following purposes:

• Maintain and administer the Allotments systems.
• Maintain our accounts and financial records, process relevant financial transactions, and follow up outstanding plot rental payments.
• Identify you when you contact us and when we contact you.
• Contact you in the event of problem with your tenancy/plot or notify you of changes to your plot or agreement e.g. repairs, maintenance.
• Send out allotment’s communications.
• Investigate and respond to issues related to the FAGS allotment site.
• Investigate complaints, such as property damages, anti-social behaviour, or other concerns.
• Monitor complaints, comments, and other feedback.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

• Your consent. You are able to remove your consent at any time. You can do this by contacting the Chairperson or Secretary.
• We have a contractual obligation.
• We have a legal obligation.
• We have a vital interest.
• We need it to perform a public task.
• We have a legitimate interest.

How we store your personal information

Your information is securely stored. We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

Your data protection rights.

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact the Chairperson or Secretary if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint by contacting the Chairperson or Secretary.

You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data.

The Information Commissioner is the UK’s independent body set up to uphold information rights.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

CCTV Policy 

Introduction

Felpham Allotment and Gardens Society (“FAGS” or “the Society”) uses closed circuit television (CCTV) images to protect the Society’s property and to provide a safe and secure environment for plot holders and visitors to the Allotment site. This policy sets out the details of how the Society will collect, use, and store CCTV images. 

The Society’s CCTV facility will only record images. There is no audio recording i.e., conversations are not recorded on CCTV.

Purposes of CCTV

The Society 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.
• Identification and prosecution of offenders.
• Monitoring of the security of the Society’s premises.
• Ensuring that health and safety rules and Society procedures are being complied with.

Location of cameras

Cameras are located at a number of strategic places. The Society has positioned the cameras so that they only cover communal or public areas on the Society’s premises, and they have been sited so that they provide clear images.

Appropriate signs are prominently displayed so that plot holders, 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.

As the recording system records digital images, any CCTV images that are held on the hard drive of a PC or server are deleted and overwritten on a recycling basis and, in any event, once the hard drive has reached the end of its use, it will be erased prior to disposal.

Access to and disclosure of images

Access to, and disclosure of, images recorded on CCTV is restricted. 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 and to those officials who are authorised to view them in accordance with the purposes of the system. Viewing of recorded images will take place in a restricted area to which other unauthorised persons will not have access when viewing is occurring.

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 Society Chairperson is the only person who is permitted to authorise 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 UK’s data protection laws, including the General Data Protection Regulation, individuals have the right on request to receive a copy of the personal data that the Society 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 Society’s Chairperson or Secretary.

The Society 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.

The Society will usually respond promptly and in any case within one month of receiving a request. However, where a request is complex or numerous the Society may extend the one month to respond by a further two months.

The Society will always check the identity of the person making the request before processing it.

The Chairperson 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 Society 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.

Implementation

The Society’s Chairperson (supported by FAGS committee members) 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 Society’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 Society’s CCTV system should be addressed to the Chairperson or Secretary.

Further Information

Further information on CCTV and its use is available from the following:

• ico.org.uk
• Regulation of Investigatory Powers Act (RIPA) 2000
• Data Protection Act 1998

Issued December 2023 

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