CCTV Privacy Notice
CCTV footage of individuals is classed as their personal data, as they are the data subject and it is data they can be identified from. This means anyone who visits our sites, whether staff members and agency staff, contractors, or members of the public, will be the data subject.
Why we use CCTV
We have CCTV installed outside our buildings and fire stations for public and staff safety, crime prevention through deterrence and detection, and for accident and incident investigation.
We also have mobile CCTV and data recorders mounted on AF&RS vehicles. This footage can be used for all the above, and also for identifying engine emissions, fuel consumption, vehicle mileage and driving hours. It provides a pool of learning experiences for training purposes that we can use to assist in improving operational tactics and command, and for reducing insurance claims and associated insurance premiums where possible.
The lawful basis
The Fire and Rescue Service Act 2004 makes it a requirement to secure the provision of the personnel, services and equipment necessary to efficiently deliver a Fire and Rescue Service. We also have an obligation to safeguard our employees, and to comply with Health & Safety legislation.
Under the General Data Protection Regulation (GDPR) 2016, our lawful basis on which we collect and use this information depends on the reason for its use:
- it is necessary for the performance of a task carried out in the exercise of our official authority as a Fire and Rescue Service (Article 6, 1 (e)) to facilitate our operational staff training, operational tactics, efficient/safe use of Fire Service resources and equipment, and Fire Investigation activities;
- it is our legal obligation to comply with Health and Safety Legislation (Article 6, 1 (c)) for the investigation of an incident involving the health, safety and welfare of our staff or individuals visiting our premises;
- it is for our own legitimate interests (Article 6, 1 (f)) for the protection of our property, other assets, reducing our insurance claims, and for investigation of crime (which could extend to the legitimate interests of a third party), whilst balancing the rights and expectations of the individuals captured by the CCTV.
Any data will only be used for these purposes, unless other legislation means further processing is necessary and lawful.
How we collect and store information
We do not perform covert surveillance.
All buildings where CCTV is fitted display awareness signs, and there is signage on all Service vehicles that have mounted CCTV equipment.
All CCTV images are recorded locally, and footage is not retained indefinitely as it is automatically overwritten once capacity has been reached. This depends on the capacity of the recording media at each site or on the Service vehicle, and so will range from approximately 2 weeks to several months.
There may be a need to keep specific footage for longer if a crime, a Health & Safety incident, or a potential insurance claim is being investigated. This data is downloaded and stored securely on AF&RS premises, treated in accordance with Home Office guidance, and deleted after use.
How we use information
Our Health, Safety and Welfare team have access to vehicle footage, to carry out health and safety investigations on behalf of the Service.
Our Property Services team, Service Control, onsite security guard, and our CCTV Maintenance Contractors have access to property footage, to manage our site security and maintain the system.
CCTV footage can also be shared with our insurance provider, to manage any insurance claims.
Decisions about any other request for access are carried out on a case by case basis, and the requester needs to show a legal reason and entitlement to access it. This includes requests from other AF&RS departments as well as any external party.
We consider release to law enforcement agencies, third party insurance companies, or official/legal representatives for the data subject concerned (solicitor, doctor, etc.) who have policies and procedures for the secure handling of personal data. This is because we need to ensure the integrity and security of any data we choose to share with a third party, in accordance with the Information Commissioner (ICO) and Home Office codes of practice.
Our CCTV Policy is on our website at www.avonfire.gov.uk/documents/category/140-health-safety-and-welfare.
Updated 30 October 2020