CCTV Policy

Introduction
1. Trotyn Croft Management (Bognor) Limited “Trotyn Croft Management” has in place a CCTV surveillance system “the CCTV system” on the Trotyn Croft private estate “Trotyn Croft”. This policy details the purpose, use and management of the CCTV system at Trotyn Croft and details the procedures to be followed in order to ensure that Trotyn Croft Management complies with relevant legislation and the current Information Commissioner’s Office CCTV Code of Practice.
2. Trotyn Croft Management will have due regard to the Data Protection Act 2018, the General Data Protection Regulation (GDPR) and any subsequent data protection legislation, and to the Freedom of Information Act 2000, the Protection of Freedoms Act 2012 and the Human Rights Act 1998.
3. This policy and the procedures therein detailed, applies to all of Trotyn Croft Management’s CCTV systems including any system capturing images of identifiable individuals for the purpose of viewing or recording the activities of such individuals. CCTV images are recorded and reviewed in strict accordance with this policy.
CCTV System Overview
1. The CCTV system is owned by Trotyn Croft Management, 4 Sudley Road, Bognor Regis PO21 1EU and managed by Trotyn Croft Management and its appointed agents. Under current data protection legislation Trotyn Croft Management is the ‘data controller’ for the images produced by the CCTV system. Trotyn Croft Management is registered with the Information Commissioner’s Office and the registration number is ZA669575. The CCTV system operates to meet the requirements of the Data Protection Act and the Information Commissioner’s guidance.
2. The Treasurer is responsible for the overall management and operation of the CCTV system, including activities relating to recording, reviewing and ensuring compliance with this policy.
3. The CCTV system consists of four (4) fixed cameras, a DVR, a point to point wireless connection, and an internet connection.
4. The CCTV system operates in four (4) locations, covering all three (3) of the resident’s allocated parking areas, the ungated access to Trotyn Croft, the gated access to Trotyn Croft, and one (1) of the visitor’s car parks. These being entrances and communal areas of Trotyn Croft. Cameras are not sited to focus in private residential areas, or public roadways.
  1. Zone A of the CCTV system implements one (1) camera covering the southeastern visitor’s car park and eastern entrance.
  2. Zone B of the CCTV system implements one (1) camera covering the southeastern carports and eastern entrance.
  3. Zone C of the CCTV system implements one (1) camera covering the western carports and western entrance.
  4. Zone D of the CCTV system implements one (1) camera covering the northwestern carports and gated entrance.
5. Signs are placed by the entrances to the estate and under the CCTV cameras, to inform residents and visitors that CCTV is in operation.
6. Trotyn Croft Management will not engage in covert surveillance.
7. The Treasurer is responsible for ensuring that adequate signage is erected in compliance with the ICO CCTV Code of Practice.
8. The CCTV system is not monitored, and only referred to in the event of suspected criminal activity or to check the system is fully operational.
9. The CCTV system is subject to a Data Protection Impact Assessment.
  Any proposed new CCTV installation is subject to a Data Protection Impact Assessment. Any new CCTV Camera installation is subject to a privacy assessment.
Purpose of The CCTV System
1. Trotyn Croft Management uses the CCTV system’s images for the prevention, identification and reduction of crime in order to provide a safe and secure environment for residents and visitors, and to prevent the loss or damage to Trotyn Croft Management property.
2. The principle purpose of Trotyn Croft Management’s CCTV system are as follows:
  - For the prevention, reduction, detection, and investigation of crime and other incidents;
  - Supporting the Police in a bid to deter and detect crime;
  - Assisting in identifying, apprehending and prosecuting offenders.
  - Assisting law enforcement agencies, security services, insurance providers, and any relevant regulators with any criminal or civil investigations, and legal proceedings.
3. The CCTV system will be used to review Trotyn Croft’s grounds following a suspected criminal activity. Any response should be proportionate to the incident detected following review of the footage.
4. Trotyn Croft Management seeks to operate its CCTV system in a manner that is consistent with respect for the individual’s privacy.
5. The use of the CCTV system for security purposes has been deemed to be justified by Trotyn Croft Management’s directors. The system is intended to capture images of intruders or of individuals damaging property or removing goods without authorisation.
Monitoring and Recording
1. Cameras are remotely accessed via secure connection using Internet Protocols.
2. Images are recorded centrally on a DVR located securely on the Trotyn Croft grounds, and are accessible by the Treasurer and the Chairperson. Additional directors of Trotyn Croft Management may be authorised by the Treasurer to review footage recorded if it is deemed necessary for the detection and/or prevention of a criminal act. A record of any access made to the CCTV system will be recorded on the CCTV management system itemising the date, time, camera, viewer and reason for the access.
3. The cameras installed provide images that are of a suitable quality for the specified purposes for which they are installed.
4. All images recorded by the CCTV System remain the property and copyright of Trotyn Croft Management.
Compliance With Data Protection Legislation
1. In its administration of its CCTV system, Trotyn Croft Management complies with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. Due regard is given to the data protection principles embodied in GDPR. These principles require that personal data shall be:
  - Processed lawfully, fairly and in a transparent manner;
  - Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
  - Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  - Accurate and, where necessary, kept up to date;
  - Kept in a form which permits identification of the data subjects for no longer than is necessary for the purposes for which the personal data are processed;
  - Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
  Trotyn Croft Management ensures it is responsible for, and able to demonstrate compliance with GDPR.
Applications for Disclosure of Images
1. Applications by Individual Data Subjects
  1. Requests by individual data subjects for images relating to themselves “Subject Access Request” should be submitted in writing to Trotyn Croft Management together with proof of identification. Further details of this process are detailed on Trotyn Croft Management’s Privacy Policy webpage: https://trotyncroft.scottmarkham.dev/privacy-policy/
  2. In order to locate the images on Trotyn Croft Management’s system, sufficient detail must be provided by the data subject in order to allow the relevant images to be located and the data subject to be identified.
  3. Where Trotyn Croft Management is unable to comply with a Subject Access Request without disclosing the personal data of another individual who is identified or identifiable from that information, it is not obliged to comply with the request unless satisfied that the individual has provided their express consent to the disclosure, or if it is reasonable, having regard to the circumstances, to comply without the consent of the individual.
2. Access to and Disclosure of Images to Third Parties
  1. A request for images made by a third party should be made in writing to the Treasurer.
  2. In limited circumstances it may be appropriate to disclose images to a third party, such as when a disclosure is required by law, in relation to the prevention or detection of crime or in other circumstances where an exemption applies under relevant legislation.
  3. Such disclosures will be made at the discretion of the Treasurer, with reference to relevant legislation and where necessary, following advice from Trotyn Croft Management’s directors.
  4. The Treasurer may provide access to CCTV images to Investigating Officers when sought as evidence in relation to criminal cases.
  5. A record of any disclosure made under this policy will be held on the CCTV management system, itemising the date, time, camera, requestor, authoriser and reason for the disclosure.
Retention of Images
1. Unless required for evidential purposes, the investigation of an offence or as required by law, CCTV images will be retained for no longer than 28 days from the date of recording. Images will be automatically overwritten after this point.
2. Where an image is required to be held in excess of the retention period referred to in 7.1, the Treasurer or their nominated deputy, will be responsible for authorising such a request.
3. Images held in excess of their retention period will be reviewed on a three monthly basis and any not required for evidential purposes will be deleted.
4. Access to retained CCTV images is restricted to the Treasurer and other persons as required and as authorised by the Treasurer.
Complaints Procedure
1. Complaints concerning Trotyn Croft Management’s use of its CCTV system or the disclosure of CCTV images should be made in writing to the Treasurer at trotyncroft@gmail.com
2. All appeals against the decision of the Treasurer should be made in writing to the Trotyn Croft Management at trotyncroft@gmail.com
Monitoring Compliance
1. All members of Trotyn Croft Management involved in the operation of Trotyn Croft Management’s CCTV System will be made aware of this policy and will only be authorised to use the CCTV System in a way that is consistent with the purposes and procedures contained therein.
2. All members of Trotyn Croft Management with responsibility for accessing, recording, disclosing or otherwise processing CCTV images will be required to undertake data protection training.
Policy Review
1. The Trotyn Croft Management’s usage of CCTV and the content of this policy shall be reviewed annually by the Treasurer with reference to the relevant legislation or guidance in effect at the time. Further reviews will take place as required.