Our CCTV Policy
Teignmouth Harbour Commissioners has in place a CCTV surveillance system deployed across its harbour and facilities. This policy details the purpose, use and management of the CCTV system at the harbour and details the procedures to be followed in order to ensure that the harbour complies with relevant legislation. The harbour will have due regard to the Data Protection Act 2018 (DPA) and the General Data Protection Regulation (GDPR). The harbour will also have due regard to the Surveillance Camera Code of Practice, in particular the 12 guiding principles contained therein. This policy applies to all of the harbour’s CCTV systems including where applicable any Automatic Number Plate Recognition (“ANPR”) Licence Plate Recognition Cameras (“LPR”), body worn cameras, webcams and any other system capturing images of identifiable individuals for the purpose of viewing and or recording the activities of such individuals. CCTV images are monitored and recorded in strict accordance with this policy.
2. CCTV System Overview
The CCTV system is owned by Teignmouth Harbour Commissioners, 2nd Floor, ABP Port Office, Old Quay Road, Teignmouth, TQ14 8ES and is managed by the harbour and its appointed agents. Under the DPA & GDPR the harbour is the ‘data controller’ for the images produced by the CCTV system. The harbour is registered with the Information Commissioner’s Office (registration number Z1923034). The CCTV system operates to meet the requirements of the Data Protection Act and the Information Commissioner’s Guidance. There are currently up to 10 operational CCTV Cameras located across the harbour estate to cover as much of the area as possible. Signs are placed around in order to inform staff, harbour users, visitors and members of the public that CCTV is in operation. Cameras are not sited to focus on private residential areas or other non-harbour property. The CCTV system is operational and is capable of being monitored for 24 hours a day, every day of the year.
3. Purpose of the CCTV System
The principal purposes of the harbour’s CCTV system are as follows: –
- safe navigation and the security of the harbour
- for the prevention, reduction, detection and investigation of crime and other incidents;
- to ensure the safety of staff, harbour users and visitors;
- to assist in the investigation of suspected breaches of harbour regulations by staff, harbour users and visitors and
- the monitoring and enforcement of harbour related matters.
The cameras installed provide images that are of suitable quality for the specified purposes for which they are installed. The harbour seeks to operate its CCTV system in a manner that is consistent with respect for the individual’s privacy. Teignmouth Harbour Commissioners Public CCTV Policy.
4. Monitoring and Recording
Cameras are monitored in harbour office in areas restricted to harbour personnel. Images are recorded on the harbour’s servers and are viewable by the harbour management team. Any member of staff may be authorised on a case by case basis by the management team to view stored images. All images recorded by the CCTV System remain the property and copyright of the harbour. Body worn cameras may be used by harbour staff. Staff wearing body worn cameras will disclose, when approaching persons, that they are being video and audio recorded. The downloading of images from such cameras will only be conducted by trained staff and images will be deleted from cameras after downloading.
5. Compliance with Data Protection Legislation
In its administration of its CCTV system, the harbour complies with the Data Protection Act and the General Data Protection Regulations. Due regard is given to the data protection principles embodied in these as well as the guiding principles of the Surveillance Camera Code of Practice. 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 stated purpose;
- 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.
- Not transferred outside the European Economic Area unless the recipient country ensures an adequate level of protection
6. Applications for disclosure of images;
Requests by individual data subjects for images relating to themselves “Subject Access Request” or by a third party should be submitted in writing to the harbour for the attention of the Data Protection Manager together with proof of identification. In order to locate the images on the harbour’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. Where the harbour 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. A record of any disclosure made under this policy will be held by the Data Protection Manager, itemising the date, time, camera, requestor, authoriser and reason for the disclosure. Teignmouth Harbour Commissioners Public CCTV Policy Teignmouth Harbour
7. Retention of images
Unless required for evidential purposes, the investigation of an offence or as required by law, CCTV images will be retained for no longer than 30 days from the date of recording. Images will be automatically overwritten after this point. Where an image is required to be held in excess of the retention period referred to in above, the Data Protection Manager will be responsible for authorising its retention. 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.
8. Complaints procedure
Complaints concerning the harbour’s use of its CCTV system or the disclosure of CCTV images should be made in writing to Harbour for the attention of the Data Protection Manager. All appeals against the decision of the Data Protection Manager should be made in writing to the Harbour Master.
9. Monitoring Compliance
All staff involved in the operation of the Harbour’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. All staff with responsibility for accessing, recording, disclosing or otherwise processing CCTV images will be required to undertake data protection training.
10. Policy review
The harbour’s usage of CCTV and the content of this policy shall be reviewed annually by the Data Protection Manager with reference to the relevant legislation or guidance in effect at the time. Further reviews will take place as required.