CCTV Policy
Introduction
As part of our commitment to creating safe communities, we us Closed Circuit Television (CCTV) for the purposes of the prevention and detection of crime. We also balance this with the rights of individuals to privacy as they go about their daily lives. This policy outlines how we where we locate CCTV, how we manage the data captured, security around its storage and deletion and who we share this data with.
Our commitment to you
We have a commitment to keep our residents, staff, partners and contractor safe. To assist with this we use CCTV to enable us to recognise and identify individuals committing anti -social or illegal behaviour in order to take the appropriate action.
We do this in line with all current legislation and best practice, outlined below. We will be clear and transparent where we are recording and how the data captured is managed.
The policy applies to the use of CCTV at CKH offices, residential properties and other buildings or areas managed by CKH.
Reasons for the use of CCTV
CKH has a legitimate interest (under the Data Protection Act 2018) for using CCTV on our properties:
- to prevent crime and protect buildings and assets from damage, disruption, vandalism, and other crime.
- for the personal safety of employees, residents, visitors, and other members of the public and to act as a deterrent against crime.
- to support internal investigations and law enforcement in the prevention, detection, and prosecution of crime, the apprehension of offenders and the prevention and detection of safeguarding incidents.
- to assist in day-to-day management, including ensuring the health and safety of employees, residents, and other individuals in and around CKH premises.
- to assist in the effective resolution of disputes which may arise during disciplinary or grievance proceedings.
- to assist in the defence of any civil litigation, including employment tribunal proceedings; and
- to assist our Insurers or Solicitors to properly consider issues of liability and indemnity.
CCTV location and operation
CCTV may monitor the interior and exterior of offices and communal areas of residential blocks. This data is recorded 24 hours a day.
Camera locations are chosen to minimise the viewing of spaces not relevant to the legitimate purpose of the monitoring. As far as practically possible, CCTV cameras will not focus on private homes, gardens or other areas of private property. This is in line with the data minimisation principle under UK GDPR.
All CCTV at the present time used by CKH is overt, meaning cameras are visible and signed. Signs are displayed at the entrance to all areas covered by CCTV to alert individuals that their image may be recorded. These signs will contain details of the organisation operating the system, the purpose for the monitoring, and who to contact for further information.
Where deemed necessary, surveillance systems will be used to record sound but only where we can clearly justify its use with robust supporting evidence.
Live feeds from CCTV cameras will only be monitored where this is reasonably necessary, for example to protect health and safety, or to monitor suspected fraudulent and/or criminal activity.
Who has responsibility for CCTV?
The Assistant Director of IT, Facilities and Business Insights is responsible for ensuring that the CCTV Policy aligns with Data Protection legislation and UK GDPR.
The Facilities Manager is responsible for the maintenance of the system, checks and maintenance. The Facilities Manager is also responsible for ensuring images are deleted in line with the Retention Policy. Members of the Facilities and IT teams will have access to the recorded images during maintenance of the systems but will under no circumstances routinely view disclose or retain copies of the recorded images.
The Data Team is responsible for dealing with and responding to any requests for access to images made by individuals under the Data Protection Act 2018. Any requests received by CKH for access to images must be forwarded to the Data Team to be progressed using existing procedures.
The Assistant Director of IT, Facilities and Business Insights, or delegated managers, are responsible for viewing images when investigating an incident or suspected incident.
Images may also be accessed by the relevant investigating manager, if necessary, as part of an investigation. Images may then be disclosed as part of the evidence assembled by the investigating manager in the event of formal action.
Use of CCTV footage
To ensure that the rights of individuals recorded by the CCTV system are protected, we will ensure that data gathered from CCTV cameras is stored in a way that maintains its integrity and security with routine access limited to approved CKH employees (e.g. managers/assistant managers). This may include encrypting the data, where it is possible to do so and when required for, e.g. police disclosures, insurance claims, where the footage is required as evidence to support a case.
The main CCTV Digital Recording Device (DVR) is located in the server room within CKH head office, which accesses the cameras located at head office and independent DVRs at satellite sites.
Retention and deletion of CCTV footage
Data from CCTV cameras will not be retained indefinitely but will be permanently deleted once there is no reason to retain the recorded information. Exactly how long images will be retained for will vary according to the purpose for which they are being recorded. For example, where images are being recorded for crime prevention purposes, data will be kept long enough only for incidents to come to light, although, in most cases, it is recognised that this is usually within 24/48 hours of an ASB, criminal or accident-related incident occurring. In all other cases, recorded images will be kept for no longer than 30 days.
At the end of their useful life, e.g. at the conclusion of an investigation (and in line with our data retention schedule) all images stored in whatever format will be erased permanently and securely. Any physical matter such as tapes or discs will be disposed of as confidential waste. Any still photographs and hard copy prints will be disposed of as confidential waste. IT will be consulted for any electronic equipment disposal.
Use of Additional Surveillance Systems
Prior to introducing any new surveillance system, including placing a new CCTV camera in any location, we will carefully consider if they are appropriate by carrying out a Data Privacy Impact Assessment (DPIA).
A DPIA is intended to assist in deciding whether new surveillance cameras are necessary and proportionate in the circumstances and whether they should be used at all or whether any limitations should be placed on their use.
A DPIA will consider the nature of the problem that we are seeking to address at that time and whether the surveillance camera is likely to be an effective solution, or whether a better solution exists. We will consider the effect a surveillance camera will have on individuals and therefore whether its use is a proportionate response to the problem identified.
Review of CCTV Use
We will ensure that the ongoing use of existing CCTV cameras is reviewed periodically to ensure that their use remains necessary and appropriate, and that any surveillance system is continuing to address the needs that justified its introduction.
Requests for Disclosure
CKH may share data with other associated companies or organisations, for example shared services partners and data sharing agreement partners where we consider that this is reasonably necessary for any of the legitimate purposes, outlined in the DPA18 and the UKGDPR.
Images from our CCTV cameras will not be disclosed to any other third party, without express permission being given by our Assistant Director of IT, Facilities and Business Insights, who will ensure the Data Protection Officer (DPO) is informed. Data will not normally be released unless satisfactory evidence that it is required for legal proceedings or under a court order has been produced.
In other appropriate circumstances, we may allow law enforcement agencies to view or remove CCTV footage where this is required in the detection or prosecution of crime.
We will maintain a record of all disclosures of CCTV footage.
Images from CCTV will never be posted online or disclosed to the media.
Data Subject Access Requests
Individuals may make a request for disclosure of their personal information, and this may include CCTV images. This can be done by submitting a data subject access request, as outlined in our Privacy Statement.
For CKH to locate relevant footage, any requests for copies of recorded CCTV images must include the date and time of the recording, the location where the footage was captured and, if necessary, information identifying the individual.
We reserve the right to obscure images of third parties when disclosing CCTV data as part of a data subject access request, where we consider it necessary to do so.
Data Protection Provisions
Privacy Notice - Transparency of Data Protection
Being transparent and providing accessible information to individuals about how we use their personal data is important to us.
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What information is being collected |
CCTV images of individuals |
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Who is collecting it |
Cross Keys Homes |
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How is it collected |
By CCTV cameras and other surveillance equipment |
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Why is it being collected |
For the legitimate business purposes as identified, from time to time, within the business, such as the prevention and detection of crime. |
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How will it be used? |
It will be used as evidence. The evidence will be used to in court, if necessary, to prove someone was in a certain place or that they committed an offence. It will also be used to improve building safety and prevent crime, by putting people off committing crimes like robbery if they know their actions are being recorded. |
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Who will it be shared with? |
Third parties such as law enforcement agencies and partners with whom we have data sharing agreements and shared services. |
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Identity and contact details of any data controllers |
Cross Keys Homes, Shrewsbury Avenue, Peterborough PE2 7BZ |
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Details of transfers to third country and Safeguards |
None |
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Retention period |
Information will be kept only as is strictly necessary to meet our purposes for recording it but for no longer than 90 days. |
Further information:
Who is responsible for managing the CCTV Policy?
The Assistant Director of IT, Facilities and Business Insights is responsible for this policy.
Legislation and regulation
This policy is written in accordance with the following regulatory and legislative requirements:
- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018 (DPA)
- Protection of Freedoms Act 2012 (Part 2)
- Data Use and Access Act 2025
Information sharing
Cross Keys Homes has an information sharing agreement with key agencies and contractors to share information in relation to the delivery of our services. Information shared must be relevant and the Data Protection Procedure adhered to when handling data. You can find more information about how we manage your data in our Privacy Policy.
Monitoring and review
The CCTV Policy was written and approved in May 2026 and will be reviewed every year - next review May 2027.