CCTV DPA Subject Access Requests from 9 Elbourn Way CCTV System =============================================================== Notes ----- It is unlikely any recordings have been retained, because: a. The system is designed and managed to strictly conform to the general data protection regulations (and DPA) - see 'https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/principles/': Lawfulness, fairness and transparency; Purpose limitation; Data minimisation; Accuracy; Storage limitation; Integrity and confidentiality (security); Accountability. b. The system intends to only record short clips of people who come on to the property. Inevitably there will be co-incidents capturing people also on this side of the road and pavement. c. Only other recordings are manually triggered by the data controller when suspicious activity happens to be observed – see ’d’ below. d. The data controller reviews recordings daily (or as soon as possible in the event of absence) & all records are deleted unless there are specific security concerns, such as: i. Damage or theft from the property ii. Trespass iii. Taking undue interest in the property (possible planning future theft etc), such as taking pictures e. Recordings are deleted in 3 months unless they are needed for future legal proceedings. Back-ups are deleted on the usual 12 months deletion cycle. Under DPA individuals are entitled to see any recorded data of themselves, unless this is likely to compromise any future legal proceedings. They are NOT entitled to see anyone else who maybe in the image (without the data controller receiving their specific consent). To this end the data controller must be confident any images disclosed are of the correct person. To achieve this the images must be clear enough to recognise them and they would need to look directly into the camera with nothing obscuring their face. To assist in processing the request, the requestor will need to provide a passport quality photo - see 'https://www.gov.uk/photos-for-passports', the time and date of the interested period, supporting information (such as clothing & route taken - see regions on the site plan) and a reason for the request. Anyone else in the view must be removed or obscured. ICO considers 30 days to be a reasonable time to respond to requests and 40 days to be the maximum. Depending on the complexity of searches, preparation of responses and frequency of requests the data controller reserves the right to charge £10 for each disclosure, as allowed by ICO's 'cctv-code-of-practice.pdf' - see 'https://ico.org.uk/media/for-organisations/documents/1542/cctv-code-of-practice.pdf' & the maximum allowed by Parliament. Responses will be provided by email. This will include: 1. A summary of whether any data was found. 2. A table listing any events retained for that day (usually there will be none), including: time; whether covered by DPA; data format; resolution of image; how recording was triggered. 3. Up to 3 photos totalling less than 5MB of data. JPG static images will be extracted from the recordings and if others are still in view they will be obscured. 4. If more images are available this will be advised. If the requestor wishes these to be provided then they will be asked to provide a USB memory stick. The requestor agrees that a record will be retained of all requests received, including: time and date of the request; the name of the requestor; their email address; what response was given; what format; when the request was fulfilled. The request records will not be subject to further data requests, as the requestor will already have received a more detailed response in the email. This is required to demonstrate DPA is being adhered to. Please refer to ICO’s web-site for clarification: https://ico.org.uk/your-data-matters/domestic-cctv-systems-guidance-for-people-using-cctv/. These procedures score GREEN on ICO’s CCTV checklist – see https://ico.org.uk/for-organisations/data-protection-self-assessment/cctv-checklist/. Requestor’s Details =================== Name: ----- Email: ------ Supporting Information ====================== Number of people/pets accompanying: ----------------------------------- Clothing worn: -------------- Route taken: ------------ Mark appropriate regions around the property with 'Y'- see site plan: 1 Adjacent rear gardens | Y / N 2 Adjacent front gardens (SE) | Y / N 3 Path to side of property (E) | Y / N 4 Nearside road to side of property (E) | Y / N 5 Farside road/path to side & front of property (E & N) | Y / N 6 Adjacent rear garden | Y / N 7 Rear garden 9EW | Y / N 8 Side garden 9EW | Y / N 9 Adjacent front garden (NW) | Y / N 10 Driveway 9EW | Y / N 11 Front garden 9EW | Y / N 12 Path to corner & front 9EW | Y / N 13 Nearside road to corner & front 9EW | Y / N 14 Path in front of adjacent property (NW) | Y / N 15 Nearside road in front of adjacent property (NW) | Y / N Purpose of request ================== Date/time of interest ===================== From: ----- To: --- Don’t forget to include a passport standard photo (see https://www.gov.uk/photos-for-passports). The photo will be deleted once the initial search has been completed. Please forward this form and photo to: jbamjambo@eastafricadreams.com