CCTV Policy

1.ABOUT THIS POLICY
1.1.
The Airport Bus Express Ltd CCTV Policy (“CCTV Policy”) is supplemental to our main Privacy Policy that can be see at /privacy-policy
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1.2.We, Airport Bus Express Ltd, use CCTV cameras to view and record individuals travelling on our buses. We do this to help ensure the safety of our staff and our passengers. However, we recognise that the images of individuals recorded by CCTV cameras are personal data which must be processed in accordance with data protection legislation. We are considered the controller of your data for data protection purposes and as such, we have registered our use of CCTV with the Information Commissioner's Office (ICO) and seek to comply with its best practice suggestions.
1.3.The purpose of this policy is to:
1.3.1.outline why and how we will use CCTV, and how we will process data recorded by CCTV cameras;
1.3.2.ensure that the legal rights of our passengers, relating to their personal data, are recognised and respected;
1.3.3.explain how to make a subject access request in respect of personal data created by CCTV.
1.4.CCTV refers to fixed and domed cameras designed to capture and record images of individuals and property.
2.WHO DOES THIS POLICY APPLY TO?
3.REASONS FOR THE USE OF CCTV
3.1.We currently use CCTV on our buses as outlined below. We believe that such use is necessary for legitimate business purposes, including:
3.1.1.to prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime;
3.1.2.for the personal safety of our staff and passengers and to act as a deterrent against crime;
3.1.3.to support law enforcement bodies in the prevention, detection and prosecution of crime;
3.1.4.to allow investigation of incidents on our buses; and
3.1.5.to assist in day-to-day management, including ensuring the health and safety of our staff and passengers;
4.MONITORING
4.1.CCTV monitors are installed at various locations on our bus and operate when the bus is running and 20 minutes after the bus engine is switched off.
4.2.The only monitor that records sound is on the driver dash-cam. All other CCTV monitors are not used to record sound.
4.4.Staff using surveillance systems will be given appropriate training to ensure they understand and observe the legal requirements related to the processing of relevant data.
4.5.All our buses display signs which inform passengers that CCTV footage is being collected by us and provide details of how to contact us.
5.USE OF DATA GATHERED BY CCTV
5.1.In order 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. This may include encrypting the data, where it is possible to do so.
5.2.We may engage data processors to process data on our behalf. We will ensure reasonable contractual safeguards are in place to protect the security and integrity of the data.
6.RETENTION AND ERASURE OF DATA GATHERED BY CCTV
6.1.Data from CCTV cameras will not be retained indefinitely and 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. Generally we would expect to delete footage after two weeks unless the footage is required, for example if it requested by law enforcement. If such footage is required for use then we will retain the footage for as long as the footage is required.
6.2.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.
7.REQUESTS FOR DISCLOSURE
7.1.We may share data with other group companies and other associated companies or organisations, for example shared services partners where we consider that this is reasonably necessary for any of the legitimate purposes set out above in paragraph 3.1.
7.2.
No images from our CCTV cameras will be disclosed to any other third party, without express permission being given by the director of Airport Bus Express Limited. Data will not normally be released unless satisfactory evidence that it is required for legal proceedings or under a court order has been produced.
7.3.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.
7.4.We will maintain a record of all disclosures of CCTV footage.
7.5.No images from CCTV will ever be posted online or disclosed to the media.
8.SUBJECT ACCESS REQUESTS
8.1.Data subjects may make a request for disclosure of their personal information and this may include CCTV images (data subject access request).
8.2.In order for us to locate relevant footage, any requests for copies of recorded CCTV images should include the date and time of the recording, the location where the footage was captured and, if necessary, information identifying the individual. If it does not, we may be unable to locate the relevant footage.
8.3.We reserve the right to obscure images of third parties when disclosing CCTV data as part of a subject access request, where we consider it necessary to do so.
9.COMPLAINTS
If you have any concerns about our use of CCTV, please contact us at info@airportbusexpress.co.uk. You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
10.REQUESTS TO PREVENT PROCESSING
We recognise that, in rare circumstances, individuals may have a legal right to request erasure of personal data concerning them or to restrict the processing of their personal data. If you consider that these rights apply to you in relation to our use of CCTV should contact us at info@airportbusexpress.co.uk in the first instance.