10.
USE OF ADDITIONAL SURVEILLANCE SYSTEMS
10.1
Prior to introducing any new surveillance system, including placing a new CCTV camera in any workplace location, we will carefully consider if they are appropriate by carrying out a privacy impact assessment ( PIA ). A PIA is intended to assist us 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. Any PIA 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. In particular, 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. No surveillance cameras will be placed in areas where there is an expectation of privacy (for example, in changing rooms) unless, in very exceptional circumstances, it is judged by us to be necessary to deal with very serious concerns.
10.2
10.3
10.4
11.
COVERT MONITORING
11.1
We will never engage in covert monitoring or surveillance (that is, where individuals are unaware that the monitoring or surveillance is taking place) unless, in highly exceptional circumstances, there are reasonable grounds to suspect that criminal activity or extremely serious malpractice is taking place and, after suitable consideration, we reasonably believe there is no less intrusive way to tackle the issue. In the unlikely event that covert monitoring is considered to be justified, it will only be carried out with the express authorisation of a Director. The decision to carry out covert monitoring will be fully documented and will set out how the decision to use covert means was reached and by whom. The risk of intrusion on innocent workers will always be a primary consideration in reaching any such decision.
11.2
11.3
Only limited numbers of people will be involved in any covert monitoring.
11.4
Covert monitoring will only be carried out for a limited and reasonable period of time consistent with the objectives of making the recording and will only relate to the specific suspected illegal or unauthorised activity.
12.
ONGOING REVIEW OF CCTV USE
12.1
We will ensure that the ongoing use of existing CCTV cameras in the workplace is reviewed at least every 18 months to ensure that their use remains necessary and appropriate, and that any surveillance system is continuing to address the needs that justified its introduction.
13.
REQUESTS FOR DISCLOSURE
13.1
No images from our CCTV cameras will be disclosed to any third party, without express permission being given by Luke Wellings. 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.
13.2
13.3
We will maintain a record of all disclosures of CCTV footage subject to document retention guidelines.
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