A. General Policy and Guidelines

1. CCTV is used by the La Caleta Icon Limited (Reg. no. HE420046), (“La Caleta”) as part of the operational system for safety and security.
2. The primary purposes of having CCTV are for fraud prevention, security and health and safety reasons. Recording images will only be used in particular circumstances. These include breach or suspected breach of law; for employee personal protection; a health and safety incident; or where recourse to CCTV images is necessary in the course of any investigation carried out by Management. In the case of an investigation, the CCTV footage may require to prove or disprove any concerns regarding a customer, employee(s), any third party or the workplace itself. For the avoidance of doubt, CCTV can be used as evidence in disciplinary investigations.
3. La Caleta operates cameras that are at various locations on the premises. Signage is displayed outside of the premises, to highlight the presence of CCTV cameras.
4. The CCTV will be operated by La Caleta on a 24-hour basis seven days a week.

B. Retention

1. Recorded images and associated information will be retained for a maximum of 15 days from the date of recording. After a period of up to a maximum of 15 days, the system will automatically overwrite images. However, La Caleta reserves the right to retain images for a longer period where there are objective reasons for doing so.
2. Where CCTV is retained for a longer period in the context of an investigation, then it will only be retained for as long as is required for the duration of the investigation/proceedings/disciplinary proceedings, including any court proceedings or appeal process, and will be permanently deleted once these proceedings /appeals are concluded in full.

C. Security and Authorised Use

1. CCTV footage will be retained securely. The CCTV storage medium will be kept securely and only accessed by designated individuals. Unauthorised accessing of CCTV is strictly prohibited.
2. Those employees who are responsibility for processing CCTV images must only do so in line with established procedures and must ensure the security of data at all time.
3. CCTV footage will only be retained and/or used for specific purpose(s) for which it was captured.

Any employee/manager who uses the CCTV system/CCTV images in an unauthorised manner may be subject to disciplinary action up to and including dismissal. Unauthorised use is any processing incompatible with the data`s original purpose including, but not limited to:

1. disclosure of images containing Personal Data to an unauthorised third party, including other employees;
2. Unauthorised processing of Personal Data in the form of copying the images onto disks, website or print format;
3. Unauthorised circulation of images containing Personal Data by email, phone or posting of mages containing person data on the internet.

 

D. Redaction/Pixilation

1. Circumstances might arise where an employee or other individual requests a copy of CCTV footage in which their image is captured. Such a request should be received in writing specifying as accurately as possible the time periods/time frame of the CCTV footage being requested. Where other individuals are identifiable on the footage, then in all cases their images will be redacted/pixelated/blocked before a copy of the footage is passed over to the individual requesting a copy of the footage, unless the permission of the other individual is obtained.

E. Access to and disclosure of images to third parties

Access to and disclosure of images recorded by CCTV system is carefully monitored. Access to images by third parties will only be allowed in limited and prescribed circumstances permitted by the relevant legislation. Such circumstances may include the disclosure of Personal data in order to:

1. Prevent injury or damage to property;
2. Meet legal requirements;
3. Obtain legal advice, or for the purpose of legal proceedings;
4. Meet a request from, or with the consent of, the data subject, or person acting on his behalf.

Such requests should be provided to La Caleta in writing and will be acceded by La Caleta within a reasonable time. If a CCTV footage is deemed urgent, then La Caleta may facilitate a viewing without the formal written request but on the understanding that the formal written request will be sent to La Caleta by as soon as is reasonably practicable.

The company also reserves the right to disclose Personal data to specific third parties where there are objective business reasons for doing so. Such third parties may include:

• Insurance providers;
• Legal advisors;
• Pension and medical insurance providers;
• Security providers.

F. Our Details

 

Location warning notice filming/ photography taking place here.

 

Please be advised that filming and/or photography will be taking place here, in this area. 

 

If you do not wish to appear in any images captured please tell us so that we can take appropriate steps to ensure you are not included.

 

The photographs/film will be used by La Caleta, at the Icon, and will be included in its publications and/or promotional materials and will be also published on the social media (Instagram, Facebook).

 

If you have any concerns, questions or complaints about this Policy, then please contact us at: gdpr@imperio-group.com or read or Privacy Policy