CCTV Privacy Statement

The following Privacy Statement applies to Horsham District Council’s (HDC’s) use of Closed-Circuit Television (CCTV). It explains what CCTV cameras we use, where they are, why we use them, who we might share the footage with and for how long we keep it.

We are fully committed to complying with the Protection of Freedoms Act 2012, the Data Protection Act (DPA) 2018 and the UK General Data Protection Regulation (GDPR). We ensure that your personal data is processed fairly, lawfully kept safe and secure and retained for no longer than is necessary. Please see our overarching Privacy Statement and separate Privacy Notices for more information.

Where do we use CCTV cameras?

CCTV cameras are in operation in the following areas:

• Horsham and Southwater town centres.
• HDC venues: The Capitol, Museum and Drill Hall.
• HDC properties.
• Car parks- stairwells and exits from stairwells onto the parking levels.
• Car parks- fixed automatic number plate recognition (ANPR) cameras.
• Hop Oast waste depot.
• Mobile cameras installed in our fleet waste vehicles.
• Redeplyable cameras for prevention and detection of environmental crime (fly tipping hot spots)
• Body cameras worn by some HDC staff, including civil enforcement officers.

Our fixed cameras are prominently situated in areas to which the public have unrestricted access and within public view. All our CCTV usage has clear signage stating that CCTV is in operation, including mobile and body worn cameras.

*To note: the HDC building at Parkside is owned by West Sussex County Council who has responsibility for the CCTV cameras.

Why do we use CCTV cameras?

The main purpose of using CCTV footage is to prevent and detect crime and disorder by helping identify, apprehend, and prosecute offenders and keep our Horsham District safe. Footage can provide the Police, HDC officials and enforcement agencies with evidence to enable criminal and/or civil proceedings to be brought in the courts, and to maintain public order.

The use of CCTV systems helps to protect our HDC staff and increase the safety of all Horsham District residents, visitors, and workers.

What personal data is collected and how long do we hold it for?

The HDC CCTV cameras collect live video recording images of an identifiable individual which is retained for 30 days then deleted.  We may have to retain information longer if we are required to do so by the police, courts or law enforcement agencies in the course of criminal investigations.

The town centre CCTV cameras are operated as a partnership between HDC and Sussex Police. Whilst we own and maintain the cameras, Sussex Police has responsibility for the collection and processing of the video images.

How do we protect our CCTV data?

Our CCTV systems are operated in accordance with relevant legislations and codes of practice:

• Protection of Freedoms Act 2012.
• Requirements for processing personal data as set out in the DPA 2018 and the UK GDPR.
• Surveillance Camera Code of Practice and associated guidance from the Surveillance Camera Commissioner.
• CCTV Code of Practice issued by the Information Commissioner’s Office (ICO)
• Documents issued by the Home Office in October 2016:
  • Technical Guidance for Body Worn Video Devices
  • Safeguarding body Worn Video Data
• Article 8 of the Human Rights Act 1998
• Police and Criminal Evidence Act 1984 and Criminal Procedure and Investigation Act 1996
• Criminal Justice and Public Order Act 1994.

Who do we share CCTV data with?

To comply with the purpose of prevention and detection of crime and disorder and to help identify, apprehend, and prosecute offenders and deal with emergency situations, we may share CCTV footage with organisations such as:

• police,
• courts,
• fire brigade,
• ambulance service,
• enforcement agencies

Your rights

You have certain rights under the Data Protection Act 2018 and the UK GDPR. These are set out in our overarching Privacy Statement.

You have the right of access to any personal information the Council holds about yourself and this includes identifiable images of you held on CCTV footage. Please see our separate section for further information on Making a Subject Access Request.

If you want to make a Subject Access Request or exercise any of your rights, then you can do so by contacting:

Information Governance Officer
Parkside
Chart Way
Horsham
West Sussex
RH12 1RL

Email: DataProtectionAct@horsham.gov.uk

However, as the town centre CCTV images are collected and processed by Sussex Police, any requests for access must be made direct to them.

CCTV Senior Responsible Officer

Our Senior Responsible Officer is responsible for monitoring and ensuring our compliance under the Protection of Freedoms Act 2012; the DPA 2018, the UK GDPR and all other relevant legislations and codes of practice. The Senior Responsible Officer provides advice to HDC staff in respect of our obligations and handling and is our point of contact for the Surveillance Camera Commissioner.

The contact details for our CCTV Senior Responsible Officer are:

Head of Legal & Democratic Services, Monitoring Officer,
Data Protection Officer and Solicitor
Parkside
Chart Way
Horsham
West Sussex
RH12 1RL

Email: DataProtectionAct@horsham.gov.uk

Last Review Date: July 2022

Reviewer: Information Governance Officer

Owner:  Data Protection Officer