Calderdale Metropolitan Borough Council of Town Hall, Crossley Street, Halifax, HX1 1UJ is registered with the Information Commissioners Office (ICO) under the provision of the Data Protection Act 2018. The Council takes its responsibilities as Data Controller under the Data Protection Act and UK GDPR very seriously. This privacy notice explains how your personal information will be processed when captured on CCTV.
Calderdale Council has CCTV in operation at various sites, including council offices and other premises, both inside and outside buildings, and on watercourses directed at trash screens for flood monitoring purposes. CCTV will capture images in real time wherever the cameras are pointed and may capture footage of you whilst you are on the premises. There are signs in place to inform you where cameras are in use.
Community safety cameras are in operation in public spaces for public safety purposes and the prevention and detection of crime. These recordings contain images of the public going about their daily business as well as possible offenders. Where fixed CCTV cameras are operating, there will be signs clearly displayed.
Our Community Safety Wardens (CSWs) and Community Safety Enforcement Officers (CSEOs) use body worn cameras and will verbally advise members of the public when it is switched on to record.
On occasions where Regulation of Investigation Power Act (RIPA) applies, targeted covert CCTV footage may be collected for the prevention and detection of crime.
In addition, Council school transport vehicles have dashboard and internal passenger seating area cameras which capture footage of passengers, pedestrians, and other vehicles while in use. All of these vehicles have notices displayed to indicate that they are equipped with cameras.
Civil Enforcement (Traffic) Officers’ body worn cameras are owned and operated by APCOA.
Cameras at household waste recycling centres are owned and operated by SUEZ Recycling and Recovery UK Ltd.
The type of personal information we will collect
- static and moving images of people
- vehicle registration numbers
- special category data: cameras may incidentally record information which falls within these categories. Additionally, footage cameras may be used as evidence regarding criminal offences or related security measures.
Why we collect and hold this information
- to ensure the health and safety of employees, service users and members of the public
- to discourage aggressive or violent behaviour towards staff and reduce staff’s fear of such behaviour
- to enhance Council premises security
- to detect, prevent or reduce the incidence of crime
- to provide evidence for formal actions including prosecutions in court
- to reduce the fear of crime and create a safer environment for the public
- to provide emergency services assistance
- to help investigate breaches in Health and Safety incidents, investigate formal complaints or to resolve formal grievances
- to assist safe behaviour on school transport safeguarding passengers and drivers, to comply with child protection obligations and manage allegations or complaints
- for the defence of the council or its employees with regards to legal or insurance claims
- for flood-risk purposes to monitor the build-up of debris on trash screens to allow us to clear them before they become blocked, and to monitor the water level of the watercourse.
Sharing your personal data
CCTV images and footage may be shared with:
- the Council’s contracted CCTV maintenance providers for on-site cameras, Andrew Greenwood Limited
- the Council’s dash camera contracted software system operators, UK Telematics
- the Council’s trash screen camera contracted operators, Meteor Communications
- Police Forces
- Fire and Rescue Services
- the Environment Agency to assist them in monitoring river levels and flooding during a weather event
- Members of the public in response to subject access requests, Insurance companies and Enforcement agencies when the sharing is compatible with the provisions of the Data Protection Act 2018/UKGDPR.
The Council will only share CCTV footage where there is a lawful reason to do so.
The lawful basis for the processing your data
- Article 6(1)(c) – for compliance with a legal obligation to which the controller is subject, e.g., the Council’s responsibility for the health and safety of employees and visitors to council premises under Health & Safety legislation.
- Article 6(1)(e) – for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, e.g., to provide a safe environment for the public.
- Article 6(1)(f) – Processing is necessary for the purposes of the legitimate interests pursued by the controller.
- Article 9(2)(g) – for reasons of substantial public interest, for the purposes of prevention and detection of crime and protecting the public as set out under Schedule 1 of the DPA 2018.
Retaining your personal information
The Council’s CCTV cameras and body-worn cameras automatically over-write footage between 28 and 31 days after it is captured. School transport services dash camera footage will be deleted after 70 hours of recording, unless required to be retained as evidence. Where authorised bodies are granted access to data collected via CCTV in order to carry out their statutory functions, then copies of the data may be made and retained securely for this purpose. Recordings required as evidence will be kept for a maximum of 6 months or until the evidence is no longer required, whichever is longer, at which time it will be securely destroyed.
Your rights
The GDPR provides the following rights for individuals. Not all rights are absolute and therefore will only apply in certain circumstances:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
You also have the right to complain to the Data Protection Officer if you feel that your data has not been handled in accordance with the law. You can contact the Council’s Data Protection Officer at information.management@calderdale.gov.uk.
You also have the right to lodge a complaint with the Information Commissioner’s Office.