INTRODUCTION
This Park Motion Detection Camera Policy sets out how Liquorice Park Millennium Green Park Trust (the Trust) will operate and process data (still photos or videos) from camera units installed in the park, in accordance with applicable Data Protection and Privacy Laws. It is not deemed necessary to carry out a specific Data Protection Impact Assessment (DPIA) as the decision to use cameras and the use of collected data does not constitute a high risk to individuals, as per the Information Commissioners office (ico) guidelines.
This policy details how the Trust will collect, use and store captured images. Unless there are exceptional circumstances (see covert recording below), the Trust will only record images, with no audio.
PURPOSE OF USING CAMERAS
The Trust considers it necessary and proportionate to install and use cameras within the park. The data collected from the system will assist in:
· Monitoring of wildlife
· Prevention or detection of criminal and anti-social activity.
· Identification and prosecution of potential offenders.
LOCATION OF CAMERAS
Cameras are mobile and will be located at strategic points within the Park boundary where there is a particular wildlife interest or criminal / Anti-social behaviour has a history of occurrence.
All cameras (with the exception of those that may be temporarily set up for covert recording) are also visible.
Appropriate signs are displayed so that members of the public are aware they are entering an area covered by CCTV.
COVERT RECORDING
The Trust is aware that covert recording (potentially including video and audio) can only be done in exceptional circumstances for example where the Trust has a request from applicable authorities to record specific criminal activity taking place.
RECORDING AND RETENTION OF IMAGES
Cameras will only be activated once motion within the camera detection zone has been detected. To minimise the impact on the general public and reduce the number of images taken, the cameras will normally only be activated between late afternoon and early morning.
Images are all digital recorded on sim cards within the cameras. Normally cards will be removed and the data downloaded once every one to two weeks. Data then should be downloaded from the sim cards within 2 days, with the sim card data then being deleted.
Images are to be reviewed within 2 weeks of download. Images of interest will only be retained when any of the following conditions are met:
· Content contains no recognisable member of the public.
· Content contains a recognisable member of the public who is aware and agrees to the retention of the image.
· Content may be used to potentially identify criminal or anti-social behaviour.
Retained images will be stored electronically on the Trusts shared drive and a back-up device.
Retained images may only be circulated to Trustees, members of the public within the image (only if all members within the image agree) or relevant authorities where criminal or anti-social activity has taken place.
MEMBER OF THE PUBLIC ACCESS RIGHTS
Under the UK’s data protection laws, including the General Data Protection Regulation (GDPR), individuals have the right on request to receive a copy of the personal data that the Trust may hold about them, including images if they are recognisable from the image.
If you wish to access any potential images relating to you, you must make a written request to the Trust. This can be done by using this email address enquiries@liquoricepark.co.uk. Your request must include the date and approximate time when you believe the images were recorded, a photo of yourself and the location of the camera, so that the images, if they still exist, can be easily located and your identity can be established as the person in the images.
The Trust will usually respond promptly and in any case within one month of receiving a request. However, where a request is complex or numerous the Trust may extend the one month.
The Trust will determine whether disclosure of your images will reveal third party information, as you have no right to access images relating to other people. In this case, the images of third parties may need to be obscured if it would otherwise involve an unfair intrusion into their privacy.
If the Trust is unable to comply with your request because access could prejudice the prevention or detection of crime or the apprehension or prosecution of offenders, you will be advised accordingly.
The Trust will not make a charge for such a request, but we may charge a reasonable fee, or refuse such request if you make a request which is manifestly unfounded, excessive, or repetitive.
IMPLEMENTATION
All trustees are responsible for the implementation of and compliance with this policy and the operation of the camera system. They will conduct a regular review of the Trusts use and processing of camera images and ensure that it remains compliant with the laws regulating data protection and privacy. Any complaints or enquiries about the operation of the Trusts camera system should be addressed for the attn. of “The Chairman” at enquiries@liquoricepark.co.uk
DATA PROTECTION
The Company will process the personal data collected in connection with the operation of the Camera policy in accordance with its data protection policy. Inappropriate access or disclosure of this data will constitute a data breach and should be reported immediately to the Trusts Chairman (marked for the attn. of “The Chairman” at enquiries@liquoricepark.co.uk).
REVIEW
This policy should be reviewed annually to ensure it is relevant and proportionate at all times and complaint with current legislation.
V30.3.23