General Policy and Guidelines
- CCTV is used by the High Cross Bars Ltd as part of the operational system for safety and security.
- The primary purpose 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.
- The Front Door Pub operates cameras that are at various locations on the premises. Signage is displayed to highlight the presence of CCTV cameras. These operate on a 24-hour basis seven days a week.
- Recorded images and associated information we be retained for a maximum of 30 days from the date of recording. After a period of up to a maximum of 30 days, the system will automatically overwrite images. However, the company reserves the right to retain images for a longer period where there are objective reasons for doing so.
- 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.
Security and Authorised Use
- 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.
- 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.
- 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:
(a) disclosure of images containing Personal Data to an unauthorised third party, including other employees;
b) Unauthorised processing of Personal Data in the form of copying the images onto disks, website or print format;
c) Unauthorised circulation of images containing Personal Data by email, phone or posting of images containing person data on the internet.
- 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.
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 legislation. Such circumstances may include the disclosure of Personal data in order to:
- Prevent injury or damage to property;
- Meet legal requirements;
- Obtain legal advice, or for the purpose of legal proceedings;
- Meet a request from, or with the consent of, the data subject, or person acting on his behalf.
- Garda Síochána requests for copies of CCTV footage or requests from legally authorised Regulatory agencies should be acceded to where formal written request is provided to the company by the Garda Síochána stating that they are investigating a criminal matter or regulatory matter where they are permitted to access such data. In some instances, where the Garda or a regulator indicate that the viewing of CCTV footage is deemed urgent, then the company may facilitate a viewing without the formal written request but on the understanding hat the formal written request will be sent by the Garda or relevant regulator 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 advisers;
- Pension and medical insurance providers;
- Security providers.
Raymond Carroll, HR Manager. Level 3, Mayoralty House, Flood Street, Galway.
Please note the terms of this policy may changed from time to time to reflect the requirements of ourselves, our suppliers and partners as well as legal and regulatory changes and you should make sure you keep it under regular review.