1 - Policy Summary

Haynes Brothers, Limited (referred to as ‘the Company’ throughout this policy), has a CCTV surveillance system across its locations (referred to as ‘CCTV’ throughout this policy).

This CCTV monitors each of our sites, listed as locations on our company website, 24 hours a day and 7 days a week. This data is continuously recorded.

2 - CCTV System Overview

  • This policy details the purpose, use and management of the CCTV systems and details the procedure to be followed in order to ensure that the Company complies with relevant legislation and the current Information Commissioner’s Office CCTV Code of Practice.
  • Camera locations have been chosen as the needs of the business dictate, covering the Health & Safety of our staff and the security of our staff and premises.
  • Our surveillance sound systems are set by default to record with no sound, however, this will be changed by our IT Department if deemed necessary for the security of our staff, customers, visitors and contractors, for health and safety and to protect our business interests.
  • Images are monitored by the Company’s authorised personnel during working hours and can also be accessed remotely at other times if required.

3 - Purpose

  • The Company will ensure that live feeds from cameras and recorded images are only viewed by approved members of its staff whose role requires them to have access to such data. This includes HR staff involved in disciplinary or grievance matters, supervisory staff managing departmental throughput and cover, our management teams to oversee Health & Safety and security within their department and our IT staff who are required to monitor the system's security.
  • Live feeds from CCTV cameras are monitored only where this is reasonably necessary, for example, to protect health and safety and our business interests, for security or to manage throughput for each department.

4 - Covert Surveillance

  • The Company does not carry out covert monitoring or surveillance (that is, where personnel are unaware that the monitoring or surveillance is taking place) unless, in highly exceptional circumstances, there are reasonable grounds to suspect that criminal activity or extremely serious malpractice is taking place and, after suitable consideration, the Company reasonably believe there is no less intrusive way to tackle the issue.
  • Any covert monitoring or surveillance will be carried out for a limited and reasonable period of time consistent with the objectives of the monitoring or surveillance and will relate only to the specific suspected criminal activity or malpractice.

5 - Monitoring & Recording

  • A camera audit and review of users will be conducted regularly to ensure that all access remains relevant to the requirement of this policy.
  • No surveillance cameras will be placed in areas where there is an expectation of privacy (for example, in toilets) unless, in very exceptional circumstances, it is judged by senior management to be necessary to deal with misconduct or criminal issues.
  • Images of individuals and their vehicles will be recorded to prevent crime and protect the buildings and assets of the Company from damage, disruption, vandalism and any other crime.
  • These images will also be used for the personal safety of staff, customers and visitors of the Company and to assist in the day-to-day management of Company Business, including ensuring the health and safety of staff, customers and visitors.
  • Images will be recorded to support law enforcement bodies in the prevention, detection and prosecution of any crime carried out on any of the Company locations.
  • Images will be recorded to assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings with the Company’s staff.

6 - Signage

  • Signs have been placed at vehicle entrances and throughout the premises in order to inform staff, visitors and customers that CCTV is in operation.

7 - Access to Images by Third Parties

  • Where images from our CCTV system are relevant to other individuals or customers (for instance if they show that their car has been damaged while on the premises), the Company may share images with those other occupants/individuals if it considers that this is reasonably necessary for any of the purposes set out above.
  • The Company is not responsible for the use other individuals make of these images.
  • The Company may allow law enforcement agencies to view or remove CCTV footage where this is required in the detection or prosecution of crime.
  • The Company will keep a record of all disclosures of CCTV footage on an encrypted system and only senior management in the business will have access to them.

8 - Retention of Images

  • Automated images are held on a secure, encrypted server for up to 90 days before being permanently deleted, or unless a retention request has been made by authorised users.
  • Images held in excess of their retention period will be reviewed on a regular basis and those no longer required for evidential purposes, will be deleted.

9 - Complaints

  • Complaints concerning the CCTV policy must be made in writing and addressed to the Data Protection Officer for Haynes Brothers, at the address shown on the website.
  • All complaints will be acknowledged and a written response made available within 31 days.
  • Where the complainant is a third party and the enquiry is relating to an individual the written consent of the relevant individual will be required.
The Company reserves the right to amend this policy at any time.