CCTV AND ANPR ON THE OXSHOTT WAY ESTATE
Privacy Policy (version 1, 3 October 2023)
Oxshott Way Residents’ Association Limited (“OWRA”) is the company that owns, maintains and manages the roads, verges and other common areas within the Oxshott Way Estate (the “Estate”), including Oxshott Way, Oxshott Rise, Harebell Hill, Broad Highway, Mizen Way, Mizen Close, Spinnaker Close and The Bowsprit. Our shareholders are the owners of the residential properties within the Estate.
OWRA has recently completed the installation of CCTV and ANPR equipment on the Oxshott Way Estate (“the Estate”). CCTV cameras and ANPR cameras have been installed at each of the five gated vehicle entrances to the Estate and CCTV cameras have also been installed at three locations where public footpaths meet the Estate roads (on Mizen Way, Broad Highway and Oxshott Rise). The CCTV and ANPR systems are expected to become operational in October 2023. The images and number plate data that these systems will capture constitutes “personal data” and collecting and using that personal data is governed by the legislation noted below.
When collecting the data specified in this privacy policy, OWRA is the Data Controller. This policy has been produced in line with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 (DPA 2018) and the Human Rights Act 1998 (HRA 1998).
OWRA is registered with the Information Commissioner’s Office (“ICO”) under registration number ZB559797. The registered Data Protection Officer is the OWRA Director with responsibility for Security and at the date hereof is Graham Marr.
Any changes to this policy will be posted on this webpage.
This policy explains:
Why we process personal data;
What personal data we collect and process;
When and why we will share personal data;
How long we will keep personal data for.
This policy also explains your rights as a data subject, including information about the right to access the information we hold about you. In certain circumstances, you also have the right to object to the processing of your data, to request that processing be restricted, or to request that we rectify or erase the data we hold about you. Further information is provided below.
Under data protection law, if you request that we action any of these rights, we must verify your identity before providing information to you.
We must also provide you with an explanation if we do not agree with your request.
Purposes – OWRA’s “lawful basis” for collecting and processing personal data
The CCTV and ANPR cameras have been installed with the following objectives:
· To assist in the prevention and detection of crime;
· To assist in enhancing the safety of residents of the Estate; and
· To enable and assist in traffic management and access control over vehicles entering the Estate.
Together these objectives constitute the “legitimate interests” that OWRA has for collecting and processing the personal data which give it a lawful basis for doing so.
What data is processed when you enter or leave the Estate
What data do we collect?
When you enter or leave the Estate via each of the five gated entrances, we will collect and process data comprising images of vehicles and people entering or leaving the Estate and/or the Vehicle Registration Mark (VRM) of such vehicles. CCTV images will also be captured at three footpath locations within the Estate (one each on Mizen Way, Broad Highway and Oxshott Rise).
Clearly visible signs are being placed, in advance of the systems becoming operational, at all pedestrian and vehicular entrances where ANPR and/or CCTV cameras are located to inform residents, visitors and members of the public that ANPR and/or CCTV is in operation.
How do we collect data?
Images of vehicles and VRMs will be collected via ANPR cameras and/or CCTV cameras. Images of pedestrians (or cyclists) will be collected on the CCTV cameras at the footpath locations.
Data Security
Data Storage
Data captured by the CCTV and ANPR systems will be stored in cloud-based systems operated by specialist third-party companies operating in the security industry.
In the case of images captured by the CCTV cameras, the relevant 3rd party is Avigilon Alta Cloud Security, a division of Motorola Solutions. Further information can be found at https://www.avigilon.com/vms/cloud.
In the case of data and images captured by the ANPR cameras, the relevant 3rd party is CloudPass. Further information can be found at https://cloudpass.com/anpr.
Both Avigilon Alta and CloudPass store the relevant data on servers within datacentres located within the EEA.
Access to and disclosure of images to third parties
A request for images made by a third party should be made in writing.
In limited circumstances it may be appropriate to disclose images to a third party, such as when a disclosure is required by law, in relation to the prevention or detection of crime or in other circumstances where an exemption applies under relevant legislation.
All unexpected requests for CCTV images by third parties including requests made by the police, should be referred to OWRA’s Security Director (who is OWRA’s Data Protection Officer under OWRA’s registration with ICO) in the first instance and if not available to the OWRA Communications Director, who will advise on the application of any appropriate exemptions.
A record of any disclosure made under this policy will be held on the ANPR & CCTV management system, itemising the date, time, camera, requestor, authoriser and reason for the disclosure.
The images and data - How long will we keep your data for?
We will store your personal data for no longer than necessary to support the purposes explained above.
Generally, we will not retain your personal data for more than between 14 and 30 days. Exceptions to this will generally only apply where the images and/or data are required as evidence in relation to the investigation of a relevant crime or other security or safety incident.
What are your rights as a data subject?
Data protection law gives you the following rights. For further information, including to make a request or ask a question about your rights, please contact security@owra.co.uk.
We will review each request we receive. Under data protection law we do not have to agree with your request but if we refuse your request, we will still contact you within one month to explain why.
To object to the processing of personal data.
In certain circumstances as prescribed by the relevant legislation, individuals have the right to object to the processing of personal data. Any such objection must be based on your particular situation. We will review each request we receive and if we refuse your request, we will inform you of the reason why we have not taken action.
To access personal data. Individuals have the right to request a copy of the data held about them. We are required to verify your identity before passing you information and we may contact you upon receipt of your request to clarify your request. We will be unable to process your request until we have all required information.
To be informed about the processing of personal data. Individuals have the right to be informed about the collection and use of personal data. This information is contained within this privacy policy.
To request that the processing of personal data be restricted. Individuals may have the right to request the restriction or suppression of personal data. This right will only apply in certain circumstances.
To request that personal data is corrected if it is inaccurate. Individuals may request that inaccurate personal data is rectified, or completed if it is incomplete.
To ask that personal data be erased. The right to erasure is also known as ‘the right to be forgotten’ and individuals can request that their personal data is erased. This right will only apply in certain circumstances.
To request to move, copy or transfer personal data (“Data Portability”). The right to data portability allows individuals to move, copy or transfer personal data easily from one IT environment to another. This right will only apply in certain circumstances.
Rights relating to automated decision making, including profiling Individuals have the right to be given information about such processing, request human intervention or challenge a decision. This right will only apply in certain circumstances.
How can you contact the Information Commissioner’s Office?
If you are concerned about our processing of your data or if you have a privacy related query not answered by this policy, please contact us using the contact details below. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO). For further information, please refer to the ICO website, www.ico.org.uk.
How can you contact OWRA if you have a privacy related query?
If you have any questions about our privacy policy, how we use or your data collected by the CCTV or ANPR systems, or your data rights, please contact OWRA at security@owra.co.uk or communications@owra.co.uk.
Alternatively, you can write to us with your privacy related query at:
Oxshott Way Residents Association Limited, Suite A, Coveham House, Downside Bridge Road, Cobham, Surrey, KT11 3EP