Privacy Policy | www.suip.co.uk

Definitions

For the purpose of the Policy the following definitions will apply:

‘CCTV’ is Closed Circuit Television System.
‘SUIP Ltd’ refers to Innovation Park Management company, Stirling University Innovation Park Ltd
‘Data Controller’ is SUIP Ltd.
‘Innovation Park’ refers to SUIP Ltd in relation to Scion House.

1.0 Scope

This Policy is binding on all visitors and tenants of the Innovation Park and all employees of contracted out services. It also applies to all other persons who maybe present, for whatever reason, in Scion House, Stirling University Innovation Park.

2.0 Ownership and operation

The CCTV system is operated by SUIP Ltd Management. The CCTV system, all recorded material and copyright are owned by the Innovation Park.

3.0 Principles

The system is intended to provide an increased level of security in the working environment for the benefit of those who study, work, or visit the Innovation Park.

The following principles will govern the operation of the CCTV system:

The CCTV system will be operated fairly and lawfully and only for the purposes authorised by SUIP Ltd;
The CCTV system will be operated with due regard for privacy of the individual;
Any changes to the purposes for which the CCTV system is operated will require the prior approval of the Head of Innovation Park.

4.0 Purpose of the CCTV system

The system is intended to provide an increased level of security in the working environment for the benefit of those who study, work, or visit the Innovation Park.

The CCTV system will be used to respond to the following key objectives:

Detect, prevent or reduce the incidence of crime.
Assist with the apprehension and prosecution of offenders.
Prevent and respond effectively to all forms of harassment and public disorder.
Improve communications and the operational response of security patrols.
Reduce the fear of crime and create a safer community.
Gather evidence by a fair and accountable method.
Provide emergency services assistance.
Assist with health and safety issues by detecting potential incidents.
Investigate suspected breaches of the Innovation Park Regulations.
Protecting the physical environment.

As community confidence in the system is essential, all cameras will be operational taking into account short periods for maintenance and repair. An appropriate maintenance programme is in place. All operators of the system will receive appropriate training.

5.0 System details

The CCTV system consists of centrally controlled and monitored cameras situated on Scion House property that monitor and record activities within key Reception area. The system will be housed in our Maintenance & Reception Services office in Scion House. All access to the Maintenance & Reception Services office for whatever purpose will be routinely monitored and recorded.

6.0 Installation and signage

Cameras shall be installed in such a manner as not to overlook private domestic areas. Cameras shall not be hidden from view and signs will be prominently displayed at the main entrance to Scion House and other key locations. The signs will indicate:

The presence of monitoring and recording
That images are being monitored and recorded for the purposes of crime prevention and public safety
Contact details for our installer - 01236 727233

If at any time mobile cameras are employed, their use will also be governed by this Policy and appropriate temporary signage or announcements will be made.

7.0 General data protection regulations

Where images of living, identifiable individuals are deliberately recorded, this is likely to comprise those individuals’ personal data. The collection, use and storage of personal data are governed by the General Data Protection Regulations (GDPR) and the Data Protection Act 2018. SUIP Ltd is registered with the Information Commissioner as a Data Controller.

The Innovation Park uses CCTV for the purposes detailed above. The legal basis for this processing is that it is in the legitimate interests of both the property, its staff, tenants and members of the public visiting the Innovation Park to maintain a safe environment.

Given that any particular sequence of CCTV recording may include personal data, all such recordings will be treated in accordance with the Data Protection legislation.

Data subjects’ rights, including a right of access to their personal data, (in accordance with Article 15 of the GDPR), will be respected where recordings are confirmed to comprise personal data. Where an individual requests access to recordings believed to be their personal data, the matter shall be referred to the SUIP Ltd’s Data Protection Officer (lynn.harris@suip.co.uk).

8.0 Access to live footage and recordings including personal data

Access to live footage

Images captured by the system will be monitored in the Maintenance & Reception Services office which is a secure room. For operational purposes, and in accordance with the stated purposes of the system, the live CCTV footage is only monitored by designated specific SUIP Ltd staff and Campus Security, trained in their duties.

Non-essential access to the Maintenance & Reception Services office is controlled.

Live images may be viewed at any time by the police and University of Stirling Campus Security, however these services do not have the power to record the images or to re-position or focus the cameras directly.

Access to recordings

For operational purposes and in accordance with the stated purposes of the system, only designated security staff shall have primary access to CCTV recordings. Access may be granted to the police if appropriate and the requisite data release form is completed.

The Head of the Innovation Park or nominee may permit the viewing of the CCTV recorded materials by other University staff where this is necessary in connection with the purposes detailed above such as prevention of crime, assisting in the apprehension and prosecution of offenders, enforcing University regulations or matters of national security.

Where Innovation Park staff or any other person requires access to CCTV recorded materials that contain identifiable individuals for any other purpose, the matter shall be referred to the Data Protection Officer.

Disclosure of Recorded Material

As the main purpose of the CCTV system is to prevent crime and assist in the apprehension and prosecution of offenders, designated SUIP Ltd staff may release CCTV recorded materials to the police where the Innovation Park has initiated contact with the police and there is a reasonable belief that the CCTV recorded materials will be of assistance.

Where the police or other official body with prosecuting powers approach the Innovation Park and request access to CCTV recorded materials they shall be asked to provide appropriate documentation confirming that the information is necessary for either the prevention of crime or the apprehension or prosecution of offenders, matters of national security or is necessary in connection with legal proceedings.

Where recordings contain no identifiable individuals or other personal data such as visible registration numbers, footage may be releasable under the Freedom of Information (Scotland) Act 2002 (FOISA). Requests received under FOISA will be dealt with by the Freedom of Information Unit.

9.0 Retention of recorded materials and disposal

CCTV recordings and other materials produced from them shall be retained for a maximum of 30 days unless an incident is recorded which requires further investigation either by SUIP Ltd/a Campus Security Officer, the police or another external body with prosecuting powers.

In the latter case, recordings shall be kept for a longer period as determined by the nature of the investigation.

All media that are no longer required, on which recordings were made will be securely and permanently destroyed and the appropriate details entered in the Destruction Records.

10.0 Breaches of code

A copy of this Policy will be made available to anyone requesting it. Any complaint concerning misuse of the system will be treated seriously and dealt with in accordance with SUIP Ltd’s complaint handling meausures. In the first instance complaints will normally be investigated by the Head of Innovation Park or nominee with advice from the Data Protection Officer when appropriate.

Any member of staff found to be in breach of this Policy shall be dealt with in accordance with SUIP Ltd’s disciplinary procedure. Where appropriate, the police will be asked to investigate any matter relating to the CCTV system which is deemed to be of a criminal nature.

11.0 Contact details

If you have any questions about the operation of the CCTV system you should contact the Head of Innovation Park in the first instance.

Lynn.Harris@suip.co.uk +44 (0) 1786 448333

If you have any questions relating to data protection these can be addressed to: info@suip.co.uk in the first instance.

You have the right to lodge a complaint against SUIP Ltd regarding data protection issues with the Information Commissioner’s Office.