Closed-Circuit Television (CCTV) Notice

At the Equality and Human Rights Commission, we operate our own closed-circuit television (CCTV) system in our Manchester office, Arndale House. 

We do not operate a CCTV system in our Cardiff, Glasgow or London offices, however there may be CCTV cameras in operation at these locations which are managed by the relevant building management companies for similar purposes. 

This notice aims to inform staff and visitors of the arrangements in place for the operation of CCTV within our Manchester office. It also sets out the accepted use and management of our CCTV equipment and images to ensure that we comply with data protection and other associated legislation and relevant codes of practice. 

Personal data processed via our CCTV system is handled in line with our Data Protection Policy. 

Our CCTV system is used to assist in the prevention and detection of crime, to ensure the security of our premises, and to maintain the health and safety of our staff and visitors. The images captured by the system will only ever be used for these purposes. 

The system also acts as a deterrent against unauthorised access to our premises and helps to mitigate against any unlawful acts which may arise from such access. Where an actual or suspected unlawful act is detected, we may use images captured by the system to assist in the identification of individuals involved. 

The use of a CCTV system can be intrusive, but we have taken steps to balance reasonable expectations of privacy against the necessity of using CCTV to ensure a proportionate approach, for example: 

• our system has only  been put in areas which are necessary to achieve the purpose of using CCTV and does not overlook any workstations, meeting rooms or other communal areas
• we have limited the data captured by the CCTV system to the recording of video images only, there is no audio recording
• our system does not use automatic facial recognition technology
• we undertake the processing ourselves and we do not instruct any suppliers to do this on our behalf
• signage is in place at our Manchester office to inform staff and visitors of when they are entering a CCTV monitored area

Images are stored securely within our CCTV system. Access to the system is limited to members of our ICT and Facilities teams, and only as required for their role. 

The images are retained for 31 calendar days from the date recorded in line with our retention schedule, after which the data is automatically overwritten. Images may be retained longer in the event of a subject access or other individual rights request, or where required as evidence for the purposes outlined in this notice.   

We do not routinely disclose CCTV images. 

We may sometimes disclose images to other organisations, but only where necessary for the purposes outlined in this notice. This may include sharing images with the police and other law enforcement agencies for the prevention and detection of crime, and other organisations if necessary to comply with our health and safety obligations. 

The Facilities team has overall responsibility for the operation and maintenance of our CCTV system and will ensure that personal data captured by the system is processed in line with our policies and procedures, and data protection legislation. 

Senior managers are responsible for viewing CCTV images when investigating an incident or suspected incident. 

The Corporate Law and Regulatory Compliance Team is responsible for handling subject access and other individual rights requests in respect of personal data captured by the system and will periodically audit the systems use to ensure it is compliant with data protection legislation.  

Manchester, Arndale House 

• 1 CCTV camera at each of the four entrance / exit points to our demised area.