1. Fair Processing
1.1 We, Shoreham Port Authority of Nautilus House 90-100 Albion Street, Southwick, Brighton, England, BN42 4ED (“Shoreham Port” “us” “we” “our”), may process your personal data through our use of CCTV and Dashcams.
1.2 We believe that CCTV and other surveillance systems have a legitimate role to play in helping to maintain a safe and secure environment for all our colleagues and visitors. However, we recognise that this may raise concerns about the effect on individuals and their privacy. This notice is intended to address such concerns and to detail the processing activities of Shoreham Port.
1.3 We are committed to complying with our legal obligations and ensuring that the legal rights of colleagues and members of the public, relating to their personal data, are recognised and respected.
2. Definitions
2.1 For the purposes of this notice the following terms have the following meanings:
2.1.1 CCTV: means fixed cameras designed to capture and record images of individuals and property.
2.1.2 Dashcam(s): means a video camera mounted on the dashboard or windscreen of a vehicle and used to capture and record the view of the road and traffic through the windscreen.
2.1.3 Personal data: means data relating to a living individual who can be identified from that data. This will include video images of identifiable individuals.
3. About this notice
3.1 We currently use CCTV to view and record individuals on and around the various sites in Shoreham Port’s control (Sites), including around the perimeter and entrances of the Sites. We also have CCTV around our leased property portfolio and inside our receptions at Nautilus House and Maritime House. Our CCTV is in accordance with the International Ship and Port Facility Security Code’s (ISPS) guidance.
3.2 We have CCTV in our cranes, which capture footage of the unloading of cargo from ships and the movement of goods and people across our terminals.
3.3 We currently use Dashcams in all our vehicles (Vehicles) in the control of Shoreham Port. At the time of writing this includes the following vehicles - 10x electric vehicles (Renualt Kangoo’s), 3x Engineering box vans, 2x Engineering flatbed trucks, 1x Property flatbed truck, 1x Operations flatbed truck and 1x Operations Minibus.
3.4 This notice outlines why we use CCTV and Dashcams, how we will use CCTV and Dashcams and how we will process personal data recorded by CCTV and Dashcams to ensure we are compliant with applicable data protection legislation.
3.5 We recognise that information that we hold about individuals is subject to applicable data protection legislation. Images recorded by surveillance systems are personal data which must be processed in accordance with applicable data protection legislation.
3.6 This notice relates to the processing of personal information of all colleagues (employees, directors, officers, consultants), contractors, volunteers, interns, workers, and other members of the public, including visitors.
4. Reasons for the use of CCTV
4.1 We believe that such use is necessary for the legitimate business purposes of Shoreham Port, including:
4.1.1 to prevent and supress acts of terrorism against the maritime community, in accordance with the International Maritime Organization’s guidance;
4.1.2 to prevent crime, anti-social behaviour and protect buildings and assets from damage, disruption, vandalism and other crime;
4.1.3 for the personal safety of colleagues, visitors and other members of the public and to act as a deterrent against crime;
4.1.4 to prevent colleagues from being at risk from unsafe working practices;
4.1.5 to detect, prevent and reduce the incidence of offences against port users and other individuals;
4.1.6 preventing or reducing the risk of uncontrolled or unauthorised access within the Sites;
4.1.7 preventing and responding effectively to harassment; and
4.1.8 to support law enforcement bodies in the prevention, detection and prosecution of crime.
5. Reasons for use of dash cams
5.1 We believe that such use is necessary for the legitimate business purposes of Shoreham Port, including:
5.1.1 to prevent crime, anti-social behaviour and protect buildings and assets from damage, disruption, vandalism and other crime;
5.1.2 to support law enforcement bodies in the prevention, detection and prosecution of crime; and
5.1.3 to ensure we have accurate footage to refer to in the event of an incident/investigation. This could be used as part of an insurance investigation or health and safety investigation for example. The footage is also used for continuous improvement and learning, especially around health and safety practices.
6. Monitoring
6.1 CCTV is located at various locations throughout the Sites and continuously records footage 24 hours a day at each location. Footage is recorded on a 30 day loop and stored digitally. Footage is only transferred (in a secure manner) to hard copy following an incident with the approval of the Harbour Master. In such case there shall be a record of such download, and this will be logged accordingly.
6.2 CCTV locations are chosen to minimise viewing of spaces not relevant to the legitimate purpose of the monitoring. As far as practically possible, CCTV will not focus on private homes, gardens or other areas of private property and are generally not hidden from public view.
6.3 Dashcams monitor footage from the dashboard or windscreen of the Vehicles and only record footage when the Vehicle is in operation (when the engine is running).
6.4 CCTV and Dashcams will not be used to record sound.
6.5 Shoreham Port monitors its CCTV footage internally and does not appoint an external provider to undertake such monitoring. All ISPS operators are engaged by Shoreham Port.
7. How we will operate any CCTV and dash cams
7.1 We will ensure that signs are displayed at the entrance of the surveillance zones and in suitable locations to inform individuals that CCTV is in operation and to alert individuals that their image may be recorded. Such signs will contain details of the organisation operating the system, the purpose for using the surveillance system and who to contact for further information, where these things are not obvious to those being monitored.
7.2 Our Vehicles do not have signs on them notifying the driver that a Dash Cam is fitted.
7.3 Live feeds, images and footage from CCTV and/or Dashcam’s are operated and/or observed by authorised colleagues of Shoreham Port only whose role requires them to have access to such data.
7.4 Colleagues operating and reviewing CCTV and Dashcam footage will be given appropriate training to ensure they understand and observe the legal requirements related to the processing of relevant data. They will also be required to follow internal safeguards and code of practice to ensure integrity and security.
7.5 All CCTV and Dashcam equipment will be kept secure so as to prevent tampering and interference from unauthorised individuals.
8.Use of data gathered by CCTV and dashcams
8.1 In order to ensure that the rights of individuals recorded by the CCTV system of via Dashcams are protected, we will ensure that data gathered from CCTV and Dashcams is stored in a way that maintains its integrity and security. Such personal data shall not be sold, used for commercial purposes or used for the provision of entertainment.
8.2 Data collected through CCTV is processed by Shoreham Port only. No third party processors are involved in monitoring, accessing and storing such data.
8.3 Data collected through Dashcams is processed by Shoreham Port only. No third party processors are involved in monitoring, accessing and storing such data.
9. Retention and erasure of data gathered by CCTV and dash cams
9.1 Data recorded by the CCTV system will be stored on a recorder in Nautilus House, connected to our Nautilus House server. It will only be transferred to a hard copy in the event of an incident or where there is an approved request for disclosure or subject access request.
9.2 Data from Dashcams and CCTV cameras will not be retained indefinitely but will be permanently deleted once there is no reason to retain the recorded information. Exactly how long images will be retained for will vary according to the purpose for which they are being recorded. In most cases, recorded images will be kept for no longer than 50 days, unless there is a reason why we need to keep this data for longer for example, where we have been asked to retain it for longer by an insurer or law enforcement or other authorities.
9.3 At the end of their useful life, all images stored in whatever format will be erased permanently and securely. Any physical matter such as tapes or discs will be disposed of as confidential waste. Any still photographs and hard copy prints will be disposed of as confidential waste.
10. Ongoing review of CCTV and dashcam use
10.1 We will ensure that the ongoing use of existing CCTV and Dashcams is reviewed periodically to ensure that their use remains necessary and appropriate, and that any surveillance system is continuing to address the needs that justified its introduction.
11. Requests for disclosure
11.1 No images or footage from our CCTV cameras will be disclosed to any third party, without express permission being given by Harbour Master. Data will not normally be released unless satisfactory evidence that it is required for legal proceedings or under a court order has been produced and such disclosures are only made in accordance with applicable data protection legislation, the Regulation of Investigatory Powers Act 2000 or other requirements under applicable laws.
11.2 Where Shoreham Port receives a request to by a third party to review images of footage from its CCTV it shall record this as an external request.
11.3 In other appropriate circumstances, we may:
11.3.1 allow law enforcement agencies to view or remove CCTV footage where this is required in the detection or prosecution of crime; or
11.3.2 share CCTV footage with insurers if there is a notifiable event1
11.4 Each master copy made of footage will have a unique reference number and we will maintain a record of all disclosures of CCTV footage as well as details of footage removed from Shoreham Port.
12. Subject access requests
12.1 Data subjects may make a request for disclosure of their personal information and this may include Dashcam or CCTV images (subject access request). In order for us to locate relevant footage, any requests for copies of recorded CCTV images must include the date and time of the recording, the location where the footage was captured and, if necessary, information identifying the individual. Shoreham Port will ask you to complete a subject access request application form to enable you to provide such information required.
12.2 We reserve the right to obscure images of third parties when disclosing CCTV data as part of a subject access request, where we consider it necessary to do so.
12.3 Data subjects may be asked if they merely wish to view their data, otherwise they will be provided with a copy of the CCTV data in standard format, unless otherwise agreed.
13. Complaints
13.1 If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioners Office (ICO). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us at dataprotection@shoreham-port.co.uk or on 01273 598100. Similarly, if you have any questions about this notice or any concerns about our use of CCTV, please contact dataprotection@shoreham-port.co.uk.
14. Requests to prevent processing
14.1 We recognise that, in rare circumstances, individuals may have a legal right to object to processing and in certain circumstances. For further information regarding this, please contact dataprotection@shoreham-port.co.uk.
15. Changes to this notice
15.1 We may amend this notice at any time. The notice will be regularly reviewed to ensure that it meets legal requirements, relevant guidance published by the ICO, ISPS and industry standards.
15.2 This notice was published/last updated on 21st December 2021
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