Privacy statement for building security CCTV

Who we are

Building security CCTV systems in buildings and property used by Glasgow City Council or any of the Council's arms' length external organisations (ALEOs) is controlled by Glasgow City Council ("GCC" or "the Council"), a local authority established under the Local Government etc. (Scotland) Act 1994. Its head office is located at City Chambers, George Square, Glasgow G2 1DU, United Kingdom.  For operational properties occupied by an ALEO, data is controlled jointly by the Council and the ALEO or ALEOs occupying the premises.  Details of the council's ALEOs can be found here.  CCTV in the City Chambers complex is under the exclusive control of the Council.

You can contact the Council's Data Protection Officer by post at either of the above addresses, or by email at: dataprotection@glasgow.gov.uk. The council's data protection officer is also data protection officer for the ALEOs.

CCTV in secondary schools in Glasgow is managed on the council's behalf by 3Ed.  This privacy statement does not cover CCTV in secondary schools.

The council also operate public space CCTV.  This is subject to a different privacy statement which can be accessed here.

Why do we need your personal information and what do we do with it?

Your information is being collected to use for the following purposes:

•         To help with the reduction or negation of criminal activity within the areas covered by the CCTV provisions

•         To help with the increased apprehension and prosecution of offenders

•         Risk management and environmental concerns

•         Increase in public safety & public reassurance

•         Reduction in the fear of crime

•         Footage of staff will be processed in accordance with the privacy statement covering managing the employment relationship between GCC and an employee, available here.

Legal basis for using your information

CCTV is operated by GCC as part of our statutory functions as your local authority.  Processing your personal information is necessary for the performance of a task carried out in the public interest by the council.

By its very nature, CCTV may capture more sensitive information about people.  We also need to process this more sensitive personal information about you for reasons of substantial public interest as set out in the Data Protection Act 2018. It is necessary for us to process it to carry out key functions as set out in law.

We may also process data about the commission of offences. This is one of the main reasons for operating a CCTV system.  Local authorities such as the Council are authorised to provide CCTV to promote the prevention of crime or the welfare of victims of crime. This power is contained in section 163 of the Criminal Justice and Public Order Act 1994.

Who do we share your information with?

Disclosure of images from CCTV will be controlled and consistent with the purpose for which the System was established. The Council has an obligation to assist in the prevention of crime and will therefore supply specific images which we are asked to provide Police Scotland or other crime detection agencies, provided we are satisfied that the request is connected to an investigation and that disclosure would be lawful and proportionate.

Security footage may also be requested by insurance companies, solicitors and others in connection with civil claims where the footage contains information relevant to the claim in question.  We will only release footage in response to such a request if we are satisfied that disclosure is genuinely necessary to allow the action to proceed.

The Council will ensure that any external agencies that receives disclosed information are fully aware of and accept their responsibilities as outlined in the General Data Protection Regulation (GDPR) and Data Protection Act 2018.  Where footage is passed to criminal investigation agencies such as the police, we consider that they are then the data controller of that footage and

International transfers:

All CCTV data held by GCC is held within the UK.

How long do we keep your information for?

Some security systems connect to the council's Alarm Receiving Centre (ARC).  Security CCTV footage is retained by the Council (or occupying ALEO) for a set period; it is then automatically deleted unless there is a specific reason to keep particular footage for longer.  Different retention periods apply to different CCTV systems dependent on system capabilities and local circumstances, but typically this will be between 14 and 31 days. 

Specific reasons for retaining footage typically arise because the footage includes evidence of criminal behaviour or possible criminal behaviour.  Where CCTV operators observe possible criminal behaviour they will alert Police Scotland to this fact.  Police Scotland will generally request a copy of the relevant footage, which as a rule will be complied with.  At the point of making such a request, Police Scotland become data controller of their copy of the footage in question. 

Your rights under data protection law

• access to your information - you have the right to request a copy of the personal information that we hold about you.
• correcting your information- we want to make sure that your personal information is accurate, complete and up to date. Therefore you may ask us to correct any personal information about you that you believe does not meet these standards.
• Deletion of your information-you have the right to ask us to delete personal information about you where:

I.            you think that we no longer need to hold the information for the purposes for which it was originally obtained

II.            you have a genuine objection to our use of your personal information - see Objecting to how we may use your information below

III.            our use of your personal information is contrary to law or our other legal obligations.

Objecting to how we may use your information - You have the right at any time to tell us to stop using your personal information for direct marketing purposes.  We do not use CCTV for any marketing activity.

Restricting how we may use your information- in some cases, you may ask us to restrict how we use your personal information.  This right might apply, for example, where we are checking the accuracy of personal information that we hold about you or we are assessing the objection you have made to our use of your information.  This right might also apply if we no longer have a basis for using your personal information but you don't want us to delete the data.  Where this right is realistically applied will mean that we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.

Please contact us as stated above if you wish to exercise any of these rights.

Profiling or automated decision-making processes

GCC and its ALEOs do not make use of profiling or automated decision-making in relation to building security CCTV.  Some CCTV systems may be used for analytical purposes such as footfall count but this does not involve any form of identification of individuals.

Complaints

If you do not have access to the internet you can contact us on 0141 287 1055 to request hard copies of any of the above documents.

We aim to directly resolve all complaints about how we handle personal information.  However, you also have the right to lodge a complaint with the Information Commissioner's Office.  Contact details for our Data Protection Officer and for the ICO can be found on our website under www.glasgow.gov.uk/privacy.

If your complaint is not about a data protection matter you can find details on how to make a complaint on our website at www.glasgow.gov.uk/complaints

More information

For more details on how we process your personal information visit www.glasgow.gov.uk/privacy.

If you do not have access to the internet you can contact us via telephone to request hard copies of our documents.