Close circuit television (CCTV) Privacy Notice

This Privacy Notice explains what to expect when collects personal data about you when visiting our premises, how we use your personal data when captured on Close Circuit Television (CCTV) and your rights regarding this information.

For further information of how we use your personal data, in general, please see our Website Privacy Notice.

When we refer to ‘personal data’ in this Privacy Notice, we mean any information about you from which you can be identified. It does not include data where your identity has been removed (anonymous data).

What personal data will we collect and how

The MSG has CCTV in operation on our premises. CCTV will capture images in real time wherever the cameras are pointed. These cameras may capture footage of you while you are on premises. Cameras have been situated outside of our buildings. There are signs in place to inform you where cameras are in use.

The personal data we collect from you through the use of CCTV will include:

• Still images
• Video recordings
• Vehicle registration numbers

We do not deliberately set out our CCTV to capture any special category personal data. However, cameras may incidentally record information which falls within these categories, like any visible disabilities or health issues, criminal activities, race characteristics.

Additionally, footage from cameras may be used as evidence regarding criminal offences or related security measures.

Where images or recordings show evidence of an offence, it may be combined with other personal data we hold about you. That data may include:

• Your name and address
• Any other data deemed necessary

 Why we collect personal data

The MSG collects personal data through the CCTV system for various reasons:

• To control access to the building and to ensure the security of the building, the safety of our patients, staff, stakeholders and visitors, as well as property and information located or stored on the premises.
• To prevent, deter, and if necessary, investigate unauthorised physical access, including unauthorised access to secure premises and protected rooms.
• To prevent, detect and investigate a theft of equipment or assets owned by the MSG, patients, staff or visitors or threats to the safety of personnel working at the office (e.g. fire, physical assault).

To enhance our safety and security related procedures, redacted CCTV footage may be used for training purposes.  The CCTV cameras are installed and focused in a way that only people who want to access the site including parking areas are filmed.  A camera is also installed internally within our records department.

The system may also be used as an investigative tool or to obtain evidence in internal investigations or disciplinary procedures (in exceptional circumstances, the data may be transferred to investigatory bodies in the framework of a formal disciplinary or criminal investigation).

 How we use your personal data and who we may share it with

The MSG is the legal entity who initiated the processing of personal data and who determines the objective of this processing activity. We collect, use and store the data for the reasons set out in this Privacy Notice.

We will not:

• Sell your data to third parties
• Share your data with third parties for marketing purposes

CCTV footage is retained in a secure environment and is only accessible by authorised personnel who have a legitimate reason to do so. [We use Amalgamated Facilities Management (AFM) to install and maintain our CCTV.]

CCTV footage will only be processed internally by our Facilities Department who are authorised to do so and any other departments where there is a legitimate and lawful reason for their involvement, such as Governance colleagues in the event of an investigation and our DPO (Data Protection Officer) in the event of a Subject Access Request.

We will not transfer or disclose personal information, other than: as identified in this Privacy Notice, to our trusted third-party suppliers where there is a legitimate and lawful reason. We will also share your personal data if required to do so by law, for example, by court order, or to prevent fraud or crime.

We may be asked to provide footage to assist the police with any criminal damage or their investigations. We may also be asked for footage from insurance companies should there be an incident involving car accidents or damage to cars parked on our premises.

Where requests for CCTV footage are made by third parties, for example a member of the public, redactions will be applied to protect the identity of the other individuals.

Images will not be shared with the media or placed on the internet or on any social media platforms.

Images will not be released outside of Guernsey subject to any legal requirements.

What legal reasons allows us to use your data in this way

The legal reasons the MSG may use for processing your personal data includes:

• Legitimate interests – The CCTV system is required to help prevent and detect crime, safeguard staff and visitors. The processing is necessary for the purposes of legitimate interests.
• Court Order/Judgment – Processing of CCTV footage/images may be required to comply with a court order or judgement.
• Legal proceedings / Court / Tribunal / Legal Advice / Legal Rights – Processing of CCTV footage/images many be required for the purpose of, or in connection with legal proceedings (including prospective legal proceedings), discharging any court or tribunal functions, obtaining legal advice or otherwise for the purposes of establishing, exercising, or defending legal rights.
• Special Category Data (‘special authorisations for processing’) - The lawful basis for processing special category data captured by the CCTV system is the prevention, detection or investigation of any unlawful act or omission

 How long we keep your data

Under normal circumstances, the footage will be held for [30] days after the initial collection date on our CCTV system. After this period, the footage will be automatically and permanently deleted unless there is a legal requirement to retain and/or legitimate reason; for example, police investigation or insurance purposes.

Images required for investigative or evidential purposes may be retained beyond 30 days and are securely disposed of upon completion or conclusion of the purposes for which it has been retained.

What are your rights are how can you enforce them?

Under the [Data Protection (Bailiwick of Guernsey) Law 2017], you will have, where appropriate, the right to:

• Be informed about how we use your personal data;
• Access a copy of your personal data by making a Subject Access Request;
• Ask us to rectify, erase or restrict the processing of your personal data;
• Object to the processing of your personal data;
• Request that we transfer your personal data to you or another organisation.

Please note, some of the rights listed above are subject to exemptions.

To exercise your rights please contact us at privacy@msg.gg.

How to contact us

If you have any questions or concerns about anything in this document or if you consider that your personal data has been misused or mishandled, you can contact us at: privacy@msg.gg.

Alternatively, if you are unhappy with how your data has been used by the MSG or feel your data protection rights have been breached, you have the right to lodge a complaint to the Office of the Data Protection Authority by emailing or calling 01481 742074.

Changes to this Privacy Notice

We will keep this privacy notice under regular review, and we will place any updates here.

This Privacy Notice was last updated: 2 May 2024