Strode Business Centre and Retail Park CCTV Policy

The Company has CCTV on the site (Strode Business Centre & Strode Retail Park) in the belief that it will play a legitimate role in helping to maintain a safe and secure environment for all our employees, tenants and their employees, employees of their suppliers and any contractors or any other visitors.

Images that are recorded by CCTV are personal data and as such must be processed in accordance with data protection laws. The Company are committed to complying with our legal obligations in order to appropriately handle and protect all personal data and details of this Policy are outlined below.

This policy sets out how our Company:

  • uses CCTV
  • those responsible for CCTV use
  • the rights individuals may have in relation to CCTV
  • who has access to CCTV images
  • how individuals can raise any queries or concerns they may have

This policy has been written with due regard to the following legislation:

  • General Data Protection Act/Regulations 2018
  • Protection of Freedoms Act 2012
  • Freedom of Information Act 2000
  • The Human Rights Act 1998
  • Information Commissioner’s Office Code of Practice for CCTV

ROLES AND RESPONSIBILITIES:

Claybrook personnel and their advisors have responsibility for ensuring compliance with Data Protection laws and the effective operation of the policy.

They are also in charge of the day to day operational responsibility for CCTV, which includes:

  • Ensuring all footage is obtained in line with legal requirements
  • How the CCTV data recorded is stored.
  • Ensuring that CCTV footage is destroyed in line with legal requirements when it falls outside of the retention period

Access to CCTV footage data will be strictly limited to these authorised personnel and will be password protected.

The names of the company personnel with these responsibilities are as follows:

  • Seb Manley (Smartech)
  • Eddie Doig
  • David Sykes
  • Matt Capps
  • Andrew Ware
  • Lorraine Curtis

THE PURPOSE OF THE CCTV SCHEME:

  • To prevent or detect crime and protect the building and assets from damage, disruption, theft and vandalism
  • Maintain a safe environment for all employees, tenants and their employees and all other users of the site
  • To support law enforcement bodies in the prevention, detection and prosecution of crime
  • To support any internal investigation – incident or accident in relation to health and safety

THE DATA COLLECTED FROM CCTV WILL BE PROCESSED LAWFULLY (IN LINE WITH DATA PROTECTION PRINCIPLES), FAIRLY AND IN A TRANSPARENT MANNER IN RELATION TO THE INDIVIDUALS.

MONITORING:

The cameras are only placed where they do not intrude on anyone’s privacy and are necessary to fulfil their purpose.

The cameras are on open display and there are warning signs placed throughout the premises advertising their use and where the system is active.

None of the cameras record sound.

The employees involved with the CCTV system are trained and understand and observe the legal requirements relating to the processing of any Data.

The system will be regularly maintained and serviced plus all cameras will be maintained, cleaned and kept in good working order

SITING OF CAMERAS:

CAMERA 1: Outside Unit 6 (pointing east)

CAMERA 2: In central corridor (pointing east)

CAMERA 3: In central corridor (pointing towards access from ramp)

CAMERA 4: On corner of Unit 7a (pointing towards entrance gate)

CAMERA 5: On corner of Unit 1 (pointing west)

CAMERA 6: On corner of Unit 1 (pointing north)

CAMERA 7: Outside Unit 8 (pointing east)

CAMERA 8: Outside Unit 8 (pointing west)

CAMERA 9: At the rear of Unit 2 Strode Retail Park (SRP)

CAMERA 10: On the rear corner of Unit 1 SRP (pointing towards entrance gates)

CAMERA 11: On the front corner of Unit 1 SRP (pointing towards front car park)

CAMERA 12: At the rear of Unit 2 SRP (pointing towards rear of Unit 3 SRP)

CAMERA 13: On the rear corner of Unit 1 SRP (pointing to side car park)

CAMERA 14: Front of Office B looking to Strode Road

CAMERA 15: Rear of Unit 2 Strode RP looking at Enterprise gates

CAMERA 16: Roof of NSL office looking at rear entrance from Huxley Close

Strode CCTV and Fire Assembly Plan(opens in new tab)

DATA USAGE:

The Company will ensure that the rights of individuals recorded on our CCTV are protected. The data gathered from such systems is stored in a way that maintains its integrity and security.

We will ensure that the data is only used for the purpose specified in this policy document and it will not be used for any other purpose.

The data is stored locally and will be erased after 2 months if there is no reason to retain it (unless it is required following a crime or as part of an accident investigation).

Where the CCTV system is linked to the internet and made available remotely, appropriate security safeguards are in place to ensure security of data and to prevent illegitimate access and tampering.

The Company will periodically review the ongoing use of the CCTV to ensure that its use remains necessary, appropriate and in compliance with Data Protection laws.

The surveillance system is registered with the Information Commissioners Office (ICO) in line with data protection legislation.

ACCESS TO INFORMATION:

Under the Data Protection Act 2018, individuals have the right to obtain confirmation that their personal information is being processed.

All images from the system belong to Claybrook Ltd and remain the property of the company.

Recordings which are not required for the purposes of security of employees and premises will not be retained for longer than is necessary (14 days)

It is important that access to, and disclosure of, images recorded is restricted and carefully controlled, not only to protect the rights of individuals but also to ensure that the evidence remains intact should the images be required for evidential purposes.

Access to recorded images is restricted to the nominated employees who will decide whether to allow requests for access to data subjects and/or third parties.

Individuals have the right to submit a request to gain access to their personal data in order to verify the lawfulness of the processing.

Any such information request must be made to the company in writing before information is supplied and the company will respond to that request without delay.

The Company will need to verify the individual before that information is released to ensure that the request is compliant and not false.

Viewing of images must be documented as follows:

  • The name of the person accessing the recording
  • The date and time of removal of the recordings
  • The name of the person viewing the recordings
  • The reason for viewing the recordings
  • The outcome – if any of the viewing
  • The date and time of the replacement of the recordings

If the images are removed for use in legal proceedings then specific authorisation of removal and provision to a third party must be documented – including any crime incident number assigned to the images, the place where the recordings are to be taken and the signature of the collecting Police Officer, where appropriate.

COMPLAINTS:

All complaints must be submitted in writing and addressed to the company. Where the complainant is a third party, and the complaint relates to someone else, the written consent of the data subject will be required.

All complaints will be acknowledged within 7 days and a written response issued within 21 days.

 

Date: April 2026