CCTV Policy for CLIFFORD CAR SALES Jersey

Clifford Car Sales CCTV Policy

1. Purpose of CCTV Surveillance

At Clifford Car Sales, we have implemented Closed-Circuit Television (CCTV) surveillance to:

Enhance security: Protect our premises, vehicles, and assets from theft or damage.
Ensure health and safety: Monitor and maintain a safe working environment for all accessing our premises.
Prevent and investigate misconduct: Address instances of theft, vandalism, or other inappropriate behaviour.

2. Legal Compliance

We are committed to complying with the Data Protection (Jersey) Law 2018 (DPJL), which governs the use of personal data in Jersey. Key compliance measures include:

Data Controller Registration: Clifford Car Sales is registered as a data controller with the Jersey Office of the Information Commissioner (JOIC).
Lawful Basis for Processing: Our use of CCTV is based on the lawful basis of "legitimate interests," specifically for the protection of property, staff, and customers.
Data Protection Impact Assessment (DPIA): A DPIA is being conducted to assess and mitigate risks associated with CCTV surveillance. If the DPIA identifies a high risk that cannot be mitigated, we will consult with the JOIC before proceeding .

3. Scope and Placement of Cameras

CCTV cameras are strategically placed in areas where there is a legitimate need for surveillance, such as:

Garage forecourt and parking bays: To monitor vehicle maintenance and repairs.
Reception and customer areas: To ensure customer safety and service quality.
Storage and parts rooms: To prevent theft and ensure inventory control.

Cameras are not installed in areas where individuals have a reasonable expectation of privacy, including:

Toilets and changing rooms: No surveillance is conducted in these private areas.

4. Data Collection and Usage

Footage Access: CCTV footage is accessible only to authorized personnel for legitimate purposes.
Data Retention: Footage is retained for a maximum of 30 days, after which it is securely deleted unless required for ongoing investigations .
Usage: Footage is used solely for the purposes outlined in this policy and is not shared with third parties without proper authorization.

5. Employee and Visitor Rights

Subject Access Requests (SARs): Employees and visitors have the right to request access to CCTV footage that features them. Requests should be submitted in writing and will be processed within one month .
Complaints: Individuals can raise concerns about CCTV surveillance with management or the JOIC.

6. Policy Review and Updates

This CCTV policy will be reviewed annually to ensure its effectiveness and compliance with applicable laws. Updates will be communicated to all staff, and any changes will be reflected in training materials and signage.