CCTV AND SECURITY CAMERA DATA PROTECTION POLICY
Pitshanger Allotment Conservation Association
Effective date: September 2026
1. Introduction
Pitshanger Allotment Conservation Association (“the Association”) operates security cameras at the allotment site for the protection of the allotment, its facilities, property and those using the site.
This policy explains how the Association operates its security camera system and how images and other information collected by the system are handled.
The Association is committed to using security cameras responsibly, proportionately and in accordance with applicable data protection legislation.
This policy is published on the Association’s website so that information about the system’s operation is readily available to allotment holders, visitors, and members of the public.
2. Purpose of the CCTV system
The principal purpose of the security camera system is to protect the allotment site and its property.
The cameras may be used to: deter and prevent theft; deter and prevent vandalism and damage to Association or allotment holders’ property; deter and prevent trespass and unauthorised access; monitor access to the allotment site, including vehicle access; record vehicle movements within areas covered by the cameras; assist in identifying vehicles involved in an incident; assist in investigating theft, vandalism, trespass, unauthorised access or other incidents; protect the safety and security of people using the allotment site; and provide relevant evidence to the police or other appropriate authorities where necessary.
The system is not intended for the routine monitoring of individual allotment holders, visitors or members of the public.
The cameras will not be used for purposes unrelated to the legitimate security purposes described in this policy.
3. Location and positioning of cameras
Security cameras will be installed at appropriate locations within the allotment site.
The cameras will be positioned and configured so far as reasonably practicable to monitor areas within the allotment site that require protection.
The Association will seek to minimise the capture of images outside the allotment site and, in particular, will seek to avoid unnecessary capture of:
neighbouring homes; neighbouring gardens; private areas belonging to adjoining properties; and areas of land or public access that do not require monitoring for the stated security purposes.
Where the camera equipment provides privacy or exclusion zones, these will be used where appropriate.
The field of view of the cameras will be reviewed if the position or surroundings of the site change.
4. Overt operation and signage
The security cameras will operate openly and are not intended to be covert surveillance equipment.
Appropriate CCTV/security signage will be displayed in relevant locations to inform people that security cameras are in operation.
The signage will provide sufficient information to direct individuals to the Association’s website or other source of information concerning the operation of the CCTV system and the handling of personal data.
5. Information collected
The CCTV system may record:
images of people entering, leaving or using areas within the camera’s field of view; images of vehicles entering, leaving or operating within areas covered by the cameras; vehicle registration numbers where these are visible; the date and time at which images are recorded; and
other information incidentally visible within the camera’s field of view.
Vehicle registration information will be treated as personal data where it can be linked to an identifiable individual.
The Association does not use facial recognition or other biometric identification through the CCTV system.
6. Lawful basis for processing
The Association considers that the operation of its security camera system is necessary for its legitimate interests in protecting the allotment site, its facilities and property, preventing and investigating crime and unauthorised access, and helping to protect people using the site.
The Association will seek to ensure that the operation of the system is proportionate to these purposes and that personal information is not collected or used unnecessarily.
7. Access to CCTV recordings
Access to recorded images will be strictly restricted to a maximum of three designated members of the Association’s Committee.
The Committee will nominate the individuals authorised to access the CCTV system.
No other committee member, allotment holder, Association member, visitor or other person will have routine access to recorded images.
The authorised committee members may access recordings only where there is a legitimate reason, including: an actual or suspected theft; vandalism or damage; trespass or unauthorised access; an incident involving a vehicle; a security or safety incident; a complaint concerning an incident captured by the cameras; a request or investigation by the police or another appropriate authority; or checking the operation of the CCTV system where necessary.
Authorised persons must maintain the confidentiality and security of recordings and must not use or disclose recordings for personal purposes.
Access permissions will be reviewed whenever there is a change in the individuals authorised by the Committee.
8. Security of the CCTV system
The Association will take reasonable technical and organisational measures to protect CCTV recordings from unauthorised access, alteration, disclosure, loss or destruction.
Access to the camera system will be protected by appropriate security measures.
Where the equipment provides individual accounts, passwords, encryption or other security functions,these will be used where reasonably practicable.
CCTV access credentials must not be unnecessarily shared.
The Association will take reasonable steps to ensure that former authorised users no longer have access when their authorisation ends.
9. Retention of recordings
CCTV recordings will normally be retained for no longer than 30 days.
The system will, where technically possible, be configured to automatically delete or overwrite recordings after the applicable retention period.
The Association considers a maximum 30-day period appropriate because incidents involving theft, vandalism, trespass or unauthorised access may not always be discovered immediately.
Where an incident is identified within the 30-day period, relevant recordings may be retained for longer where reasonably necessary to:
investigate the incident; report or assist with a police investigation; deal with a complaint; make or defend a legal claim; or meet another legitimate legal or regulatory requirement.
Where recordings are retained beyond 30 days for one of these purposes, they will be securely deleted as soon as they are no longer required.
10. Disclosure of recordings
CCTV recordings will not routinely be disclosed to allotment holders, members of the public or other thirdparties.
Recordings may be disclosed where there is a lawful basis to do so, including where disclosure is necessaryor appropriate for: the prevention or detection of crime; a police investigation; a criminal or civil legal matter; an insurance claim; the protection of individuals or property; or
compliance with a legal obligation.
Where a recording is disclosed, the Association will disclose only information that is reasonably necessary for the relevant purpose.
11. Requests for access to CCTV images
Individuals have rights under applicable data protection legislation concerning personal data relating to them.
An individual may, subject to applicable exemptions and requirements, request access to CCTV images in which they appear.
Requests should be made to the Association using the contact details provided below.
To assist the Association in locating relevant footage, a request should provide, where possible: the date of the incident; the approximate time;
the location; and a description of the individual or circumstances concerned.
Because recordings are normally deleted after 30 days, requests should be made as soon as reasonably practicable.
The Association will deal with requests in accordance with applicable data protection legislation.
12. Privacy and proportionality
The Association recognises that CCTV involves the collection of information about people and therefore has implications for privacy.
The system will be operated in a manner intended to balance the legitimate security needs of the allotment with the privacy of allotment holders, visitors, neighbours and members of the public.
The Association will periodically consider whether: the cameras remain necessary; the camera locations remain appropriate; the field of view remains proportionate; unnecessary areas are being recorded; the retention period remains appropriate; and access to recordings remains appropriately restricted.
13. Complaints
Anyone who has concerns about the operation of the CCTV system or the way in which their personal data has been handled may contact the Association.
Complaints should be sent to:
Pitshanger Allotment Conservation Association
Email: secretary @pitshangerallotments.org
The Association will investigate complaints and take appropriate action where necessary.
Individuals may also raise concerns with the Information Commissioner’s Office (ICO) where appropriate.
14. Responsibility for the CCTV system
The Association’s Committee is responsible for overseeing the operation of the CCTV system and ensuring that it is operated in accordance with this policy.
The Committee will ensure that no more than three designated committee members have routine access to recordings.
The Committee will also review the system and this policy periodically.
15. Changes to the CCTV system
Any significant change to the number, location or purpose of the cameras will be considered by the Committee before implementation.
The Association will consider the privacy and data protection implications of any proposed change.
Where appropriate, this policy and the information provided on the Association’s website will be updated.
16. Review of this policy
This policy will be reviewed periodically and whenever there is a significant change to the CCTV system or its use.
Date of policy: September 2026
Last reviewed: N/A
Next review: September 2027
17. Contact details
For enquiries, data protection requests or complaints concerning the Association’s CCTV system:Pitshanger Allotment Conservation AssociationEmail: secretary@pitshangerallotments.org Website: https://pitshangerallotments.org/