Refurbs CCTV Policy





Refurbs Flintshire uses closed circuit television (CCTV) images to provide a safe and secure environment for employees and for visitors to the Company’s premises, such as service-users, families, contractors and suppliers, and to protect the Company’s property.


This policy sets out the use and management of the CCTV equipment and images in compliance with data protection legislation (the GDPR) and the CCTV Code of Practice.


The Company’s CCTV facility records images only.  There is no audio recording i.e. conversations are not recorded on CCTV (but see the section on covert recording).


Purposes of CCTV


The purposes of the Company installing and using CCTV systems include:


  • To assist in the prevention or detection of crime.
  • To assist in the identification and prosecution of offenders.
  • To monitor the security of the Company’s business premises.
  • To ensure the safety of the Company’s staff and service-users.
  • To ensure that health and safety rules and Company procedures are being complied with.
  • To assist with the identification of unauthorised actions or unsafe working practices that might result in disciplinary proceedings being instituted against employees and to assist in providing relevant evidence.


Location of cameras


Cameras are located so that recordings meet the stated purpose and so that they provide clear images. 


All cameras are also clearly visible.


Appropriate signs are prominently displayed so that employees, service-users, families and other visitors are aware they are entering an area covered by CCTV. 


Recording and retention of images


Images produced by the CCTV equipment are intended to be as clear as possible so that they are effective for the purposes set out above.  Maintenance checks of the equipment are undertaken on a regular basis to ensure it is working properly and that the media is producing high-quality images.


Images may be recorded either in constant real-time (24 hours a day throughout the year), or only at certain times, as the needs of the business dictate.


As the recording system records digital images, any CCTV images that are held on the hard drive of a PC or server are deleted and overwritten on a recycling basis and, in any event, are not held for more than 14 days.  Once a hard drive has reached the end of its use, it will be erased prior to disposal. 


Images that are stored on, or transferred on to, removable media such as CDs are erased or destroyed once the purpose of the recording is no longer relevant.  In normal circumstances, this will be a period of one month.  However, where a law enforcement agency is investigating a crime, images may need to be retained for a longer period.


Access to and disclosure of images


Access to, and disclosure of, images recorded on CCTV is restricted.  This ensures that the rights of individuals are retained.  Images can only be disclosed in accordance with the purposes for which they were originally collected. 


The images that are filmed are recorded centrally, Access to recorded images is restricted to the nominated operators of the CCTV system and to those line managers who are authorised to view them in accordance with the purposes of the system. Access is secured by the need to have a password and a pin.  Viewing of recorded images will take place without members of the public being able to review. If media on which images are recorded are removed for viewing purposes, this will be documented.


Disclosure of images to other third parties will only be made in accordance with the purposes for which the system is used and will be limited to:


  • The police and other law enforcement agencies, where the images recorded could assist in the prevention or detection of a crime or the identification and prosecution of an offender or the identification of a victim or witness.
  • Prosecution agencies, such as the Crown Prosecution Service.
  • Relevant legal representatives.
  • Line managers involved with disciplinary and performance management processes.
  • Individuals whose images have been recorded and retained (unless disclosure would prejudice the prevention or detection of crime or the apprehension or prosecution of offenders).


The Retail Manager of the Company (or another member of the Senior Management Team acting in their absence) is the only person who is permitted to authorise disclosure of images to external third parties such as law enforcement agencies.


All requests for disclosure and access to images will be documented, including the date of the disclosure, to whom the images have been provided and the reasons why they are required.  If disclosure is denied, the reason will be recorded.


Individuals’ access rights


Under the GDPR individuals have the right on request to receive a copy of the personal data that the Company holds about them, including CCTV images if they are recognisable from the image. 


If you wish to access any CCTV images relating to you, you must make a written request to the Company’s Data Protection Officer for the supply of the images requested.  Your request must include the date and approximate time when the images were recorded and the location of the particular CCTV camera so that the images can be easily located and your identity can be established as the person in the images.  The Company will respond promptly and in any case within one month of receiving the request. 


We will always check the identity of the employee making the request before processing it.


The Data Protection lead will first determine whether disclosure of your images will reveal third-party information as you have no right to access CCTV images relating to other people.  In this case, the images of third parties may need to be obscured if it would otherwise involve an unfair intrusion into their privacy.


If the Company is unable to comply with your request because access could prejudice the prevention or detection of crime or the apprehension or prosecution of offenders, you will be advised accordingly.


Staff training


The Company will ensure that all employees handling CCTV images or recordings are trained in the operation and administration of the CCTV system and on the impact of the GDPR with regard to that system. 




The Company’s Data Protection lead is responsible for the implementation of and compliance with this policy and they will conduct a regular review of the Company’s use of CCTV.  Any complaints or enquiries about the operation of the Company’s CCTV system should be addressed to them.


Data Protection Lead


The Retail Manager will be The Data Protection Lead and point of contact



(Version 1.1  26th February 2019)