This CCTV Policy describe the CCTV system and explains the safeguards we have put in place to protect personal data of any individuals who may be captured by the CCTV system cameras.
Scope and Purposes
Astoria Culinary and Hospitality Institute (ACHI) has installed and operates a Closed-Circuit Television (CCTV) system at its premises which are monitored and recorded on a 24-hour basis.
This Policy describes and explains the safeguards we have put in place to protect personal data of any individuals who may be captured by the CCTV.
The collection, use, disclosure, storage and other processing of personal data by the CCTV system is for purposes of protecting of the security of our Properties, facilities, networks, systems and providing and managing a safe environment for our customers, visitors, personnel and other individuals, including without limitation:
- deterring crime and anti-social behavior
- assisting in the detection, investigation, and prosecution of offenses
- for the purposes where recordings may resolve any facts of the dispute
- for the taking and defense of litigation.
CCTV System Description
The cameras operate full time (24 hours a day, 7 days a week).
There are three (3) types of CCTV cameras installed in the premises of the properties: fixed, PTZ and fish-eye. Fixed cameras do not allow operators to zoom in on or otherwise follow individuals.
Another type of cameras is installed inside the vans and cars which are called Dash Cam which is used for recording videos of accidents to prove fault. Dash Cam also records voices but its sole purpose is to support any proven accidents.
The cameras record movement detected in the area under surveillance as well as the time, date and location of the footage.
The cameras currently installed in the premises do not conduct sound recording however considerations to this policy will apply to new cameras with built-in sound recording that will be installed in the future.
Location of Cameras
The placement or siting of CCTV cameras shall not unreasonably intrude on the privacy of individuals.
The CCTV system provides coverage over the following areas:
- entrances and exists to the properties including emergency exits
- lobbies, waiting areas, including loading and unloading bays
- corridors and hallways
- elevators and stairs within the properties
- dinning areas, gyms and other facilities
- warehouse or store houses
- front desk, cashiering and other offices
- other premises or areas as required by the business
Our CCTV systems do not infringe on restricted areas (i.e. toilets/restrooms or other similar places).
Upon installation, all equipment is tested to ensure that only the designated areas are monitored.
Notices
The public shall be notified of CCTV surveillance operations through signage installed near the areas monitored, digital signages and websites.
CCTV Privacy Policy are posted in our websites for public to view.
Authorized Personnel
Footage captured and recorded by the CCTV is accessible only by authorized personnel of the Security Department.
Video Quality
The images and/or footage produced by the equipment will as far as possible be of a quality that is effective for the purpose(s) for which they are intended.
Security Measures
The CCTV System is used as a complement to other security measures implemented to safeguard the security of our facilities, networks and systems and the safety of our customers, visitors, personnel and other individuals. The CCTV System enhances other access control and physical intrusion prevention systems within our premises.
Access to the images recorded by our CCTV System is restricted and carefully controlled.
The security of the IT systems containing the CCTV footage is safeguarded through technical, organizational, and physical means.
Footage recorded by our CCTV cameras are encrypted and otherwise stored in a secure manner to protect their confidentiality, integrity and availability. The digital perimeter of the IT infrastructure is protected under our Privacy Policy and IT Security Policy.
The CCTV monitoring and storing equipment is kept in a segregated, secure area to which only authorized personnel with security clearance are granted access.
All persons with access to the CCTV System are under binding/contractual confidentiality commitments.
Security protocols have been put in place to ensure that only authorized personnel are allowed to view, monitor and otherwise process CCTV footage.
Upon installation, all equipment is tested to ensure that suitable quality pictures are available in live and play back mode. All CCTV equipment is maintained regularly.
Procedure for Access Requests
Individuals who request access to CCTV footage must submit this formally in writing, with sufficient details to identify the section of footage with which they are concerned and to enable the Company to determine that the person making the request is the data subject of that specific recording. A written request should be made and submitted to our Duty Manager for proper dissemination.
Upon receipt of the written request, it is referred to the Security Department and the Data Protection Officer who will determine whether disclosure is appropriate. After the evaluation of the request, request will be sent and discussed with the General/Resort Manager of the property for final approval.
Our response in allowing access to CCTV footage will depend on other considerations on the ease of access to the footage and the need to protect other people’s privacy.
Disclosure/Transfer
Access granted to CCTV footage is tiered: either by viewing or providing a copy, the latter option being allowed only when proportional to the purpose of the request. At all times, the footage to be disclosed, either by viewing or providing a copy, are only those that are necessary and not excessive to the purpose for which they are being disclosed.
CCTV footage may be disclosed in the following instances:
- Law enforcement and criminal investigations. On requests for CCTV footage to be disclosed in relation to a criminal investigation, the Company shall require the law enforcement officer or the requesting party to provide sufficient proof as to the occurrence of a crime and the investigation thereof as well as proof of authority of the law enforcement officer before release of the CCTV footage.
- Court Order. Requests for disclosure and use of CCTV footage and images by virtue of a lawful order of a court of competent authority is allowed, taking into consideration the pertinent rules on issuance of subpoena.
- Administrative investigations. Use of CCTV footage for purposes of an administrative investigation may be allowed. The requesting party must provide sufficient proof of the investigation being conducted or the pending complaint before an administrative body.
- Other third-party requests. Third-party access requests for CCTV footage and images is evaluated on a case-to-case basis with due regard to the rights to privacy of individuals, and applicable provisions of relevant laws.
We shall act on viewing requests within five (5) working days after the approval of the written request and submission of required additional supporting documents if ever is requested by the Security Department; while requests for copies of CCTV footage will be acted upon within fifteen (15) working days after receipt of the request or of required documentation. We may charge a reasonable fee for providing a copy of the CCTV footage to cover administrative costs as may be applicable.
Retention Period
CCTV recordings are generally maintained for at least thirty (30) calendar days and are thereafter overwritten making recovery impossible, except that they may be kept for a longer duration in certain instances including:
- where there is legal basis
- where we are legally required to do so, or
- where the footage otherwise has investigative value (such as where a security incident occurs) and the recordings are stored as necessary for the duration of the investigation, the prosecution of the incident or the exercise, enforcement or defense of any legal claims.
The foregoing list is not exhaustive and there may be other circumstances where the CCTV is retained for longer than thirty (30) calendar days as is justified under the circumstances.
Where an incident or suspected incident has been identified under the appropriate procedures mentioned in this Policy, the pertinent portion of the CCTV footage is to be retained for that incident.
Regular Review
ACHI undertakes yearly periodic reviews of the CCTV System and the associated internal policies, procedures, protocols and processes. These reviews will be used to assess the continued need for the CCTV System, as well as the adequacy, necessity and proportionality of the CCTV System.
Last updated on 27 September 2024