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Glasgow City Council

Privacy Statement for city-wide public space CCTV and the Traffcom traffic management cameras

Who we are

Public space CCTV (PSCCTV) and Traffcom CCTV in Glasgow is the responsibility of a number of different agencies:

PSCCTV is monitored by Community Safety Glasgow ("CSG"). CSG is a company limited by guarantee, incorporated in Scotland with Company Number SC130604, a registered Scottish Charity (Charity Number SCO17889), and having its registered office at Eastgate, 727 London Road, Glasgow G40 3AQ.

Traffcom (traffic management CCTV) is monitored by Glasgow City Council ("GCC" or "the Council"), a local authority established under the Local Government etc. (Scotland) Act 1994. Its head office is located at City Chambers, George Square, Glasgow G2 1DU, United Kingdom.

CSG and GCC share a Data Protection Officer; you can contact the Data Protection Officer by post at the above addresses, or by email at: dataprotection@glasgow.gov.uk, and by telephone on 0141 287 1055.

Police Scotland is able to assume control of PSCCTV in certain circumstances, described below. You should consult the Police Scotland website http://www.scotland.police.uk/ for details of how Police Scotland handles personal information including CCTV footage.

GCC has announced that it intends to bring a number of services - currently provided on its behalf by CSG - back in-house. This is likely to include PSCCTV monitoring. If and when this service is brought within the management of the Council then the Council will become data controller of this data. We will update this privacy statement to reflect any changes in data control.

CSG is also responsible for monitoring building security CCTV systems on behalf of GCC; this includes facilities owned by the Council but operated by other Council ALEOs, in particular Glasgow Life. Details of the organisations making up the council family can be seen at www.glasgow.gov.uk/aleos ).

For purposes of security CCTV, CSG acts as a data processor to the Council and the data controller of these systems is the Council, regardless of the part of the council family which operates the facility or building in question.

 

Why do we need your personal information and what do we do with it?

Your information is being collected to use for the following purposes:

•        To help with the reduction or negation of criminal activity within the areas covered by the CCTV provision

•        To help with the increased apprehension and prosecution of offenders

•        Risk management and environmental concerns

•        To increase public safety and public reassurance

•        To reduce the fear of crime

•        To enhance and complement partnership working

•        To assist in the management of major events and incidents

 

Legal basis for using your information

PSCCTV is operated by CSG on behalf of GCC as part of its statutory functions as a local authority.  Processing your personal information is necessary for the performance of a task carried out in the public interest on the Council's behalf by CSG.

By its very nature, PSCCTV may capture more sensitive information about people.  We also need to process this more sensitive personal information about you for reasons of substantial public interest as set out in the Data Protection Act 2018. It is necessary for us to process it to carry out key functions as set out in law.

We may also process data about the commission of offences. This is one of the main reasons for operating a PSCCTV system.  Local authorities such as GCC are authorised to provide CCTV to promote the prevention of crime or the welfare of victims of crime. This power is contained in section 163 of the Criminal Justice and Public Order Act 1994.

Who do we share your information with?

Disclosure of images from PSCCTV will be controlled in terms of the purpose for which the System was established. As an organisation jointly owned by GCC and the Scottish Police Authority, CSG has an obligation to assist in the prevention of crime and will therefore supply specific images which we are asked to provide to Police Scotland or other crime detection agencies, provided we are satisfied that the request is connected to an investigation and that disclosure would be lawful and proportionate.

CSG will ensure that any external agency that receives disclosed information is fully aware of and accepts its responsibility as outlined in the General Data Protection Regulation (GDPR) and Data Protection Act 2018.

International transfers

All CCTV data held by GCC and CSG is held within the UK.

How long do we keep your information for?

CCTV footage is retained by GCC and CSG for fourteen days; it is then automatically deleted unless there is a specific reason to keep particular footage for longer.

Specific reasons typically arise because the footage includes evidence of criminal behaviour or possible criminal behaviour.  Where CCTV operators observe possible criminal behaviour they will alert Police Scotland to this fact.  Police Scotland will generally request a copy of the relevant footage, which as a rule will be complied with.  At the point of making such a request, Police Scotland becomes the data controller of the footage in question.  If the footage is still, at this point, stored on GCC/CSG equipment, it is held on behalf of Police Scotland which is sole data controller of the footage and GCC and/or CSG are acting as data processors to Police Scotland.

Your rights under data protection law

·         access to your information - you have the right to request a copy of the personal information that we hold about you.

·         correcting your information- we want to make sure that your personal information is accurate, complete and up to date. Therefore you may ask us to correct any personal information about you that you believe does not meet these standards.

·         Deletion of your information-you have the right to ask us to delete personal information about you where:

              I.        you think that we no longer need to hold the information for the purposes for which it was originally obtained

            II.        you have a genuine objection to our use of your personal information - see Objecting to how we may use your informationbelow

           III.        our use of your personal information is contrary to law or our other legal obligations.

 

Objecting to how we may use your information
 

You have the right at any time to tell us to stop using your personal information for direct marketing purposes.  We do not use CCTV for any marketing activity.

 

Restricting how we may use your information

In some cases, you may ask us to restrict how we use your personal information.  This right might apply, for example, where we are checking the accuracy of personal information that we hold about you or we are assessing the objection you have made to our use of your information.  This right might also apply if we no longer have a basis for using your personal information but you don't want us to delete the data.  Where this right is realistically applied will mean that we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.

Please contact us as stated above if you wish to exercise any of these rights.

Profiling or automated decision-making processes

CSG has a system known as Person Search which uses automated processing to locate people, such as someone reported missing, from its recorded footage.  This is based on image recognition software (based on characteristics such as  full body image, textures and clothing colour or unique characteristics) but is not an automated recognition system - the software flags up potential matches which require human intervention before any positive identification can be made.

 

Complaints

We aim to directly resolve all complaints about how we handle personal information. If your complaint is about how we have handled your personal information, you can contact the CSG's and the Council's Data Protection Officer by email at dataprotection@glasgow.gov.uk or by telephone on 0141 287 1055.

However, you also have the right to lodge a complaint about data protection matters with the Information Commissioner's Office, who can be contacted by post at:  Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. By phone on 0303 123 1113 (local rate) or 01625 545 745. Visit their website for more information at- https://ico.org.uk/concerns

Please note if your complaint is not about a data protection matter and concerns matters of service standards, service failures or staff conduct, you can find details of how to make a complaint on our website at http://www.communitysafetyglasgow.org/contact-us/making-a-complaint/  or by phoning 0141 276 7559.

If your complaint is not about a data protection matter you can find details on how to make a complaint on our website at www.glasgow.gov.uk/complaints.
 

More information

For more details on how we process your personal information visit http://www.communitysafetyglasgow.org/privacy-policy/ or www.glasgow.gov.uk/privacy

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