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We value your privacy

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EDGBASTON ESTATES SECURITY LIMITED

The images and personal information are captured for the purpose of security,
crime detection, public safety and other reasons set out in our privacy notice
(as denoted below), which applies to images and personal information collected
using our CCTV system.


CCTV Privacy Notice Private Space | CCTV Privacy Notice Public Space


CCTV PRIVACY NOTICE PRIVATE SPACE

This notice sets out how Calthorpe Group Management Limited of 76 Hagley Road,
Edgbaston B16 8LU (we, us our) uses your personal information which may be
recorded on our CCTV system. This notice explains how we comply with the law on
data protection and what your rights are and for the purposes of data protection
we will be the controller of any of your personal information recorded on our
CCTV system.

We sub-contract aspects of our CCTV system to Watch Systems Limited, and given
the degree of control that they may have over our CCTV system, in certain
circumstances they may also be a joint controller of any of your personal
information recorded on our CCTV system.  This privacy notice also covers Watch
Systems Limited and so references to “we”, “us” and “our” are where appropriate
also references to Watch Systems Limited of 49 Frederick Road, Edgbaston,
Birmingham, B15 1HN.

We have not appointed a Data Protection Officer to oversee our compliance with
data protection laws, but  contact details of the person responsible for data
protection matters are set out in the “Contacting us” section at the end of this
privacy notice.

1. What information may we hold / process that will relate to you?

We may collect from you video recordings and still pictures which feature you if
you are in the field of vision of any of our CCTV system.  This personal
information may include your activities, your face, car registration details
including make model and colour as well as other visual information about you
which is recorded on our CCTV system.

2. What do we do with your personal information?

As the data controller we will collect personal information on our CCTV system
and use it for the following purposes:

 * For the prevention, reduction, detection and investigation of crime
 * For evidence in any civil, disciplinary or criminal proceedings
 * To assist in investigations
 * For safety and security
 * The monitoring, enforcement of and dealing with traffic related incidents
 * Dealing with any queries, complaints or enquiries
 * Retaining records


As well as being the purposes for which we use your personal information, all of
the above are also legitimate reasons for us to use and store personal
information relating to you which is captured on our CCTV system and legitimate
interests is our main legal basis for processing your personal information. 

We may anonymise any of the personal information we hold on our CCTV system (so
that it does not directly identify you, for example by obscuring your face) and
it therefore ceases to be your personal information.  We may use this anonymised
information for any other purposes.

3. Who we share your personal information with

We share your personal information with the following parties:

 * Suppliers and service providers: to manage and operate the CCTV system as our
   data processor.
 * The police and other law enforcement agencies: to carry out policing, assist
   investigations, trace missing people and investigate alleged criminal
   activities.
 * The security services: where relevant for matters of national security.
 * People who have been injured, attacked or had property damaged or stolen and
   their insurance providers: to assist them with any criminal or civil
   investigations or legal proceedings.
 * People who have been involved in road traffic accidents and their insurance
   providers: to assist with insurance claims, legal claims and investigations.
 * Private and other investigators: to aid their investigations.
 * Any relevant regulators: where we are required to do so by law or to assist
   with their investigations or initiatives, and this includes but is not
   limited to the Information Commissioner’s Office.
 * Other individuals: where we are required to do so by law in response to their
   data subject access request and pixelation/cropping is not viable. 


We do not disclose personal information obtained using our CCTV system to anyone
else except as set out above except where we are permitted or required to do so
by law.

4. Transferring your personal information internationally

The personal information we collect about you is not transferred to or stored in
countries outside of the UK or European Economic Area except as set out in this
section.  

Our directors and other individuals working for us may in limited circumstances
access personal information outside of the UK and European Economic Area if they
are on holiday abroad outside of the UK or European Economic Area.  If they do
so they will be using our security measures and will be subject to their
arrangements with us which are subject to English Law and the same legal
protections that would apply to accessing personal data within the UK.  

In limited circumstances the people to whom we may disclose personal information
from our CCTV system as mentioned in section 3 above may be located outside of
the UK and European Economic Area.  In these cases we will impose any legally
required protections to the personal information as required by law before it is
disclosed.  

If you require more details on the arrangements for any of the above then please
contact us using the details in the “Contacting us” section below.

5. How long do we keep your personal information for

We will keep your personal information for up to approximately 31days after the
recording was made.  After this time the recording stored on the hard drive of
our CCTV system will usually be overwritten.   However if we receive an enquiry
about a particular recording on our CCTV we will generally then retain that part
of the recording until it is no longer required (which will be reviewed on a
three monthly basis).  This period can vary as it will depend upon the
circumstances of the particular case, but for criminal or civil legal
proceedings this could mean that the personal information is retained until
after the legal case and any appeals have been concluded, which may be many
years.  As soon as it is no longer required we will then delete the personal
information. 

6. Your rights in relation to your personal information

You have the following rights in relation to your personal information: (i) the
right to be informed about how your personal information is being used; (ii) the
right to access the personal information we hold about you; (iii) the right to
request the correction of inaccurate personal information we hold about you;
(iv) the right to request the erasure of your personal information in certain
limited circumstances; (v) the right to restrict processing of your personal
information where certain requirements are met; (vi) the right to object to the
processing of your personal information; (vii) the right to request that we
transfer elements of your data either to you or another service provider; (viii)
the right to object to certain automated decision making processes using your
personal information; and (iix) the right to withdraw any consent previously
given by you. 

You should note that some of these rights, for example the right to require us
to transfer your data to another service provider or the right to object to
automated decision making, may not apply as they have specific requirements and
exemptions which apply to them and they may not apply to personal information
recorded and stored in our CCTV system.  For example we do not use automated
decision making in relation to your personal data in our CCTV system.  However
some have no conditions attached, so your right to withdraw consent or object to
processing for direct marketing are absolute rights, though we do not rely on
consent as a lawful basis for processing and direct marketing is not relevant to
our CCTV system.

There is no legal, contractual or other requirement or obligation for you to
provide our CCTV system with your personal information.

More information about your legal rights can be found on the Information
Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to
your rights, please contact us by using the details set out in the “Contacting
us” section below.

We are here to help and would encourage you to contact us to resolve any 
complaint first.  However if you are unhappy with the way we are using your
personal information you can also complain to the UK Information Commissioner’s
Office or your local data protection regulator in the European Economic Area if
you are based outside the UK or bring a claim in the courts.

7. Changes to this notice

We may update this privacy notice from time to time. You are encouraged to
regularly check for any updated version of this privacy notice.

8. Contacting us

In the event of any query or complaint in connection with the personal
information we hold about you or if you would like more information about or to
exercise your rights, you can contact our Head of Legal.  Please email
dataprotection@calthorpe.co.uk or write to us at: Head of Legal , Calthorpe
Estates, 76 Hagley Road, Edgbaston, B16 8LU.  You can use these contact details
for both Calthorpe Group Management Limited and Watch Systems Limited.

Version 28th February 2023

Calthorpe Group Management Limited is a limited company incorporated in England
and Wales. Registered Number: 07582078. Registered Office: 76 Hagley Road,
Edgbaston, Birmingham B16 8LU


CONTACTING US

In the event of any query, or if you would like a copy of this privacy notice
sent to you, you have any queries or wish to exercise any of your rights in
relation to your personal information we hold about you please contact our Data
Protection Officer. Please email dataprotection@calthorpe.co.uk or write to us
at: Data Protection, Edgbaston Estates Security Limited, 76 Hagley Road,
Edgbaston, B16 8LU or telephone 0121 452 1615.