PRIVACY POLICY

CCTV, ACCESS CONTROL & DOOR ENTRY SYSTEMS

 

1. Introduction

This Privacy Policy explains how personal data is collected, used, stored and disclosed in connection with the operation of CCTV systems, electronic door entry systems, access control systems, fob entry systems and related security measures operated at the developments managed by Apt Property Management Ltd.

 

The purpose of these systems is to:

• Promote the safety and security of residents, visitors and contractors
• Prevent and detect crime and anti-social behaviour
• Protect buildings, communal areas and property
• Assist with the investigation of criminal or security-related incidents
• Support the effective management of the developments

 

Apt Property Management Ltd and Riverview Management Company Limited are individually registered with the Information Commissioner’s Office (ICO) and operate these systems in accordance with:

• The UK General Data Protection Regulation (UK GDPR)
• The Data Protection Act 2018
• ICO guidance relating to CCTV and surveillance systems

 

2. Types of Information Collected

Depending on the systems installed at a particular development, the following information may be collected:

 

CCTV Systems

• Video footage of communal areas
• Images of residents, visitors, contractors and vehicles
• Date and time recordings
• Movement within monitored communal areas

 

Door Entry / Access Control Systems

• Fob access records
• Entry and exit logs
• Flat or property reference numbers associated with fobs
• Door release activity
• Visitor call records where applicable

 

Not all developments operate the same systems and some developments may only use limited security measures.

 

3. Purpose of Processing

Personal data is processed solely for legitimate management and security purposes, including:

• Crime prevention and detection
• Investigation of criminal activity or serious breaches of lease or estate regulations
• Protection of residents and property
• Monitoring unauthorised access
• Assisting law enforcement authorities
• Maintaining building security

 

The systems are not used for general surveillance of residents’ private activities.

 

4. Lawful Basis for Processing

The lawful basis relied upon under Article 6 UK GDPR is:

 

Legitimate Interests

Processing is necessary for the legitimate interests of:

• Maintaining the security of the developments
• Protecting residents, visitors and property
• Investigating criminal or anti-social behaviour
• Supporting the proper management of communal areas

 

Where criminal activity is suspected, processing may also be necessary for:

• The prevention and detection of crime
• Compliance with legal obligations
• Cooperation with law enforcement agencies

 

5. Access to Information

Access to CCTV footage and access control records is strictly limited.

 

The following principles apply:

• Apt Property Management is the sole authorised individual responsible for reviewing footage or access records in the first instance.
• Information is only reviewed where there is a legitimate reason to do so, normally following:
  • A criminal incident
  • Security concern
  • Serious anti-social behaviour
  • Police request
• Information may be disclosed to:
  • Police or other law enforcement authorities
  • The Board of Directors of the relevant development where necessary for review of a serious incident.
• Footage or records are not routinely disclosed to residents or third parties.

 

Under normal circumstances, residents are not permitted direct access to CCTV footage involving other individuals due to data protection and privacy considerations.

 

6. Disclosure to Police and Authorities

Where criminal activity or serious security concerns arise:

• Relevant footage or access records may be provided directly to the Police
• Requests are assessed on a case-by-case basis
• Appropriate records are maintained of disclosures where required

 

The Management Company reserves the right to refuse inappropriate or excessive disclosure requests.

 

7. Retention of Data

Data is retained only for as long as reasonably necessary.

 

Typical retention periods are:

• CCTV footage: generally between 14 and 31 days unless required for an active investigation
• Access control logs: retained only for operational and security purposes
• Incident-related material: retained for the duration of any investigation, legal proceedings or insurance claim

 

Retention periods may vary depending on system capability, operational requirements or legal obligations.

 

8. Data Security

Appropriate technical and organisational measures are implemented to protect data, including:

• Restricted system access
• Password protection
• Secure storage of recordings and logs
• Controlled disclosure procedures
• Limiting access to authorised persons only

 

Reasonable steps are taken to prevent unauthorised access, misuse, alteration or disclosure.

 

9. Residents’ Rights

Individuals may have rights under UK GDPR, including:

• The right to request access to their personal data
• The right to request correction of inaccurate data
• The right to object to certain processing
• The right to lodge a complaint with the ICO

 

Requests will be considered in accordance with data protection legislation and may be subject to exemptions where disclosure would adversely affect the rights of others or prejudice crime prevention activities.

 

10. Subject Access Requests (SARs)

Requests relating to personal data should be submitted in writing to Apt Property Management Ltd, who can:

• Require proof of identity
• Request clarification of the information sought
• Refuse or redact information where disclosure would infringe the rights of third parties

 

11. Complaints

Any concerns regarding the use of CCTV or access control systems should first be directed to Apt Property Management Ltd.

 

Individuals also have the right to complain to:

 

Information Commissioner’s Office (ICO)

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

 

Website: https://ico.org.uk

 

12. Policy Review

This Privacy Policy may be reviewed and updated periodically to reflect:

• Changes in legislation
• Operational requirements
• Changes to security systems
• ICO guidance

 

The latest version will be made available upon request.

 

13. Contact Details

Property Manager: Dolores O’Reilly

Managing Agent: Apt Property Management Ltd

Correspondence Address: 32 Chequer Street, Fenstanton, PE28 9JQ

Email: dolores@aptpropertymanagement.co.uk

Telephone: 07740 107622

 

ICO Registration Number(s):

• Apt Property Management Ltd — ZA098650
• River View Management Company (Cambridge) Limited — ZA265922