Introduction
This policy outlines the management and retention of images and recordings captured by the Closed-Circuit Television (CCTV) System at Hotel De Normandie. We use CCTV for the safety and security of our guests, staff, and premises in compliance with the Data Protection (Jersey) Law 2018 (DPJL).
Purpose of CCTV
The primary purposes for using CCTV at Hotel De Normandie are:
To prevent and detect crime.
To ensure the safety of guests and staff.
To monitor security at entrances, exits, and vulnerable areas of the hotel.
To protect property against theft, vandalism, and unauthorised access.
The CCTV system is not used for any other purpose, such as monitoring employee performance, without prior notice and legal justification.
Lawful Basis for Processing CCTV Data
Under the DPJL, our lawful bases for processing CCTV footage are:
Legitimate interests: Ensuring the safety of our guests, staff, and premises.
Legal obligations: Retaining footage when required by law enforcement for investigations.
Storage and Retention of CCTV Data
We retain CCTV footage for a maximum of 30 days, unless it is required for a specific investigation or legal purpose. After this period, footage is automatically deleted from our system. If footage is needed for an investigation, it may be retained until the conclusion of the investigation or any legal proceedings.
Security of CCTV Data
CCTV footage is stored on secure servers with restricted access to authorised personnel only.
Access to CCTV recordings is strictly controlled, and footage is only reviewed in the event of an incident or as requested by law enforcement.
Physical and technical safeguards are in place to prevent unauthorised access, tampering, or misuse of the CCTV system and recordings.
Access to CCTV Footage
Access to CCTV footage is restricted to authorised personnel such as:
Hotel management
Security personnel
Law enforcement officers (upon official request and documentation)
If footage is required by law enforcement or insurance companies, proper documentation and authorisation will be obtained before any release of footage. We maintain a record of all footage shared with third parties, including the purpose of the disclosure.
Notification and Transparency
CCTV signage is clearly displayed around the premises to notify staff, guests, and visitors that they are under surveillance. The signs include:
The purpose of the CCTV system (security and safety).
Contact information (email or phone number) for inquiries.
Data Subject Rights
Under the DPJL, individuals have the right to request access to CCTV footage that captures them, known as a Subject Access Request. To respond to such requests:
We will provide the individual with a copy of the footage, unless it includes images of third parties whose identities cannot be protected by blurring or other methods.
Requests should be made in writing to the Data Protection Officer at Hotel De Normandie.
We aim to respond to such requests within four weeks as required by law.
Data Retention and Disposal
CCTV footage is retained for no longer than 30 days unless required for an investigation or legal purpose. Once the retention period has passed:
Electronic data is automatically deleted from the system.
Footage related to ongoing investigations is securely archived and deleted once it is no longer required.
Reviewing the CCTV System
The CCTV system and this policy are reviewed annually to ensure compliance with data protection regulations and the safety requirements of the hotel. If there are any changes in data protection law or CCTV usage, this policy will be updated accordingly.
Contact Information
For any questions or concerns about this CCTV Retention Policy or to submit a Subject Access Request, please contact:
Ulises De Freitas Data Protection Officer Email: uli@ch.je Phone: +44 (0) 1534 721347