1 Purpose
Chameleon Bride (referred to as the “Business”, “we”, “us”, “our”) uses Closed Circuit Television (CCTV) on our premises.
At Chameleon Bride, we believe that CCTV plays a legitimate role in helping to maintain a safe and secure environment for all our staff, guests, customers, suppliers and contractors customers and to protect the Business’s property and to ensure high standards of customer care.
Images recorded by Closed Circuit Television (CCTV) are personal data and as such must be processed in accordance with data protection laws. CCTV digital recordings and images (if they show an identifiable person (an individual)) constitute personal data as defined by the General Data Protection Regulation and the Data Protection Act 2018 (together referred to as the “GDPR”). We are committed to complying with our legal obligations in order to appropriately handle and protect personal data and ensure that the legal rights of staff, guests, customers, and potential customers, suppliers and contractors relating to their personal data,
This policy is intended to enable staff, guests, customers, and potential customers, suppliers and contractors to understand how Chameleon Bride uses CCTV, those departments responsible for CCTV use, the rights individuals may have in relation to CCTV, who has access to CCTV images and how individuals can raise any queries or concerns they may have.
We reserve the right to change this policy at any time and will notify all members of staff of those changes.
2 Policy Statement
We currently use CCTV to view and record individuals on and around our premises. This policy outlines why we use CCTV, how we will use it and how we will process data recorded by CCTV systems to ensure we are compliant with the GDPR.
For the avoidance of doubt, we have cameras in the main retail part of the shop as well as in the two bridal bays and VIP room. For your personal privacy, these cameras cannot see inside the fitting room when the curtains are pulled across, though sound is still recorded.
We have considered and determined that the purposes for which the CCTV is deployed are legitimate as well as being reasonable, appropriate and proportionate.
In respect of our use of CCTV, we process personal data to pursue our (or a third party’s) legitimate interests as a business, including the processing of CCTV images gathered from our CCTV systems.
In particular, we have installed CCTV systems:
- for security reasons (i.e. to deter and detect crime, including theft and criminal damage);
- for the protection of our property and staff and customers;
- for health and safety reasons;
- to assist in the overall management of our building and facilities;
- for internal conduct, performance or grievance matters (i.e., to assist in the effective resolution of disputes which may arise or to investigate suspected breaches of our various policies and procedures where conduct may be construed as gross misconduct);
- where appropriate for the defence or establishment of a legal claim (including employment tribunal proceedings and general litigation).
This list is not exhaustive and other purposes may be or may become relevant, as set out below.
Our CCTV systems will NOT be used:
- to provide recorded images for the world-wide-web, advertising or marketing;
- for any automated decision taking;
Where, in carrying out these purposes, images of members of staff committing acts which may give rise to a criminal conviction are obtained, such footage may be used as evidence in internal disciplinary hearings and may, as the circumstances apply, be shared with the police or other law enforcement agencies as set out below.
CCTV systems must not be used for the general surveillance of staff or for purposes other than those specifically indicated above. Covert CCTV systems will not be used within the Business.
2.1 CCTV Installations
CCTV systems have been installed on the premises generating images and sound recorded to a hard disc within the office.
Anneliese Ward and store Manager Sophie Tarrant (the “Managers”) will have sole access to this system.
It is a condition of employment that all staff will abide by the rules and regulations of the Business. Any failure to follow the Business’s Data Protection Policy or the wording of this policy, particularly with regard to unauthorised disclosure of personal data, may therefore result in disciplinary proceedings. Using our CCTV systems for purposes other than those specifically identified in this policy may also attract criminal liability to the Business or the individual CCTV operator.
All digital recordings must be password protected to maintain security. Recording media no longer in use will be securely destroyed. If images are used for any disciplinary purpose or other legal reason, the footage should be retained securely in the relevant case file, with the Managers to be contacted directly where this is proposed.
2.2 Processing data
Disclosures to third parties will only be made in accordance with the purpose(s) for which the system is used and will be limited to:
1. police and other law enforcement agencies, where the images recorded could assist in a specific criminal enquiry and/or the prevention of terrorism and disorder;
2. prosecution agencies (such as the Crown Prosecution Service);
3. relevant legal representatives of individuals whose images have been recorded and retained (unless disclosure would prejudice criminal enquiries or criminal proceedings);
4. individuals who have been caught on our CCTV in accordance with a request made such as one described in 1.4 below;
5. in exceptional cases, for others (such as insurers) to assist in the identification of a victim, witness or perpetrator in relation to a criminal incident; and
6. staff involved with our disciplinary processes.
2.3 Retention
For digital recording systems, CCTV recordings held on the hard drive of a PC or server will be overwritten on a recycling basis once the drive is full, and in any event, will not be held for more than 7 months. Images stored on removable media such as USB sticks or on mobile phones will be erased or destroyed once the purpose of the recording is no longer relevant, unless it is required to be retained for legal / compliance reasons.
2.4 Access
All requests to access CCTV images should be made in writing to Anneliese Ward.
If the Police request images from our CCTV systems in relation to an investigation that has not been initially reported it may be that we are required to disclose the images or we have a discretion to do so.
2.5 Monitoring and review
This policy will be kept under continuous review and we may amend this policy at any time. Any questions about its interpretation or operation should be referred to Anneliese Ward.
2.6 Complaints and enquires
Enquiries relating to this policy should be addressed to Anneliese Ward
Any complaints about the operation of our CCTV systems should be made in line with our Grievance Procedure. In the event that such a complaint is considered not to have been dealt with satisfactorily, complaints can be progressed with the ICO, and details of how to do so can be found on their website: www.ico.org.uk.
Version: 2
Date: April 2025
