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TINGDENE – WORKPLACE CCTV, USE & EFFECT UPON EMPLOYEES - POLICY Introduction Tingdene Parks Limited, Tingdene Holiday Parks Limited, Tingdene Marinas Limited and Tingdene Boat Sales Limited (together referred to as “Tingdene” or the “Company”) takes its data protection responsibilities seriously. The Company adheres to the principles (as applicable) contained in the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) and Data Protection Act 2018 (together called the “Data Protection Legislation”). The Data Protection Champion (“DPC”) is responsible for ensuring compliance with policy. That post is held by the company’s Chief Financial Officer (“CFO”), who, may be contacted by email, or by telephone to the company’s Head Office. This policy sets out how the Company's approach to the use of CCTV in the workplace affects its employees. Cameras are normally located in the communal areas of our business premises, but they may in certain cases by situated in offices in order to provide a suitable view of communal areas, reception desks. Using CCTV is necessary for the Company’s legitimate interests. Cameras are installed for the purpose of maintaining security and as method of protecting our employees as part of our Zero Tolerance Policy. The Company’s Zero Tolerance Policy is in place to protect our employees, and, in certain cases, detecting and preventing crime.

Purpose of CCTV The Company will not use CCTV for monitoring the work of employees or to monitor whether or not employees are complying with the Company’s policies and procedures. CCTV will be installed only if the Company decides (after an assessment) that it is a necessary and a proportionate way of dealing with either a current or identified potential problem. The Company will ensure that all cameras are set up in a way that ensures that there is minimal intrusion of employee privacy, if there is deemed to be an intrusion the Company will fully justify that intrusion. In areas of CCTV surveillance, signs will be displayed prominently to inform employees that CCTV is in use. If is accepted by the company and know to all employees, that if they access the applicable areas, their images will be captured on CCTV.

Limits on use of CCTV CCTV will not be operated in toilets, private offices or changing rooms, unless CCTV Monitoring is necessary for the investigation of a serious crime or there are circumstances in which there is a serious risk to Health & Safety or to the operation of the company’s business. CCTV will only be used in this way where it is a proportionate means of achieving the aim in the circumstances. Covert CCTV will only ever be set up for the investigation or detection of crime or serious misconduct. The use of covert CCTV will be justified only in circumstances where the investigator has a reasonable suspicion that the crime or serious misconduct is taking place and where CCTV use is likely to be a proportionate means of securing evidence. Any covert recording will be strictly time limited and authorised by Senior Manager or Company Director.

Evidence from CCTV footage CCTV evidence may be used against an employee in disciplinary proceedings only where such evidence tends to show, in the reasonable belief of the company, that he or she has been guilty of serious misconduct. The employee will be provided the opportunity to see and respond to the images in these circumstances. Such incidents will be dealt with under the Company’s disciplinary policy and procedure.

Storage & Access of CCTV footage Images from CCTV footage will be securely stored and only authorised personnel will have access to those images. Authorised personnel will normally be members of the Company’s IT team and Company Directors. For the avoidance of doubt, authorised personnel may also include members of the Human Resources Department, an employee's Line Manager, and Managers in the business area in which the footage is taken. However, information would normally be shared only in this way if the Company has reason to believe that a criminal offence or serious misconduct has occurred. Surveillance information may also be shared with law enforcement agencies for the purposes of detecting crime. CCTV images will be retained only long enough for an incident to come to light and any investigation to be conducted. In normal circumstances, CCTV footage will be securely deleted after 28 days. Employees whose images are recorded have a right to view images of themselves and to be provided with a copy of the images. Employees may make a request for the images the company holds by contacting the DPC by e-mail or by telephone to the company’s Head Office.

Tingdene CCTV Policy  
Tingdene CCTV Policy