CCTV and Body Cameras Privacy Notices

CCTV, body cameras, dashcams and drones

We are committed to tackling and reducing crime, anti-social behaviour, the fear of crime and to provide a safer environment for those people who live and work in Gwynedd and for visitors travelling through the county.

Section 163 of the Criminal Justice and Public Order Act 1994 creates the power for local authorities to provide closed circuit television coverage of any land within their area for the purposes of crime prevention or victim welfare. We have installed CCTV (closed circuit television) cameras in various locations across the county (town centre CCTV system in Bangor, Bethesda, Caernarfon, Pwllheli and Porthmadog), including premises owned by us (Council buildings such as libraries, museums, council offices etc.). There are visible signs showing that CCTV is in operation.

We use body worn cameras for our enforcement activities and for our staff’s personal safety and welfare. The recordings provide video and audio evidence of interactions between our staff and members of the public. All recordings are incident specific. The employee is required to state that recording is taking place and whether the recording includes audio.

We use dash cams (outward only facing) for our staff’s personal safety and welfare, accident liability and on occasion, to record unlawful activities. There are visible signs on our vehicles to show that recording is taking place.

Our CCTV, body worn cameras and dash cams are overt methods implemented to promote public reassurance, capture best evidence, modify behaviour, prevent harm and deter people from committing crime and/or engaging in anti-social behaviour.

The Council owns and operates Unmanned Aerial Systems (drones) with an attached camera, all of which are registered with the Civil Aviation Authority (CAA). UAS pilots are also registered with the Civil Aviation Authority (CAA). Video footage and photographs are captured on a memory card on board the drone, and this footage is then transferred to the Council’s secure server before being deleted from the card.

 

Processing activity - it is necessary for us to collect and hold personal information. In general terms, we process personal information relating to:

  • the investigation and detection of crime and disorder
  • the detection and prevention of terrorism
  • the instigation of legal proceedings
  • accident liability
  • health and safety of employees

 

Information requirements - our processing activities may include:

  • name, address, email, telephone number
  • date of birth
  • photographs in the form of valid ID documents
  • vehicle registration numbers
  • specific locations relating to activities of individuals.
  • North Wales Police intelligence or data relating to specific individuals, or groups of people.
  • CCTV images and audio linked with bodycam and dash cam footage.

 

Lawful bases -  Our lawful bases for processing your personal information.

  • Public space CCTV is provided under section 163 of the Criminal Justice and Public Order Act 1994 to "promote the prevention of crime", by virtue of the Data Protection Act 2018 s30(1)(b) and S31 as "promoting the protection of crime" satisfies the purpose of prevention of crime (for law enforcement purposes).
  • Off-street car parks are provided under the Road Traffic Regulation Act 1984 to relieve or prevent traffic congestion and/or preserve local amenities. CCTV protects our car parks from trespass and to ensure that in protecting our property, legitimate users of our facilities are able to park unhindered in our car parks.
  • UK GDPR Article 6(1)(c) - our legal obligation(s) under the:
    • Criminal Procedure and Investigations Act 1996 (prosecutions).
    • Crime and Disorder Act 1998 (duty to consider crime and disorder).
    • Protection of Freedoms Act 2012 and Protection of Freedoms Act 2012 (Code of Practice for Surveillance Camera Systems and Specification of Relevant Authorities) Order 2013 and Surveillance Camera Code of Practice Section 29 Protection of Freedoms Act 2012.
    • Counter-Terrorism and Security Act 2015.
  • UK GDPR Article 6(1)(e) - where processing is necessary for the performance of a task in the public interest or in the exercise of official authority vested in us under the legislation referred to above.
  • UK GDPR Article 10 as supplemented by DPA 2018 section 10(5) & Schedule 1, Part 2, paras. 6(1) and (2)(a) and 10 - criminal convictions and offences - where processing is necessary for reasons of substantial public interest.
  • UK GDPR Article 6(1)(f) - for the purposes of our legitimate interest (we can use ‘legitimate interests’ if we can demonstrate that the processing is for purposes other than for performing our tasks as a public authority). In this context, our objectives are to:
    • protect our premises e.g., our Civic Centre against burglary, theft or vandalism.
    • protect our staff’s personal safety and welfare.

  • UK GDPR Article 6(1)(c) - our legal obligation(s) under the:
    • Criminal Procedure and Investigations Act 1996 (prosecutions).
    • Crime and Disorder Act 1998 (duty to consider crime and disorder).
    • Protection of Freedoms Act 2012 and Protection of Freedoms Act 2012 (Code of Practice for Surveillance Camera Systems and Specification of Relevant Authorities) Order 2013 and Surveillance Camera Code of Practice Section 29 Protection of Freedoms Act 2012.
    • Counter-Terrorism and Security Act 2015.
  • UK GDPR Article 6(1)(f) - for the purposes of our legitimate interest (we can use ‘legitimate interests’ if we can demonstrate that the processing is for purposes other than for performing our tasks as a public authority). In this context, our objectives are to:
    • protect our premises e.g., our Civic Centre against burglary, theft or vandalism.
    • protect our staff’s personal safety and welfare.

  • UK GDPR Article 6(1)(c) - our legal obligation(s) under the:
    • Control of Pollution Act 1974 (environmental crime).
    • Refuse Disposal (Amenity) Act 1978 (environmental crime).
    • Criminal Procedure and Investigations Act 1996 (prosecutions).
    • Environmental Protection Act 1990 (environmental crime).
    • Town and Country Planning Act 1990 (environmental crime).
    • Crime and Disorder Act 1998 (duty to consider crime and disorder).
    • Regulation of Investigatory Powers Act 2000.
    • Clean Neighbourhoods and Environment Act 2005 (environmental crime).
    • Serious Crime Act 2015 (fraud).
  • UK GDPR Article 6(1)(e) - where processing is necessary for the performance of a task in the public interest or in the exercise of official authority vested in us under the legislation referred to above.
  • UK GDPR Article 10 as supplemented by DPA 2018 section 10(5) & Schedule 1, Part 2, paras. 6(1) and (2)(a) and 10 - criminal convictions and offences - where processing is necessary for reasons of substantial public interest.
  • UK GDPR Article 6(1)(f) - for the purposes of our legitimate interest (we can use ‘legitimate interests’ if we can demonstrate that the processing is for purposes other than for performing our tasks as a public authority). In this context, our objectives are to:
    • protect our premises e.g., our Civic Centre against burglary, theft or vandalism.
    • protect our staff’s personal safety and welfare.

Dashcams:

  • UK GDPR Article 6(1)(c) - our legal obligation(s) under the:
    • Control of Pollution Act 1974 (environmental crime).
    • Refuse Disposal (Amenity) Act 1978 (environmental crime).
  • UK GDPR Article 6(1)(e) - where processing is necessary for the performance of a task in the public interest or in the exercise of official authority vested in us under the legislation referred to above.
  • UK GDPR Article 6(1)(f) - for the purposes of our legitimate interest (we can use ‘legitimate interests’ if we can demonstrate that the processing is for purposes other than for performing our tasks as a public authority). In this context, our objectives are to:
    • protect our premises e.g., our Civic Centre against burglary, theft or vandalism.
    • protect our staff’s personal safety and welfare.
  • UK GDPR Article 6(1)(f) - for the purposes of our legitimate interest (we can use ‘legitimate interests’ if we can demonstrate that the processing is for purposes other than for performing our tasks as a public authority). In this context, our objectives are to:
    • protect our premises e.g., our Civic Centre against burglary, theft or vandalism.
    • protect our staff’s personal safety and welfare.
  • We use 360 cameras on our refuse and recycling vehicles to ensure the safety and well-being of our staff, accident liability, and on occasion to record issues related to waste collection. Visible signs on our vehicles indicate that recording is taking place.

These objectives constitute our legitimate interests for video surveillance. A third party could reasonably expect and conclude to be subject to monitoring in these specific situations.

 

Data sharing - to aid with the detection and prevention of criminal acts, we may share your information with:

  • Courts/tribunals.
  • Insurance agencies.
  • North Wales Police.
  • British Transport Police.
  • Solicitors.
  • Maritime Coastguard and Marine Accident Investigation Branch.

 

Retention period - images captured will be held securely on our systems. Access will be strictly controlled to relevant staff only. Images will not be kept for longer than 90 days. On occasions, however, there may be a need to keep images and footage for longer e.g., where a crime is being investigated or it may become relevant to an investigation. In such cases, images will be retained for a long as necessary (e.g., until the conclusion of any criminal proceedings arising from the incident). When we dispose of personal information, we will do so in a secure way.

 

Right to object – please see Cyngor Gwynedd’s privacy policy.