Privacy Policy

A. Proper Storage and Handling of CCTV Footage

Our CCTV system and any personal data collected by it (“Footage”) is subject to security measures to protect it and to prevent unauthorised access to or handling of it, including the following measures:

• Storage: All Footage is encrypted and stored in secured physical and digital locations. Access to the physical storage locations is secured and restricted to authorised users only. Digital storage of the Footage can be accessed only by authorised users and then only by way of a traceable log-in and password. Records are kept of the authorised users who access the Footage.
• Use: Authorised users are only permitted to access and view the Footage when an incident is reported to us that reasonably requires the Footage to be viewed (“Incident”), such as an offence being committed on the premises or for the purposes of a police investigation. If such an Incident occurs, the Footage is stored as set out above until the Incident is investigated and closed.
  
  If the Footage is to be moved in digital format through email or any other electronic transmission method, it will only be moved in encrypted form to an authorised user, and then only as necessary in accordance with this policy. We have safeguards in place to protect our electronic transmission systems from interception. All movement of the Footage is documented.
• Deletion: If no Incident is reported to us within a reasonable period of time from the date on which the Footage was first recorded, or when an Incident is closed, the relevant Footage will be securely and permanently destroyed. If the Footage is in hard copy form, it will be destroyed by shredding and then secure disposal; if it is in electronic form, the Footage will be permanently erased from our systems.
• Compliance: We carry out compliance checks and audits annually to review the effectiveness of the safeguards and procedures of the CCTV system.

B. Transfer of CCTV records to third parties

• We will only disclose Footage to a third party in accordance with the section “Who will we share this data with, where and when”.
• If we are requested to provide Footage to a law enforcement agency, e.g. to the Police for criminal investigation purposes, we will only do so in compliance with a written request provided by the relevant law enforcement agency and if we reasonably believe that an exemption under the Ordinance or other applicable laws applies.

C. Customer enquiries about our use of CCTV

You may report any suspected misuse of our CCTV system using the contact details set out in the in the section “How do I get in touch with you” below.

Please note that we are unable to accept requests from customers to view Footage, because the Footage may contain personal data of other third parties that we may not be allowed to share under applicable laws.