GDPR Policy

GDPR Policy


Next Review Date June 2022

For the purpose of this document:

The Frome Memorial Theatre Trust is known as: FMTT

Use of CCTV under the 2018 GDPR, is in line with the ICO CCTV Code of Conduct.

1.0 Introduction

FMTT uses closed circuit television (CCTV)

1.1 The images produced are used to detect crime and monitor the FMTT complex to provide a safe and secure environment for the staff and FMTT customers and suppliers.

1.2 The system comprises of 3 separate systems.

A) A number of static dome cameras covering a historic high value statue and the front private carpark area.

B) A number of static fixed cameras covering an enclosed private car park and private drive way.

C) Is used only for technical support to stage and production crews, it has a least 1 camera that normally points at the stage, we don’t normally record these images.

These cameras are monitored by FMTT production staff or visiting production crews; for technical production, control and safety purposes only.

Due to the varied technical nature of productions some productions may show limited images of members of the public.

Monitors may not normally be visible to the general public.

FMTT reserve the right to replace or upgrade their CCTV at anytime providing it’s in line with the ICO CCTV code of practice.

1.3 All CCTV systems do not have sound recording capabilities.

1.4 All the CCTV systems are owned by FMTT and operated solely by authorised FMTT staff.

1.5 The A and B CCTV systems are monitored from 2 secure locations within the FMTT complex.

1.6 The person responsible for the monitoring of both systems is the FMTT Technical Director both systems are password-protected and kept in secure non-public locations.

1.7 All authorised operators with access to the images are aware of procedures that need to be followed when accessing recorded images.

2.0 Intent

2.1 FMTT complies with Information Commissioner Office (ICO) code of practice to ensure that the FMTT CCTV systems are used responsibly to safeguard FMTT staff, customers and suppliers.

ICO Reference: Frome Memorial Theatre Trust ZA443494)

2.2 CCTV warning signs are clearly and prominently placed around the external entrance to the complex in close proximity to camera positions, further signs are in other outdoor areas. Signs contain details of the purpose for use.

2.3 FMTT CCTV systems cameras only capture images relevant to the purpose, for which they are installed. Every effort is made to ensure reasonable privacy expectations are not violated, FMTT will ensure that the location of equipment is carefully considered to ensure that captured images comply with the General Data Protection Regulations (GDPR) and the ICO CCTV code of practice.

2.4 The FMTT system doesn’t use active ANPR or Facial recognition or covert CCTV monitoring, however we may in exceptional circumstances determine a sound reason to set up convert monitoring where there is good cause to suspect illegal or unauthorised actions or serious misconduct is taking place.

2.5 Any covert monitoring will cease following the completion of an investigation.

3.0 Storage Of CCTV Images

3.1 Recorded images will not be retained longer than necessary,

3.2 While retained, the integrity of the recoding will be maintained to ensure their evidence value and to protect the rights of the people whose images have been recorded.

3.3 All retained images will be stored securely and encrypted at all times and permanently deleted when appropriate or required.

4.0 Access to images

4.1 Access to recorded images will be restricted to those staff authorised to view them and not shared with third parties

4.2 FMTT have the right to share images to authorised personnel such as the police and service providers to the FMTT, for investigation and enforcement purposes.

5.0 Subject Right Of Access Requests

5.1 Individuals have the right under GDPR to request CCTV footage only relating to themselves, all requests have to be made in writing to Frome Memorial Theatre data subjects requests for images have to provide sufficient confirmation of identity and information to enable footage relating to them to be identified; Date, Time, Location and Reason for the request.

5.2 FMTT will respond within 40 calendar days of receiving the written request.

5.3 A fee of £10:00 may be charged for each request inline

with the ICO CCTV code of practice.

5.4 FMTT Reserves the right to refuse an individual access to CCTV footage where this would prejudice the legal rights of other individuals or jeopardies an on-going investigation.

6.0 Complaints

6.1 Complaints and enquires about the operation of the FMTT CCTV systems should be directed to FMTT

Email: [email protected]

In writing to:
Frome Memorial Theatre,
Christchurch Street West
BA11 1EB

CCTV Code Of Practice Ver 1.2 is published by the ICO

Code of Practice

Policy prepared by FMT

Version 1.3