Recording Policy | Chard 1964 Ltd

Contents: About this policy

Contents: CCTV Data

Contents: Telephone Call Data

Contents: Security and Disclosure of Personal Data

Contents: Retention Period

Contents: Use of Additional Surveillance Systems

Contents: Covert Monitoring

Contents: Ongoing Review

Contents: Subject Access Requests

Contents: Requests to Prevent Processing

Contents: Contact Us

This is our recording policy. Please follow the following links to our privacy policy, cookie policy or full terms of sale.

About Chards

Chard (1964) Limited is a coin and bullion dealer operating within Blackpool, Lancashire. In this Recording Policy, we refer to ourselves as “we”, “us” and “our”. We are a limited company registered in England and Wales under company number 1378220. Our premises are located at 32-36 Harrowside, Blackpool, Lancashire FY4 1RJ.

Our Harrowside Showroom

About this policy

We operate a CCTV surveillance system throughout our premises. We believe that CCTV surveillance has a legitimate role to play in helping to maintain a safe and secure environment for all our staff, customers and visitors.

The information we capture through CCTV cameras will amount to personal data under data protection laws. The information we capture may include images of personal appearance and behaviors of individuals entering and exiting the premises and individuals inside the premises (CCTV data). Please refer to section 3 below for further information.

We also record all telephone calls we make and receive. These recordings will capture personal data, including the identity and contact details of individuals, and any other personal information disclosed during a call (telephone call data). Please refer to section 4 below for further information.

This policy is designed to provide you with information as to why and how we use CCTV surveillance and telephone call recording and how we will process CCTV data and telephone call data. References in this policy to recorded data are to CCTV data and telephone call data.

This policy will be relevant to you if you work for us, visit our showroom or speak with us on the telephone. We are committed to protecting the privacy and security of your personal information.

Please read this policy carefully. For additional information about how we collect and process your personal data as a customer or employee, please refer to our Customer Privacy Policy (https://www.chards.co.uk/info/privacy-policy) and Employee Privacy Notice as applicable (our Privacy Policies).

CCTV Data

We use CCTV cameras on the perimeter of our building and inside the showroom. The cameras are operated 24 hours a day.

Signs are displayed within and outside our premises to alert individuals to the fact that CCTV cameras are in use and they may be recorded.

We use CCTV and process the CCTV data for our legitimate business purposes, including:

For the personal safety of all staff, customers and other visitors
To deter and prevent crime, in particular fraud, theft and violence
To deter and confront intruders and trespassers
To support law enforcement bodies with any criminal investigations
To enable us to investigate any allegations of criminal acts or other misconduct
For the health and safety of all staff, customers and visitors
To protect our buildings and assets from damage, disruption, vandalism and other crime

We also process CCTV data for the purpose of establishing, exercising and defending legal claims.

The above list is not exhaustive and other purposes may be or become relevant.

Our CCTV cameras are located throughout our building in our strong rooms and stock rooms, above the counters in our showroom, and on the perimeter of our building. All CCTV cameras are located in places that are relevant to the legitimate purposes described above. All CCTV cameras are visible.

The CCTV surveillance system is not used to record sound.

The CCTV system is recording continuously and may be monitored live from any monitor in the building where this is reasonably necessary, for example where suspicious activity is suspected during office hours or if an alarm has been triggered outside office hours. All monitors are password protected. We will ensure that live feeds from CCTV cameras and recorded images are only viewed by authorised personnel who need to access such data for the purpose of performing their duties. This may include HR staff involved with disciplinary or grievance matters. Recorded images will only be viewed by designated personnel.

All authorised personnel are fully trained in operating and accessing the CCTV system and are given appropriate training to ensure they understand and observe the legal requirements related to the processing of personal data.

We store all CCTV data on hard disk drives (HDDs) within the netwrok video recorders (NVRs) which form part of the software we use for the CCTV surveillance.

The CCTV data will be processed in accordance with our Privacy Policies (https://www.chards.co.uk/info/privacy-policy).

Telephone Call Data

We use telephone call recording on all of our incoming and outgoing calls. Our telephone system plays a recorded message at the start of each call to inform the recipient that the call is being recorded.

We use telephone call recording and process the telephone call data for our legitimate business purposes, including:

To deter and prevent crime, in particular fraud
To support law enforcement bodies with any criminal investigations
To enable us to investigate any complaints or criminal acts
For staff training and to improve customer service
To maintain business records of our sales
To monitor compliance with our regulatory obligations

We also process telephone call data for the purpose of establishing, exercising and defending legal claims.

The above list is not exhaustive and other purposes may be or become relevant.

We store all telephone call data at our premises. We ensure that telephone call data is only viewed by management to carry out the above legitimate business purposes, and is password protected.

The telephone call data will be processed in accordance with our Privacy Policy (https://www.chards.co.uk/info/privacy-policy).

Security and Disclosure of Personal Data

We have put in place appropriate storage and security measures to protect against unauthorised access, alteration, disclosure or destruction of the recorded data, including password protection, and encryption where appropriate.

We may engage third parties to maintain our CCTV and telephone systems. These third parties shall only be permitted to process personal data for specified purposes and, where they are processing personal data on our behalf, in accordance with our instructions. We will ensure that reasonable contractual safeguards are in place to protect the security and confidentiality of recorded data.

We will access recorded data in the following circumstances:

To comply with a request from a law enforcement body
To conduct staff training following a review from a customer
To comply with a subject access request
To resolve any discrepancies in cash transactions
To resolve any disputes in relation to verbal contracts entered into between us and a customer

We may be required to disclose recorded data to third parties where we are under a legal obligation to do so, including law enforcement bodies for the purposes of detecting, investigating and prosecuting criminal activities, and for evidential purposes in legal proceedings. We may also share recorded data with other businesses and industry bodies who are investigating criminal activities. We will make a record of any request we receive from third parties to access the recorded data, and any recorded data we provide to such third parties. The recorded data we share shall be limited so far as possible and we will take steps to protect the identity of anyone who is incidental to the recording.

Retention Period

We shall only keep recorded data for as long as necessary to fulfil the legitimate purposes described in this policy and our Privacy Policies (https://www.chards.co.uk/info/privacy-policy).

The recorded data will be permanently deleted once there is no reason to retain it. We will usually retain CCTV data for a period of one month. Telephone call data will generally be retained for five years in line with the period for which we keep our customer invoices to comply with money laundering regulations (as this data may assist with a money laundering or fraud investigation). In some circumstances, we may be entitled to retain the data for a longer period, for example for the purpose of exercising or defending a legal claim.

At the end of their useful life, all recorded data stored in whatever format will be erased permanently and securely. Any physical matter such as tapes or discs will be disposed of as confidential waste. Any still photographs and hard copy prints will be disposed of as confidential waste.

Use of Additional Surveillance Systems

Prior to introducing any new surveillance system, including if we install any new CCTV cameras, we will conduct a data protection impact assessment (DPIA) to consider whether the surveillance system is necessary and proportionate.

As part of the DPIA we will consider whether the proposed surveillance system should be used at all and whether any limitation should be placed on its use. Any DPIA will consider the nature of the problem that we are seeking to address at the time and whether the surveillance system is likely to be an effective solution, or whether a better solution exists. In particular, we will consider the effect the proposed surveillance system will have on individuals and therefore whether its use is a proportionate response to the problem identified.

No surveillance cameras will be placed in areas where there is an expectation of privacy (for example, in any toilet or showering facilities) unless, in very exceptional circumstances, it is judged by us to be necessary to deal with very serious concerns.

Covert Monitoring

We do not engage in covert monitoring or surveillance (that is, where individuals are unaware that the monitoring or surveillance is taking place) unless, in highly exceptional circumstances, there are reasonable grounds to suspect that criminal activity or extremely serious malpractice is taking place and, after suitable consideration, we reasonably believe there is no less intrusive way to tackle the issue.

In the unlikely event that covert monitoring is considered to be justified, it will only be carried out with the express authorisation of the Managing Director OR Busines Development Manager (as appropriate). The decision to carry out covert monitoring will be fully documented and will set out how the decision to use covert means was reached and by whom. The risk of intrusion on innocent workers will always be a primary consideration in reaching any such decision.

Only limited numbers of people will be involved in any covert monitoring.

Covert monitoring will only be carried out for a limited and reasonable period of time consistent with the objectives of making the recording and will only relate to the specific suspected illegal or unauthorised activity.

Ongoing Review

We will review this policy and use of our CCTV and call recording systems every 12 months to ensure that their use remains necessary and appropriate for the legitimate purposes described above.

Subject Access Requests

You have the right to request access to your personal data that we hold and to receive certain information relating to that data, which may include a copy of CCTV images and recordings and transcripts from telephone call recordings. If you wish to make a subject access request, please email us at [email protected] or write to us at 32-36 Harrowside, Blackpool, Lancashire, FY4 1RJ.

We reserve the right to obscure images and voices of third parties when disclosing recorded data to comply with a subject access request, where we consider it necessary to do so to protect the personal data of those third parties.

For further information about your rights under data protection law, please refer to our Privacy Policies (https://www.chards.co.uk/info/privacy-policy).

Requests to Prevent Processing

You have the right to object to how we process your personal data (including recorded data) in circumstances where we believe we have a legitimate interest in the processing (as described above). However, in some cases we may demonstrate that we have compelling legitimate grounds to process your data which override your rights and freedoms. You may also not be entitled to exercise this right if we are relying on other legal grounds to process the personal data, such as the exercise, establishment or defence of legal claims. For more information, please email us at [email protected] or write to us at 32-36 Harrowside, Blackpool, Lancashire, FY4 1RJ or refer to our Privacy Policies (https://www.chards.co.uk/info/privacy-policy).

Contact Us

If you have any questions or concerns about any information contained within this policy, please email us using the contact form on our site (https://www.chards.co.uk/contact), email us at [email protected], telephone us on +44 (0) 1253 343081, or write to us at 32-36 Harrowside, Blackpool, Lancashire FY4 1RJ.

This policy was last updated in August 2020.