City of York Council (CYC) current data protection notification is registered with the Information Commissioner’s Office (ICO) – reference Z5809563. We regularly review this privacy notice, and it was last updated in November 2024.
CYC contracts with Gough & Kelly Security Ltd. (G&K) to provide the CCTV services. G&K is an Information Commissioner's Office (ICO) registered data controller (Z1585966) and a National Security Inspectorate (NSI) Gold approved company contracted to the council to manage CCTV operations. The NSI is recognised as the leading certification body for the security and fire protection sectors in the UK.
For the purposes of data protection legislation, CYC is the data controller and G&K are the data processor and are both responsible to you under the law for the processing set out in this privacy notice.
CYC is committed to ensuring that personal data is handled in accordance with the principles set out in data protection legislation and guidance from the Information Commissioner’s Office (ICO).
This privacy notice tells you what to expect when we process your information, and it applies to information captured on our CCTV systems.
You can contact the council’s data protection officer at:
West OfficesStation Rise
York
YO1 6GA
Telephone: 01904 554145.
Email: information.governance@york.gov.uk.
You can contact G&K’s data protection officer at:
Gough & KellyUnit 2, Railsfield Mount
Bramley
Leeds
LS13 3AX
Telephone: 0344 8807100
Email: enquiry@gough-kelly.co.uk
This privacy notice should be read in conjunction with other relevant CYC privacy notices and/or policies and procedures.
When appropriate we will provide a ‘just in time’ notice to cover any additional processing activities not mentioned in this document.
- How we collect your information
- What personal data we process and why
- Automated decision-making
- Collecting information automatically
- Children's information
- Lawful basis for processing your personal data
- How long we keep your personal data
- Data sharing
- Data processors and/or third parties
- Transfers of personal data
- How we protect your information
- Your rights in relation to this processing
How we collect your information
We get information about you from our CCTV systems which includes our public spaces CCTV and when using body worn systems.
Find more details about our CCTV public spaces locations.
What personal data we process and why
Our CCTV systems will process personal data, special categories of personal data and criminal offence data for the below purposes:
- monitoring and managing public spaces including traffic and travel
- event management (such as cycle events, York Marathon, York Races)
- 'Storenet', a service to retail and licensed premises, including a radio link with registered Security Industry Authority (SIA) operatives
- barrier control such as on-street rising bollards, car park barriers and Hostile Vehicle Mitigation (HVM) barriers
- production of evidence for example to police, solicitors, insurance companies, court proceedings where it is appropriate to do so
- welfare and security checks for individuals where it is appropriate to do so
Automated decision-making
We do not carry out any automated decision-making in our use of CCTV systems.
Collecting information automatically
Please see our Cookies Policy for further information about the information we collect automatically when you use our website.
Children’s information
Where we provide services directly to children or young people, the information in the relevant parts of this notice applies to children and young people, as well as adults.
Lawful basis for processing your personal data
Any information that we process about individuals is done so in accordance with Article 6, 9 and 10 of the UK GDPR and Schedule 1 of the Data Protection Act 2018 (DPA 2018).
- Article 6(1)
- (d) Vital interests: the processing is necessary to protect someone’s life.
- (e) Public task: the processing is necessary for the council to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
- (f) Legitimate interests: the processing is necessary for the council’s legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks)
- Article 9(2)
- (c) Vital interests
- (g) Reasons of substantial public interest (with a basis in law)
This is supported by Schedule1, Part 2 (6) of the Data Protection Act 2018 and the following legal framework:
- Protect Duty which is known as ‘Martyn’s Law’
- Prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties including the safeguarding against and the prevention of threats to public security
- Crime and Disorder Act
- Safeguarding vulnerable groups Act 2006
- Traffic Management Act 2004
Where we process information relating to criminal offences, this is also under Article 10 UK GDPR that covers processing in relation to criminal offences or related security measures. In addition, section 11(2) of the DPA 2018 specifically confirms that this includes personal data relating to the alleged commission of offences, or proceedings for an offence committed or alleged to have been committed, including sentencing.
Some of the Schedule 1 conditions for processing special category and criminal offence data require an Appropriate Policy Document (APD) to be in place, which sets out and explains the procedures for securing compliance with the principles in Article 5 and policies regarding the retention and erasure of such personal data. This document explains this processing and satisfies the requirements of Schedule 1, Part 4 of the DPA 2018 and supplements this privacy notice.
Our Appropriate Policy Document provides further information about this processing.
How long we keep your personal data
CCTV data will only be kept for as long as is necessary and will be automatically and securely overwritten after 31 days.
You can find more details about how long the council keeps records in the council retention schedule.
Data sharing
We will only share your information with other council services and with other organisations, agencies, partners such as contractors who undertake work on our behalf, government departments, etc where it is appropriate to. For example:
- Gough & Kelly Security Ltd
- Retail and licensed premises who use 'Storenet' including SIA licensed operatives
In some circumstances, such as under a court order or safeguarding, we are legally obliged to share information.
We will always satisfy ourselves that we have a lawful basis on which to share the information and document our decision-making.
Additionally, we are required under the Public Records Act 1958 (as amended) to transfer records to the City or National Archives (TNA) for permanent preservation. Full consideration will be given to Data Protection and Freedom of Information legislation when making decisions about whether such records should be open to the public.
Data processors and/or third parties
Where we have third parties providing parts or all of our services for us, we have contracts in place with them. These are listed below:
- Gough and Kelly’s privacy policy
- Security industry authority privacy notice
- National security inspectorate privacy notice
- If we use Microsoft Teams, to contact you, to gather information from you, or if we are recording or transcribing our discussion or meeting with you, we will let you know. You can find more details about this in the City of York Council Microsoft Office 365 (MS365) Teams Meeting recording and transcription privacy notice
Transfers of personal data
We do not routinely transfer personal data, special categories of personal data or criminal offence data, outside of the UK but when this is necessary, we ensure that we have appropriate safeguards in place and that is done in accordance with the UK data protection and privacy legislation.
How we protect your information
We're committed to keeping your information safe and secure. There are several ways we do this, such as:
- IT security safeguards such as firewalls, encryption, and anti-virus software
- on-site security safeguards to protect physical files and electronic equipment
- training for all staff and elected councillors
- policies and procedures
Your rights in relation to this processing
To find out about your rights under data protection law, you can go to the Information Commissioner's Office website.
You can also find information about your rights in our Privacy Notice.
If you have any questions about this privacy notice, want to exercise your rights, or if you have a complaint about how your information has been used, please contact us on email: information.governance@york.gov.uk, or on telephone: 01904 554145, or write to:
Data Protection OfficerCity of York Council
West Offices
Station Rise
York YO1 6GA