Privacy Notice – UU Closed Circuit Television (CCTV)
This Privacy Notice explains how Ulster University (University) collects, uses and processes participants’ personal data as a data controller and explains individuals’ rights in relation to the personal data that the University processes during the use and management of the CCTV equipment.
The University actively seeks to preserve the privacy rights of those individuals that share information with the University. The personal data which you provide to the University will be processed in accordance with UK data protection legislation, specifically UK GDPR and the Data Protection Act 2018.
What is the purpose and legal basis of the processing
- to promote a safe community for our staff and students
- to monitor the safety and security of university premises
- to assist in the prevention, and detection of crime and to deter crime;
- to assist with the identification, apprehension and prosecution of offenders;
- to support investigations into the actions that might result in disciplinary proceedings being taken against staff or students and in giving evidence to relevant members of staff where disciplinary action may be or is being taken;
- to identify car parking and traffic management problems at the campuses
The following lawful basis that applies to this processing is:
UK GDPR Article 6.1(c) – processing is necessary for compliance with a legal obligation to which the controller is subject
UK GDPR Article 6.1(e) – processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
For processing special category data, our legal basis for processing is:
UK GDPR Article 9(g) – reasons of substantial public interest (with a basis in law).
Data Protection Act 2018, Part 2, Schedule 1 (6) – statutory and government purposes
Data Protection Act 2018, Part 2, Schedule 1 (10) – preventing or detecting unlawful acts
How we use your personal data
Data is collected on a daily basis on each campus using cameras. The university will clearly and visibly display signs so that staff, students and visitors are aware that they are entering an area covered by CCTV.
Change of Purpose
The University will only use your personal data for the purposes for which it collected in, unless the University reasonable considers that it needs to use the personal data for another reason and that reason is compatible with the original purpose. If the University needs to use your personal data for an unrelated purpose it shall notify you and explain the legal basis for which allows the University to do so.
How long is your personal data kept
Personal data collected as part of CCTV Data collection will be retained for a period of 31 days.
The University’s Retention and Disposal Schedule includes guidance on retention and disposal periods.
Categories of personal data processed by the University
Personal Data
The University may collect, use, store and transfer the following types of personal data as part of this processing:
- Facial features
- Voice
- Vehicle Registration Numbers
Special Category Data
“Special Categories” or particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation require higher levels of protection. The following categories of special category data may be passively processed if the footage collected reveals:
- Racial or ethnic origin
Who does the University share your data with?
The University shares personal data with third parties where necessary for the purposes of the processing and where there is a legal basis to do so. Where information is shared with such third parties, the University will seek to share the minimum amount necessary.
As part of this processing the University may share your personal data with the following third parties:
- Government agencies and authorities including the police for the prevention and detection of crime and the apprehension and prosecution of offenders.
- Insurance companies and solicitors where they make a lawful request for CCTV footage for the purposes of investigating insurance claims involving their insured parties or other legal claims relating to their clients.
- Footage may be shared internally to members of staff involved with the University’s disciplinary processes.
International Transfers
The University will not transfer your personal data to the countries outside of the United Kingdom:
In these circumstances your personal data is being transferred on the basis that the Secretary of State has made an adequacy regulation in respect of said countries. This means that countries are deemed to provide equivalent protection to personal data as provided by the UK data protection regime.
Your rights as a Data Subject
As a University data subject you have the right to:
- Access and obtain a copy of your personal data on request;
- Require the University to change incorrect or incomplete personal data;
- Require the University to delete or remove your personal data, for example where the data is no longer necessary for the purposes of processing. Note, however that the University may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
- Object to the processing of your personal data where the University is relying on its legitimate interests as a legal ground for processing;
- Where the University is relying upon consent to process your personal data, you may withdraw your consent at any time; and ask the University to stop processing personal data for a period if the personal data is inaccurate or there is a dispute about whether or not your interests override the University’s legitimate grounds for processing the personal data.
Further information and your right to complain
Further information in respect of the University’s practice in respect of data protection and our Data Protection Policy is available at Data Protection at Ulster University.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request the University transfer a copy of your personal information to another party, please contact the University’s Data Protection Officer.
Eoin Coyle, Data Protection & Information Compliance Manager, c/o Ulster University, Room J306, Coleraine, BT52 1SA, 02871 675525, gdpr@ulster.ac.uk
If you are not satisfied with how the University is processing your personal data, you can make a complaint to the ICO. Further information about your data privacy rights are available at the ICO.