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Any organization which provides maintenance services or monitoring services in connection with the CCTV scheme may have access to CCTV images recorded. No other parties will be allowed access to the tapes. SUGGESTED ACTIONS . Document why CCTV is to be installed and what it is intended to do or prevent. Appoint one individual to be responsible for the day-to-day operation of CCTV and its compliance with the CCTV Code of Practice. When positioning the cameras, check that they pick up relevant images only (for example, avoiding staff rest areas if the CCTV is being introduced to monitor cash registers).
Care needs to be taken to ensure that personal data is not disclosed between the parties except as strictly necessary. This is a situation where a clear warning to employees that their personal data will be shared between the parties (in this case the employer, the insurance company, and the pension scheme trustees) avoids the issue and illustrates the value of appropriate and well thought out subject information. Also, the employer should ensure that one or more of the conditions for fair processing of sensitive data is met.
In this way the trustees and/or employer are not involved in processing ‘personal data’ as the sealed envelope does not identify the beneﬁciary data subjects. SUGGESTED ACTIONS . Ensure that the trustee body is registered for data protection. (See Chapter 23). Identify all personal data processing undertaken by, or on behalf of, the scheme trustees. Ensure that appropriate subject information is in place for scheme members, prospective members, pensioners and pension visitors. Identify any third parties involved in processing personal data on behalf of the scheme trustees – including the employer – and put contracts in place.