Recycle IT CCTV Policy Statement

This Policy will be made freely available for both staff and visitors to Recycle IT. A copy is available in reception office, on our website and in our staff handbook.

Recycle IT, as the data controller, has a registered address at Recycle IT, Unit 14/2 Crag Terrace, Clondalkin Industrial Estate, Clondalkin Dublin D22 TK37.  

Recycle IT are a not-for-profit organisation, registered in Ireland under Companies Registration Number 365139.

Recycle IT recycle waste electronic and electrical equipment (WEEE) and metals.

Recycle IT telephone number: 01-4578321.  If you have a question or concern regarding the impact on your privacy due to the use of CCTV, please contact Una Lavelle, General Manager & Privacy Officer at info@recycleit.ie, by telephone or at the above address.

Legal Basis for Processing
The legal basis for processing is public interest, security, safety, health, wellbeing, and environmental protection i.e., creating a safe, and secure environment for the public, visitors, and staff of Recycle IT. Personal data maybe record during the process.
Personal data’ is any data that relates to an identifiable living individual. The definition of ‘processing’ of personal data includes collecting, recording, storing, adapting, using, disclosing, and deleting data.

Compliance
Closed Circuit Television System (CCTV) has been in place since 2020 and system was updated in 2022 and complies with Irish security regulations.  This policy was last reviewed and updated in March 2022 following on from a Data Protection Assessment (DPA).

The outcome of the DPA was to ensure our CCTV system did not compromise the privacy of any individual. The organisation wishes to ensure that the use of CCTV is in line with requirements under Irish Data Protection regulations.

Why we collect data
Recycle IT provide waste management services in Dublin and for the people who live and work in Dublin and surrounding areas. We collect data to support the delivery of the service and the safe, legal, and appropriate use of the service, facility, and the environs.

We collect data for the following reasons with respect to our recycling centre services:

to encourage a safe and healthy environment for service users and staff alike

to detect and deter crime

to inform investigations

to monitor service demand

to identify inappropriate use of services / service area

to ensure that all applicable wastes are transferred in a legally compliant manner.

to respond to correspondence

Responsibility & Restricted Access
Overall responsibility for the organisation’s CCTV system lies with our General Manager & Privacy Officer.  Access rights to CCTV footage has been assigned to a restricted number of personnel who have been appropriately trained to view, playback and download footage.   Otherwise, there is no access to the CCTV system and recorded material by Recycle IT staff.

The restricted number of staff with responsibility for processing CCTV images must only do so in line with established procedures and must always ensure the security of the data. Any employee who uses the CCTV system or CCTV images in an unauthorised manner may be subject to disciplinary action up to and including dismissal.  All employees have a responsibility to adhere to this policy.

Retention
Recorded images are retained 31 days from the date of recording. However, the organisation reserves the right to retain images for a longer period where there are objective reasons for doing so such as a written request from An Garda Siochana and/or Environmental Enforcement Agency or we have received a Subject Access Request to view footage.

Subject Access Request
All individuals have the right to access images containing their personal data. This applies equally to staff and members of the public. We would request that all requests to view footage is made in writing and addressed to General Manager & Privacy Officer (details above).  Careful consideration must be given to requests for access that would involve disclosing images of other individuals.   Individuals requesting access to images must supply the organisation with the following:

adequate information for the images to be located

sufficient information/justification to verify a legitimate right to request access

proof of identification, if necessary

Individuals should specify whether they would be satisfied with merely viewing the images rather than requiring a copy. A request in relation to what personal data is stored will be responded to within 15 days explaining whether such data is kept and, if so, giving a description of the data and the purpose of keeping it. A copy of the personal data of the individual will be supplied within 30 days of the request.

Due to the anonymity, we offer visitors and our strong privacy culture, there will be occasions that a request will be denied.  On these occasions, we will log the request, purpose of request and reason for refusal. Then inform the individual of the reason.  The data subject has the right to dispute this decision with the Irish Data Protection Commission.

Unauthorised Processing
Unauthorised use is any processing incompatible with the data’s original purpose including, but not limited to:

disclosure of images containing personal data to an unauthorised third party, including other employees

unauthorised processing of personal data in the form of copying the images on to a disk, website or print format

circulation of images containing personal data by email or posting of images containing personal data on the internet

access to and disclosure of images to third parties

access to and disclosure of images recorded by the CCTV system is carefully restricted with limited access.  Some circumstances for disclosure may include: - 

prevent, and investigate offence

prevent injury or damage to property

meet legal requirements

obtain legal advice, or for the purpose of legal proceedings

meet a request from, or with the consent of, the data subject, or a person acting on his or her behalf

Requests from An Garda Siochana and/or Environmental Enforcement Agency must always be followed up by a written request on headed paper confirming that An Garda Siochana and/or Environmental Enforcement Agency are investigating a criminal or environmental matter.

Gardaí are permitted to view footage on the premises of Recycle IT.  The organisation also reserves the right to disclose personal information to specific third parties where there are objective business reasons for doing so. Such third parties may include:  insurance providers or medical practitioners.

Third Party Processing
We have a Data Processing Agreement in place with security system provider. PhoneWatch.

Location & Signage
The organisation operates two external and two internal cameras.  The external CCTV cameras operate on a 24-hour basis, seven days a week. The internal CCTV camera operate outside business hours. Adequate signage is placed in the vicinity of CCTV cameras to indicate that CCTV is in operation. 

Notification & Dispute
A copy of this CCTV Policy is available to the public, all staff and Board members through our website and staff handbook and in the reception office for visitors to the recycling facility. 

We will only process your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint

regarding the processing of your personal data, please communicate in the first instance with our General Manager & Privacy Officer.

If you are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the Supervisory Authority (Irish Data Protection Commission) if you believe that we have not complied with this CCTV Policy and the GDPR regulations about your personal data.

Data Protection Commission, 21 Fitzwilliam Square, Dublin 2, D02 RD28, Ireland.
Updated March 14th, 2022.