Hello,
I have recently returned from maternity leave and have received a
complaint regarding the following. I hope you'll be able to provide
some guidance.
An estate Concierge Officer has submitted a complaint regarding Tenant
Representatives selling Laundry Tokens voluntarily (on behalf of the
Council) from their Office. The Tenants Reps sell the aforesaid tokens
on alternate Saturdays for an hour. A decision was made to sell the
tokens in the office as it is secure, taking into account the Reps
Safety. Their safety is paramount.
The Concierge Officer has concerns that these Reps have access to
personal data held on files and images on CCTV monitors. As it is a
small estate office CCTV monitors and personal files are held in the 1
office. Screens have been erected to attempt to ensure that the CCTV
images can not be viewed by members of the public. However Officers and
Tenants Reps entering the office would be able to view the images.
Would this be in breach of the 7th Data Protection Principle (Security
of data)? In my opinion the Reps would be classed as Data Processors,
would this be correct? Carrying out duties on behalf of the Data
Controller. Therefore the Reps concerned have signed a confidentiality
agreement regarding non disclosure of any personal data they come into
contact with.
The CCTV system displays images in realtime, and is also recorded.
Therefore when Concierge Officers leave the Office they could turn the
monitors off. Whilst the tokens are being sold, a Concierge Officer is
present unless there is an emergency on the estate.
The CCTV guidance from TICO states that 'monitors displaying images from
areas which individuals would have an expectation of privacy should not
be viewed by anyone other than authorised employees of the user of the
equipment'. With this in mind, in your opinion could this practice
continue?
I look forward to your replies.
With kind regards,
Julie Bentley
Data Protection Adviser
ICTS, Wolverhampton City Council
Tel: 01902 (55)4498 Fax: 01902 (55)4582
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