Esprit Investments Limited and its subsidiaries (“Esprit Investments”) operate CCTV at certain locations under their control. CCTV is used for specified purposes including the security and protection of premises, people and property, and the prevention and detection of crime.
CCTV footage containing identifiable individuals constitutes personal data and is processed by Esprit Investments in accordance with applicable data protection legislation, including the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.
Authorised personnel may access CCTV footage, and it may be shared, where necessary and lawful, with Corvus Property Services, G4s, Covert Security Consultants, Re:sure, Headway Security, Gallant Security, An Garda Síochána, other competent authorities, insurers, legal advisers or other relevant third parties. Where a third-party service provider processes CCTV footage on behalf of Esprit Investments, appropriate data processing and confidentiality arrangements will be maintained.
CCTV footage will be retained for 30 days for the purpose for which it was collected. Footage relating to a particular incident may be retained for longer where this is necessary, for example for the investigation of an incident, the establishment, exercise or defence of legal claims, or where required by law.
CCTV footage will be protected by appropriate technical and organisational security measures. Access will be restricted to authorised persons on a need-to-know basis, and appropriate controls will be maintained regarding the viewing, copying, downloading and disclosure of footage.
Individuals whose personal data is captured by CCTV have rights under data protection legislation, including, where applicable, the right to request access to their personal data. Requests relating to CCTV footage should be directed to info@corvus.ie.
Appropriate CCTV signage will be displayed at monitored locations. Signage and associated privacy information will identify Esprit Investments Limited as the data controller, explain the purpose of the CCTV and provide information on how further details about the processing of personal data can be obtained.
Covert surveillance will not ordinarily be undertaken. Any proposed covert surveillance will be considered only in exceptional circumstances, for example where there are reasonable grounds to suspect criminal activity, and only where it is lawful, necessary and proportionate. Any such surveillance will be subject to a specific written assessment and appropriate safeguards, including a Data Protection Impact Assessment (DPIA) where required, and will be limited in scope and duration