CCTV Policy

 

Introduction

The purpose of this policy is to explain how R & B Wharton Limited T/A Carlton House Guesthouse uses, stores and protects information captured by Closed Circuit Television systems, commonly referred to as CCTV.


This policy also explains the rights of individuals whose personal data may be captured by CCTV and how they may exercise those rights.

R & B Wharton Limited T/A Carlton House Guesthouse is the data controller for personal data captured by CCTV at Carlton House Guesthouse.

 

Purpose of CCTV

CCTV is used by R & B Wharton Limited at Carlton House Guesthouse in line with the needs of the business and in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018 and other applicable data protection legislation.


CCTV is used for the following purposes:


  1. To improve the safety and security of guests, visitors, employees and contractors.
  2. To assist in the investigation of accidents, incidents and near misses so that appropriate risk management measures can be considered and implemented.
  3. To provide reassurance to staff, guests and visitors that reasonable safety and security measures are in place.
  4. To assist local law enforcement authorities in the investigation, detection and prevention of crime.
  5. To deter crime and support the identification of individuals involved in criminal activity.
  6. To discourage anti-social behaviour, including alcohol-related, drug-related or disorderly conduct on or near the premises.
  7. To help protect the premises, property, staff, guests, visitors and contractors.

 

CCTV will not be used for purposes that are incompatible with those listed above.


Lawful Basis for Processing

The lawful basis for processing CCTV images is the legitimate interests of R & B Wharton Limited in maintaining the safety and security of Carlton House Guesthouse, protecting people and property, preventing and detecting crime, and managing incidents.


Where CCTV footage is shared with law enforcement authorities or where disclosure is required by law, processing may also be necessary to comply with a legal obligation.

 


CCTV Signage and Transparency

Appropriate signage is displayed at or near areas covered by CCTV to inform individuals that recording is taking place and to identify R & B Wharton Limited T/A Carlton House Guesthouse as the organisation responsible for the CCTV system.


This policy provides further information about how CCTV footage is used, retained and accessed.

 

Access to CCTV Footage or Images

Access to the CCTV system and stored images is restricted to authorised personnel only. Access is granted only where necessary for the purposes set out in this policy.


In appropriate circumstances, CCTV footage may be accessed or disclosed:


  1. To local law enforcement authorities, where disclosure is necessary for the prevention, detection or investigation of crime or anti-social behaviour.
  2. To individuals whose personal data is captured in the footage, or to their authorised legal representatives, in response to a valid subject access request.
  3. To insurers, legal advisers or other professional advisers where necessary in connection with an incident, claim, dispute or legal obligation.
  4. To individuals or organisations where disclosure is required by law, court order or other legal process.
  5. To other parties where it is lawful, necessary and proportionate to do so.


Where footage includes images of other identifiable individuals, R & B Wharton Limited will take reasonable steps to protect their rights and freedoms, which may include redacting or obscuring images before disclosure where appropriate.

 

Retention Period and Security

CCTV images are retained for a maximum of one month from the date of recording, unless a longer retention period is necessary for one of the purposes set out in this policy.


Footage may be retained for longer where it is required in connection with an accident, incident, complaint, insurance claim, legal claim, investigation, law enforcement request or other lawful purpose.


CCTV images and recordings are stored securely. Access is strictly limited to authorised personnel. R & B Wharton Limited takes appropriate technical and organisational measures to protect CCTV footage against unauthorised access, loss, misuse, alteration or disclosure.


When CCTV footage is no longer required, it will be securely deleted or overwritten.

 

Subject Access Requests

Individuals have the right to request access to CCTV footage in which they are identifiable.


Requests can be made by email or in writing to:


Email: info@whartonproperties.co.uk

Post: Carlton House Guesthouse, 1–3 Carlton Terrace, Scarborough, YO11 2DE

 

Requests will be handled in accordance with the UK GDPR and the Data Protection Act 2018. The ICO states that organisations should respond to subject access requests without undue delay and within one month of receipt, with a possible extension of a further two months for complex requests or where multiple requests are received from the same individual.


To help locate relevant footage, individuals making a request may be asked to provide:


  1. The date, approximate time and location of the recording.
  2. A description of the individual, clothing or other identifying details.
  3. Any other information that may help R & B Wharton Limited locate the footage efficiently.
  4. Proof of identity, such as a passport or driving licence.
  5. Evidence of authority to act, where a request is made by a representative.


R & B Wharton Limited may refuse or limit disclosure where an exemption applies, where disclosure would adversely affect the rights and freedoms of others, or where the request is manifestly unfounded or excessive.


Complaints

If you have concerns about how R & B Wharton Limited uses CCTV or handles your personal data, you should contact us first using the details above.



You also have the right to raise a complaint with the Information Commissioner’s Office, the UK supervisory authority for data protection matters.

 

Review of this Policy

This policy will be reviewed periodically and updated where necessary to reflect changes in the law, regulatory guidance or the way CCTV is used at Carlton House Guesthouse.

 

Last reviewed: 2026