RATP Dev London operates in the UK static and mobile CCTV systems at most of our locations on our buses and sites that are open to the general public in accordance with the CCTV Code of Practice issued by the ICO in the UK. The system in London is owned by a relevant company of RATP Dev London. “We” or “our” in this notice refers to the relevant RAPT Dev London Company only.
The aim of this privacy notice is to explain the purposes of these video surveillance systems and to provide all information as required by current Data Protection Legislation.
Our CCTV systems are used to capture, record (sometimes only in the cab area of our buses) and monitor images of what takes place at depots and in and around our buses. CCTV is operated for health and safety of employees, customers and members of the public and prevention and detection of crime and anti-social behaviour.
Our purposes are as follows:
- to maintain security at our sites and properties;
- to protect and maintain the health and safety of staff, customers, members of the public and visitors;
- to protect our property and the property of staff, customers, members of the public and visitors;
- to ensure that contractual requirements are met and that complaints can be appropriately investigated;
- to prevent and detect crime;
- to facilitate the apprehension and prosecution of offenders and apprehension of suspected offenders to facilitate the apprehension and prosecution of offenders and apprehension of suspected offenders;
- to assist in the identification of unauthorised actions or unsafe working practices that might result in disciplinary proceedings being instituted against employees and to assist in providing relevant evidence;
- to support learning from incidents and collect statistics (including through third parties) relating to them for example to we may pass CCTV footage to third party organisations for the purpose of safety research and analysis
- to satisfy certain legitimate interest which would include requests such as defending or making a legal claim, such as to insurers following a vehicle collision; or if it is required by law or it is otherwise is necessary for a legitimate purpose such as defending or bringing legal action; and
- to reduce anti-social behaviour towards staff (prevention through deterrence and detection).
Categories of personal data collected
Static and mobile CCTV systems will capture images of staff during their employment, visitors, customers, members of the public and vehicles.
Mobile CCTV systems may capture all of the above but will also capture images of members of the public outside of any of our facilities.
Neither static nor mobile CCTV systems capture audio routinely.
Data capture, overwriting and downloading
Images are all recorded locally to storage media.
CCTV storage media is not routinely downloaded to a computer and is overwritten on a monthly basis (up to a maximum of thirty-one days) unless there is a further legal/contractual requirement to keep the data for longer.
CCTV footage will only be downloaded and stored securely for the following reasons:
- Any accident, injury or near-miss (employee, visitor or member of the public)
- a vehicle-related accident, injury or near miss
- a report of violence or anti-social behaviour against our staff
- to facilitate the apprehension and prosecution of offenders and apprehension of suspected offenders
- to assist in the identification of unauthorised actions or unsafe working practices that might result in disciplinary proceedings being instituted against our employees and to assist in providing relevant evidence
- receipt of a complaint about employee driving standards
- a formal request from an external agency
- a request from an individual to access personal information held (called a Subject Access Request)
Recipients of personal data (video surveillance footage)
Static and CCTV footage are not routinely shared.
Under certain circumstances and only after following due diligence, we may share video surveillance footage with the following:
- Emergency services in connection with the investigation of an accident
- Transport for London (TfL) in pursuit of an investigation of an event/incident or prosecution
- Claimants in civil proceedings
- Insurance companies
- Local authorities
- Prosecution agencies
- Other official/statutory agencies
- The media where the assistance of the general public is required in the identification of a victim of crime or the identification of a perpetrator of a crime, disclosure in this case will only be made by the Police Force concerned
- People whose images have been recorded and retained unless disclosure to the individual would prejudice criminal enquiries or criminal proceedings
Video surveillance footage may be shared with data subjects upon receipt of a subject access request (please see Access Requests section, below).
CCTV (both static and mobile) will be retained for a period of no more than 31 days, after which time the footage will be overwritten unless an investigation is being conducted, in which case images may need to be retained for a longer period.
On buses, the CCTV images are recorded over continually and retained for a maximum of 12 days before it is overwritten automatically, unless downloaded for legitimate reasons.
In accordance with current Data Protection Legislation, CCTV data will not be kept any longer than is necessary and on its expiry should be destroyed in a safe and secure manner.
Certain buses may be equipped with audio recordings in in the drivers’ cabins. Our policies is to disable the functionality when we operate any such buses. We do not routinely enable or use the audio recordings but if we were to do so, we would do it for legitimate purposes such as traffic management and the same purposes which are set out in the section CCTV Purposes.
For the same reasons, audio recordings are not routinely downloaded to a computer and are overwritten within 12 days unless there is a further legal/contractual requirement to keep the data for longer.
Where applicable, we follow the same rules as for CCTV footage regarding data capture, downloading and sharing with third parties.
When downloaded, we keep the data for legitimate purposes and in accordance with the law.
if you have any question regarding audio recordings please use the contact form on our website.
Audio recordings may be shared with data subjects upon receipt of a subject access request (please see Access Requests below).
Under current Data Protection Legislation, individuals have the right (upon request) to receive a copy of any personal data that a RATP Dev London Company holds about them, including images obtained via video surveillance systems, as long as the individual is recognisable from those images. This request is known as a Subject Access Request. We disclose images in response to valid requests from the police and other statutory law enforcement agencies. Before we authorise any disclosure, the police must demonstrate that the personal data is necessary to assist them in the prevention or detection of a specific crime.
If you have any concern about the way we handle your personal information or we use our surveillance camera systems or audio recordings or how we process personal data, or you want to make a complaint please use where possible our Subject Access Request form and send it to us at the address below.
If you wish to access any video surveillance images relating to yourself and these were taken in our premises or on one of our buses, you should:
- make a request to us at https://www.ratpdevlondon.com/contact, specifying the name of the premises or garages where the CCTV camera is located.
- Remember that you can only request footage where you are clearly identifiable. You are not permitted to receive images of other individuals or vehicles.
- Ensure the request includes the date and approximate time when the images were recorded and the location of the particular video surveillance system, so that the images can be easily located and your identity can be established. Other details (such as your vehicle registration number or details of a particular incident/event, may also help to speed up the process). You will also need to submit a clear full length photograph of yourself with your request so that we can identify you when searching for the relevant images.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We will aim to respond promptly and in any case within 30 days of receiving the request.
When we are not required to provide CCTV by law, we will take into account the circumstances and any potential harm to individuals, we may also charge a fee and seek indemnity for any use beyond which it is requested.
RATP DEV LONDON
Stamford Brook Garage
74 Chiswick High Road
London W4 1SY, England.
Attn: Data Protection Officer.
To contact us in relation to any video surveillance operations or audio recordings (if applicable), please email firstname.lastname@example.org or write to the address above.
Under current Data Protection Legislation you have rights related to how we protect and look after your personal information. More information is available in our Privacy Notice.
This Notice was last updated on: 1st April 2021