CCTV Policy

This policy outlines the practices Stay at Mine Limited, Be London and any associated brands employ in regards to closed-circuit television recording.

Definitions

Be London: Be London refers to, and is a trading name of Stay at Mine Limited and other associated companies, which include (but are not limited to) Be London Estates Limited, Be London Holdings Limited and Be London Investments Limited.

Privacy policy, GDPR policy or Policies: Our policies as published on our website https://be.london/legal or (in the case of internal-only policies) on internal systems or referred to in the Employee Handbook.

Apartment, Property or Unit: An individual unit in which a guest has exclusive use during their stay. This is the reserved apartment or house, but does not include areas to the exterior of the individual door to the unit. Personnel authorised by Be London may enter these areas, but they are not generally open to the general public, or to guests in other units.

CCTV: Any visual recording systems installed, whether by Be London, their partners or building owners to which Be London hold no affiliation.

Operational Areas: A location which is used for operational purposes, but is not individually reservable by a guest. For example, Be London’s offices, or communal areas.

Communal Areas: Areas which are not intended for use by the general public, but rather shared spaces between residents or tenants of one or more apartments. For example a hallway in an apartment building, or external courtyard.

Be London Operated System: In most cases, Be London operates and manages CCTV in areas where it is installed. In some cases however, another company or government agency may operate CCTV equipment. In these cases, Be London may not have on-demand access to the system, and queries regarding an SAR, footage, the use of footage and polices may have to be redirected to them. This includes, for example buildings where there are non-Be London units or external public areas with CCTV operated by government agencies or local authorities.

Stakeholders: Individuals who engage and communicate with Be London. This includes but is not limited to staff, guests, customers, clients, agents and partners of Be London.

Staff: An individual employed by Be London, contracted by Be London or acting on behalf of Be London.

Purpose

CCTV is recorded for the purposes of:

Safety and security
Prevention and detection of crime
Ensuring adherence to policies and procedures
Resolution of disputes between stakeholders

Scope

CCTV is in place in several locations across Be London properties and operational areas.

They are not present in the internal parts of a unit. Areas such as gardens, communal areas, courtyards or patios may have CCTV installed within them, but cameras will not point inside a unit.

In areas where CCTV is installed, they are installed in an overt manner, no camera in any area is covertly installed. Signage is present in all areas where CCTV monitoring is in place.

The list of properties with CCTV changes with the addition or removal of units in the Be London portfolio. Please contact the team to verify if CCTV is installed in a particular unit.

CCTV may not always be a Be London Operated System, and may be installed and operated by another company unaffiliated with Be London. In these cases, they are subject to their data protection policies, Be London may not have on-demand access and you may be required to contact them directly with any queries you may have, including a subject access request (SAR). In these cases, the remainder of this policy does not apply. In any case our use of this footage is subject to our privacy policies and GDPR policy.

For the avoidance of doubt, audio recording is not active in any Be London operated system, in some cases CCTV equipment is capable of audio capture however this functionality is disabled.

Data Playback & Storage

Any playback of footage will take place exclusively amongst personnel acting under the authority of a member of the management team.

Recordings are typically stored on hard drives on-location and is protected through physical barriers, encryption and software barriers, in some cases they may be stored encrypted in the cloud by the provider of the CCTV system.

In the event specific recordings are downloaded for investigation or inspection, they will be stored in on Be London’s secure and internal only, cloud-storage system. Shared specifically with a limited number of employees and deleted once the conclusion of any investigation is reached.

Live streaming and remote playback of footage can only be carried out whilst connected to the Be London internal network. This is managed by the IT Manager/Data Protection Officer.

The recording and monitoring of telephone communications are in line with the General Data Protection Regulations (GDPR), in conjunction with our privacy policy which can be found on our website.

A Subject Access Request should be issued in the event an individual would like access to footage in which they are present. This should be made to Be London and will be handled by the IT Manager/Data Protection Officer. The request will be assessed and a response issued in line with legal regulations and this policy.

Once a request has been verified and approved, the requestor will be sent the recording electronically. In the event that the request is made in a non-digital format, arrangements will be made to transfer the requested files.

An appropriate request from a government body, relating to the detection or prevention of a crime or other legally approved purpose should be sent to Be London, the IT Manager/Data Protection Officer will assess and carry out this request.