Privacy Notice for Image Capture

Foxbrush property Limited
v1.2 – last updated 30/5/23

This policy relates solely to image capture by CCTV and/or Electronic Access Control Systems at buildings we manage. You can read more about how your data is captured, stored and processed when doing business with us or using our website in our Cookies & Privacy Policy.

1. Introduction

Foxbrush Property Ltd is a registered “data controller” (number ZB492658). This means that we are responsible for deciding how we hold and use personal information about you. We are committed to protecting the privacy and security of your personal data and to meeting out data protection obligations. We strive to always be clear and transparent about how we collect and use your data, and we are proud signatories of the Real Estate Data (RED) Foundation’s Data Ethics Principles and to support their work in the industry.

Foxbrush Property collects, stores, and processes personal data relating to clients, customers, prospective clients and prospective customers, contractors and suppliers in order to provide property management services. 

Some of the properties we manage have Closed Circuit Television (CCTV) and/or an Electronic Access Control Systems (EACS) which capture video and/or audio of members of the public both inside and outside the building. Your image, when captured by one of these systems in a way that allows you to be identified, is considered personal data.

2. Data protection principles

Foxbrush Property will comply with data protection law. This means that the personal data we hold about you must be: 

  • Used lawfully, fairly, and in a transparent way;

  • Collected only for valid purposes that we have explained to you clearly and not used in any way that is incompatible with these purposes;

  • Relevant to the purposes we have told you about and limited to those purposes only;

  • Accurate and kept up to date;

  • Kept only for such time as is necessary for the purposes we have told you about; and

  • Kept securely.

3. What information does Foxbrush Property collect and process?

  • Your image, as captured by the CCTV or EACS; 

  • The time of your arrival and departure; and

  • Your vehicle registration number (if you arrive at the property in a vehicle and the system is configured to capture this).

This data is stored in the IT system associated with the capture system at the property. If you would like further information about where your data is stored, please contact us and provide the property address to which your query relates.

4. Why does Foxbrush Property process personal data?

We need to process this personal data for the following purposes:

  • To prevent and investigate crime by monitoring the security of the premises;

  • To protect the rights, property and safety of the occupiers of the building;

  • For health & safety; and

  • To manage the property effectively, such as monitoring delivery of goods and services, including as arrival and departure times of contractors and suppliers.

We regularly assess whether it is necessary and proportionate to use CCTV systems at each of the properties where we are the Data Controller by reviewing the lawful purpose for which the images are captured. 

5. Situations in which we will use your personal information 

Situations in which we will process your personal information are listed below:

  • To investigate crimes or suspected crimes;

  • To investigate health and safety incidents; and

  • To investigate issues with the provision of services to the property.

6. Change of purpose

We will only use your personal data for the purposes for which it was collected unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose(s). If we ever need to use your personal data for an unrelated purpose, we will only do so if we are able to contact you and explain the legal basis which allows us to do so.

7. How long does Foxbrush Property keep personal data?

Recorded footage is kept for a limited time before being deleted. The specific retention period depends on the configuration of the system at the property you have visited. Footage may be retained for longer than the standard retention period if this is required to fulfil the purposes we collected it for, for example to investigate a crime.

If you would like further information about how long your image is retained, please contact us and provide the property address to which your query relates.

8. Who is information shared with?

Images of you may be shared internally within Foxbrush Property with members of staff.

We will never sell or rent your images, and we will never share them with third parties for marketing purposes.

However, we may share your images with third parties where required by law or where it is necessary in order to fulfil the purposes for which the images were captured, such as investigating a crime.

Subject to the purposes for which the footage has been collected, it may be shared with:

  • Courts and law enforcement agencies to comply with legal requirements such as the administration of justice; and

  • Companies and other persons providing services to the property, if we have reasonable grounds to believe that the footage relates to their staff or contractors; and

  • Tenants of the property.

Contractors who provide services to support the CCTV or EACS system will also have access to the images captured, but we will only work with contractors who have suitable data protection arrangements in place. 

9. How does Foxbrush Property protect personal data?

Foxbrush Property takes the security of your personal data seriously. We have internal policies and controls in place to prevent your personal data being lost, accidentally destroyed, misused, or disclosed. Details of the specific measures for each property are available on request.

When Foxbrush Property engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

10. Your rights

As a data subject, you have a number of rights. You can:

  • Access and obtain a copy of your data on request (known as a “data subject access request”);

  • Require Foxbrush Property to change incorrect or incomplete data;

  • request erasure of your personal data.  This enables you to ask us to delete or stop processing your data, for example, where the data is no longer necessary for the purposes of processing;

  • Object to the processing of your data where the we are relying on our legitimate interests as the legal ground for processing; and

  • Ask us to suspend the processing of your personal data for a period of time if data is inaccurate or there is a dispute about its accuracy or the reason for processing it.

If you would like to exercise any of these rights, or you have any questions about the property you have visited and whether it has a CCTV or Electronic Access Control System installed, you can contact us using the form on our website.

If you believe that the Foxbrush Property has not complied with your data protection rights, you have the right to make a complaint to the Information Commissioner’s Office.