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OWLPEN MANOR

CCTV AND VIDEO SURVEILLANCE POLICY

Last updated: November 2026

1. Introduction

Owlpen Manor uses closed-circuit television (CCTV) and video surveillance in certain areas of the estate to help protect the safety and security of guests, visitors, employees, contractors and property.

This policy explains how we operate our CCTV systems, what information may be collected, how recordings are used and stored, and the rights of individuals whose images may be captured.

We are committed to ensuring that CCTV is used responsibly, proportionately and in accordance with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This policy should be read alongside our Privacy Policy, which provides further information about how Owlpen Manor collects and processes personal information.

2. Who is responsible for CCTV?

The organisation responsible for operating the CCTV system and determining how recordings are used is:

Owlpen Manor
Owlpen Manor
Near Uley
Gloucestershire
GL11 5BZ

Email: hello@owlpen.com

For data protection purposes, the data controller is Owlpen Manor Weddings And Events

3. Why do we use CCTV?

CCTV is operated for legitimate security and safety purposes, including:

  • Protecting the safety and security of guests, visitors, employees and contractors.
  • Protecting buildings, grounds, equipment and other property from theft, damage or unauthorised access.
  • Helping to prevent and detect crime.
  • Assisting with the investigation of accidents, incidents, complaints or security concerns.
  • Supporting the safety and effective management of the estate.

CCTV is not intended to monitor individuals unnecessarily or to observe their private activities.

We will only use recordings for the purposes for which the system is operated, or for another purpose where that use is lawful and compatible with the original purpose.

4. Where CCTV operates

CCTV cameras are installed in selected areas of the estate where monitoring is considered reasonably necessary for safety and security purposes.

The cameras may capture images of individuals entering or moving through areas covered by the system.

We take care to position cameras so that they capture only areas reasonably necessary for the purposes described in this policy. We do not intend to operate CCTV in places where individuals would reasonably expect privacy, such as bathrooms or changing facilities.

CCTV coverage is indicated by appropriate signage displayed in relevant areas.

5. What information do we collect?

Our CCTV systems may collect and record:

  • Images of guests, visitors, employees, contractors and other individuals.
  • The date and time at which images are recorded.
  • Information about individuals’ movements within areas covered by the cameras.
  • Images of vehicles and vehicle registration numbers, where captured by the cameras.

CCTV footage may constitute personal data where an individual can be identified from the recording.

6. Our lawful basis for using CCTV

We process CCTV footage on the basis of our legitimate interests under Article 6(1)(f) of the UK GDPR.

Our legitimate interests are protecting people and property, maintaining security, preventing and detecting crime, and investigating incidents.

We consider whether the use of CCTV is necessary and proportionate for these purposes and whether the interests and fundamental rights of individuals are appropriately protected.

We do not rely on consent as the usual lawful basis for CCTV because individuals may enter areas covered by cameras as part of their visit and genuine consent would not generally be practical.

7. Who can access CCTV footage?

Access to CCTV recordings is restricted to authorised individuals who need access for legitimate security, safety or management purposes.

We will not routinely disclose recordings to members of the public or other organisations.

Footage may be disclosed where necessary and lawful, including to:

  • The police or other law enforcement authorities investigating an incident or suspected offence.
  • Insurers in connection with a relevant claim.
  • Legal advisers or professional representatives where necessary.
  • Relevant regulatory or public authorities where disclosure is required or permitted by law.

We will consider each request for footage individually and will only disclose information where there is a proper legal basis to do so.

8. How long do we keep recordings?

CCTV recordings are normally retained for 30 days, after which they are automatically overwritten or securely deleted.

Where footage is required in connection with an accident, complaint, suspected crime, insurance claim or legal matter, the relevant recording may be retained for longer where necessary. Any such footage will be securely stored and deleted when it is no longer required.

We do not retain CCTV recordings indefinitely or simply because storage capacity permits.

9. Security of recordings

We take appropriate technical and organisational measures to protect CCTV recordings against unauthorised access, disclosure, alteration, loss or destruction.

These measures include restricting access to authorised individuals and taking reasonable steps to ensure that recordings are stored securely.

Individuals who have access to CCTV footage are expected to handle it confidentially and only use it for authorised purposes.

10. Your rights

If you believe that you have been recorded by our CCTV system, you may ask us whether we hold footage in which you appear and request access to that footage.

Requests should be sent to:

Email: hello@owlpen.com

Please provide as much information as possible to help us identify the relevant recording, including:

  • The date and approximate time you believe you were recorded.
  • The location or area in which you believe the recording took place.
  • A description of yourself and, where relevant, the clothing you were wearing.

We may need to ask for further information to establish your identity and locate the relevant footage.

We will normally respond to a valid subject access request within one calendar month, subject to applicable legal requirements. We may need to protect the privacy and rights of other individuals who appear in the same recording. This may involve editing or obscuring images before footage can be supplied.

You may also have other rights under data protection legislation, depending on the circumstances. Further information is available in our Privacy Policy.

11. Complaints and concerns

If you have any questions or concerns about our use of CCTV, please contact us using the details above.

We will consider any concerns raised and respond appropriately.

If you remain dissatisfied, you have the right to raise a complaint with the Information Commissioner’s Office (ICO):

Website: https://ico.org.uk
Telephone: 0303 123 1113

12. Changes to this policy

We may update this policy from time to time to reflect changes in our CCTV arrangements, operational requirements or applicable data protection legislation.

The latest version will be published on our website.