Somers Psychotherapy CCTV Policy

CCTV cameras are in operation externally in Somers Psychotherapy for the protection of our clients and team members. The purpose of this policy is to regulate the use of Closed Circuit Television (CCTV) and its associated technology when monitoring the external environment of the premises.

This policy applies to all personnel in and visitors to Somers Psychotherapy, 2-3a Orchard Road, Clondalkin, Dublin 22. It relates directly to the location and use of CCTV, and the monitoring, recording, and subsequent use of such recorded material. This policy prohibits CCTV monitoring based on the characteristics and classifications contained in equality and other related legislation e.g. race, gender, sexual orientation, national origin, disability, etc. Furthermore, CCTV monitoring is
limited to uses that do not violate the reasonable expectation to privacy as defined by law.

The CCTV cameras will be used to:

1.    Protect Somers Psychotherapy’s building and assets, both during and outside of operational hours
(the system will be in operation 24 hours a day, every day)

2.    Promote the health and safety of personnel and visitors

3.    Support the Gardaí in a bid to deter and detect crime

4.    Assist identifying, apprehending and prosecuting offenders.

The personal data recorded and stored by the CCTV system will be used only for the purposes outlined in this policy document. Collection, storage, and use of CCTV footage shall be in compliance with Data Protection legislation.

Data Controller: 

The data controller in respect of images recorded and stored by the CCTV system at Somers Psychotherapy’s premises. The data processor is Rachel Somers, Owner of Somers Psychotherapy and is responsible for monitoring the implementation and compliance of the CCTV policy within Somers Psychotherapy.

Fair Obtaining: 

The fair obtaining principles inherent in the Data Protection Acts 1988 and 2003 require that those people whose images may be captured on camera are so informed. Somers Psychotherapy’s Data
Protection Officer will provide a copy of this CCTV Policy to staff and on request to visitors / clients to Somers Psychotherapy. Adequate signage will be placed at each location in which CCTV cameras are situated to indicate that CCTV is in operation.

The name and contact details of the data controller as well as the specific purpose for which the CCTV camera is in place in each location can be provided upon request.

Location of Cameras

The CCTV network for Somers Psychotherapy extends to the following areas:
-External Entrance Unit 1 and 2

Operation of the System

The recording system is a digital system that records video data. The system can only be accessed by the Owner of Somers Psychotherapy.

Data Protection, Storage, and Retention

The data captured from the CCTV cameras is securely stored as electronic data in a designated area within the centre. This data is retained for 30 days however, data may be retained for longer periods if, in the opinion of Somers Psychotherapy, the events captured may give rise to court proceedings. Unauthorised access to the CCTV data is not permitted at any time. Access to the data is restricted to authorised personnel. There is no access to the CCTV data other than with authorised personnel. The storage devices are password protected. Supervising the access and maintenance of the CCTV system is the responsibility of the Owner or appropriate nominee(s).

Access Requests

Access to the CCTV system will be restricted to authorised personnel only. In relevant circumstances, CCTV footage may be accessed by An Garda Síochána where Somers Psychotherapy are required by law. Access requests can be made in writing to Rachel Somers (Owner) Somers Psychotherapy, -3a Orchard Road, Clondalkin, D.22, or by emailing Somerspsychotherapy@gmail.com.

Providing CCTV Images to An Garda Síochána

With regard to requests from An Garda Síochána to download footage, the footage will only be released to An Garda Síochána and, if requested, by a Judge in a Court of Irish Law. The Data Protection Commissioner recommends that requests for copies of CCTV footage should only be granted when a formal written request is provided to Somers Psychotherapy stating that An Garda Síochána is investigating a criminal matter. For practical purposes, and to expedite a request speedily in urgent situations, a verbal request may be sufficient to allow for the release of the footage sought. However, any such verbal request must be followed up with a formal written request. It is up to Somers Psychotherapy to be satisfied that there is a genuine investigation underway. For practical purposes, a phone call to the requesting An Garda Síochána station may be sufficient, provided that one speaks to a member in the District Office, the station sergeant or a higher-ranking officer, as all may be assumed to be acting with the authority of a District/Divisional officer in confirming that an investigation is authorised. A log of all An Garda Síochána requests will be maintained by Somers Psychotherapy.

Review and Approval of the CCTV Policy

This policy will be reviewed and updated regularly to take into account changing Data Protection legislation or guidelines from the Data Protection Commissioner, An Garda Síochána, and relevant bodies.