Privacy Policy
INTRODUCTION AND IMPORTANT INFORMATION
Hostsmart Ltd (“we”, “us” or “our”) are committed to protecting and respecting your personal data and privacy.
This privacy policy relates to how we use and collect personal data from you when you book with us as a guest or visitor to our self-catering accommodation (the Property), use our services or access our website. It also relates to our use of any personal information you provide to us by telephone (including SMS or WhatsApp), in written correspondence (including letter and email), through our social media channels and in person.
Please note that:
- our website is not intended for children under the age of 18 and we do not knowingly process personal data relating to children]; and
- our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Whenever you provide personal data, we are legally obliged to use your information in line with all applicable laws concerning the protection of such information; including but not limited to the Data Protection Act 2018 and the General Data Protection Regulation, as it applies to the UK (UK GDPR), described in this policy as the “Data Protection Laws”.
This privacy policy also forms part of our terms of business and is not intended to override them. This policy may be amended or updated from time to time and any revisions will be posted to this page, so please check back regularly.
WHO WE ARE AND HOW TO CONTACT US
For the purpose of the Data Protection Laws, the data controller is Hostsmart Ltd. We are a private limited company registered in England and Wales under company number 15153667. Our registered office is at 19a Hart Street, Henley-On-Thames, RG9 2AR. If you want to request more information about our privacy policy or information regarding data protection you should contact us using the details provided below:
FAO: Privacy Officer
Hostsmart Ltd
United Kingdom
Email: [email protected]
Telephone: 07860155983 and ask to speak to the Privacy Officer.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
THE DATA WE COLLECT ABOUT YOU
We collect and process personal data. Typically, the personal data we collect and process will include identity, contract, transactional, technical, profile, usage and marketing and communications data such as:
- Identity Data includes first name, last name, title or other identifier (such as job title), marital status, date of birth, gender and images.
- Contact Data includes billing address, email addresses and telephone numbers.
- [CCTV Data includes data (including but not limited to images, video and sound) gathered by Closed Circuit Television, Automatic Number Plate Recognition and other surveillance technologies installed at the Property.]
- Transaction Data includes details about services you have purchased from us or your visits to our premises.
- Financial Data includes bank account and payment card details.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences (including details about your personal likes and dislikes as identified during your visits to our premises), feedback and survey responses.
- Usage Data includes information about how you use our Property (including but not limited to any property facilities such as vehicle registrations for approved vehicles on site [or EV charging points]), website, products and services.
- Marketing and Communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Please note that we may collect and/or process other personal data from time to time. If we ask you to provide any other personal information not described above, the personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point that you are asked to provide your personal information.
We also collect, use and share aggregated data, such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data, but is not considered to be personal data in law as it will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate a percentage of users accessing a specific feature of our services. However, if we combine or connect your aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used solely in accordance with this policy.
We do not routinely collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). However, we will collect the health information we need to provide special assistance services requested under the booking or where we need to record and report an incident or accident occurring at the Property. Nor do we collect any information about criminal convictions and offences.
We only collect data from you directly or via third parties (see the section Third Parties below).
It is important that the Personal Data we hold about you is accurate and current. We cannot be held responsible for any inaccurate or incomplete data on our system arising out of your default in this regard. Please keep us informed if your Personal Data changes during your relationship with us.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Profile and Financial Data by filling in forms or by corresponding with us by post, phone, messaging service, email or otherwise. This includes personal data you provide when you:
- book our Property;
- create an account on our website;
- subscribe to our additional service(s);
- request marketing to be sent to you;
- enter a promotion or survey; or
- give us feedback or contact us.
Automated technologies or interactions.
We may also collect your Technical Data about your equipment, browsing actions and patterns when you visit our website. We collect this personal data by using cookies and other similar technologies. Please see below cookie policy for further details.
Visiting the Property.
We may collect your [CCTV Data and] Usage Data through our inspection of the Property [or through use of surveillance systems at the Property in accordance with our CCTV policy.]
Third parties or publicly available sources.
We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
- Contact, Financial and Transaction Data from providers of technical, or payment services.
- Identity and Contact Data from data brokers or aggregators, including trade organisations or exhibition organisers.
- Identity and Contact Data from publicly available sources such as Companies House.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel all or part of a service you have with us but we will notify you if this is the case at the time.
HOW YOUR DATA WILL BE USED
We use information held about you to:
- carry out our obligations arising from any contracts entered into between you and us and provide our services, including any third party services we make available to you;
- carry out feedback and research on our services; and
- notify you about changes to our services.
We never sell your data to third parties or allow third parties to contact you without your permission.
We share your data with third parties where there is a legal obligation for us to do so or we have identified a valid lawful basis as set out in the table below (please also see clause 7 below). We may process your personal data without your knowledge or consent where this is required or permitted by law.
We have set out below in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a guest or visitor of the Property (including any vehicles). Identity
Contact
Usage
Performance of a contract with you.
Necessary for our legitimate interests (to ensure unauthorised visitors do not attend or occupy the Property).
[To register you as a website account holder and set up your account profile.] [Identity
Contact
Profile]
[Performance of a contract with you].
To provide our self-catering accommodation and connected service(s) (including but not limited to activities) to you and to process related transactions, including:
Manage payments, fees and charges
Collect and recover money owed to us.
Identity
Contact
Transaction
Usage
Marketing and Communications
Performance of a contract with you.
Necessary for our legitimate interests (to recover debts due to us).
To provide you with request special assistance. Identity
Contact
Health (Special Category Data limited to what is necessary for the provision of special assistance)
Explicit consent.
To manage our relationship with you which will include:
Notifying you about changes to our terms or privacy policy.
Asking you to leave a review or take a survey
Identity
Contact
Profile
Marketing and Communications
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
[To keep the Property, our staff, contractors and guests secure]. [CCTV]
[Usage]
[Necessary for our legitimate interests (to keep our Property secure and ensure the wellbeing of staff and guests while at the Property). A copy of our Legitimate Interest Assessment (LIA) in relation to our use of the CCTV system is available on request.]
To record incidents and accidents occurring at the Property. Identity
Contact
Usage
Health (Special Category Data)
Necessary to comply with a legal obligation (health and safety).
Necessary for our legitimate interests (to ensure the Property is fit for use by guests and resolve complaints).
We may also use this information to exercise and defend our legal rights and may be required by law to process this information.
[To assess your compliance with our EV Charging Policy]. [Identity
Contact
Usage]
[Necessary to comply with a legal obligation (health and safety).
Necessary for our legitimate interests (to ensure fair use of our EV facilities)].
To enable you to partake in a competition or complete a survey. Identity
Contact
Profile
Usage
Marketing and Communications
Performance of a contract with you.
Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). Identity
Contact
Technical
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
Necessary to comply with a legal obligation.
To measure or understand the effectiveness of the advertising we serve to you. Identity
Contact
Profile
Usage
Marketing and Communications
Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our website, services, marketing, customer relationships and experiences. Technical
Usage
Profile
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about services that may be of interest to you. Identity
Contact
Technical
Usage
Profile
Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business).
LAWFUL BASIS FOR PROCESSING
We only process your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. These are as follows:
- Contractual obligation – means processing that is necessary to comply with our obligations arising out of a contract, for example, where you have bought services from us we will use the personal data you provide to fulfil our contractual obligations.
- Legitimate Interest – means in the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process you personal data for our legitimate interests. Where we use legitimate interests we will record our decision on making this decision. We rely on legitimate interest where processing of the data we hold on you does not, in our opinion, affect your rights or freedoms and is proportionate to our interests e.g. keeping you up to date with our latest services or obtaining your feedback on our service.
- Consent – We will seek to obtain your consent to process:
- your data outside our contractual obligations (see above) unless we have identified a Legitimate Interest (see above); and
- any special category data.
- Legal obligation – We may process your data where we it is necessary for us to do so to comply with the law.
We may also process your personal data in the following circumstances, which are likely to be rare:
- Vital Interests – where we need to protect your vital interests or someone else’s vital interests (the processing is necessary to save a life); and/or
- Public Task – processing your personal data is needed in the public interest.
THIRD PARTIES AND SHARING INFORMATION
We will keep your information within the organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you.We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
Please see below the list which sets out the categories of recipients of personal data.
SERVICE PROVIDERS WHO MAY RECEIVE YOUR PERSONAL DATA & LOCATION
(e.g within the UK, EEA or outside of the UK/EEA)
- IT Support Services
- Email Provider
- Website Provider
- Secure document disposal service
- Banks
- Online payment providers
- Accountants
- Insurers
- Solicitors
- Software Providers
- Feedback aggregators and collectors
- Couriers
- Marketing Agencies
We may disclose your Personal Data to any competent law enforcement body, regulator, government agency, court or other third party where we believe disclosure is necessary: (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
We may also be required to share your Personal Data as part of any sale, transfer or merger of our business or assets (or parts thereof). Such disclosure will be subject to the buyer’s processing of your Personal Data on terms equal to the protections afforded to you by this policy.
In addition, third parties may provide us with personal data and they should only do so where the law allows them to. This may vary our position as Data Controller under clause 1.
INFORMATION SECRUITY
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.
MARKETING
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We strive to provide you with choices regarding certain personal data uses, namely around marketing and advertising. In particular:
We will always obtain your express opt-in consent before we share your personal data with any third party for marketing purposes; and
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to your or by contacting us at any time.
INTERNATIONAL TRANSFERS
Your data is stored by us and our processors in the UK. However, several of our external third parties are based outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that we only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Whenever we transfer your personal data to countries outside of the UK and/or European Economic Area (‘EEA’), where we use certain service providers (see clause 8.2), we will rely on an appropriate international data transfer mechanism (such as standard contractual clauses (SCCs), international data transfer agreements (IDTAs) or any future agreed mechanisms) approved by the UK regulatory authority, the Information Commissioner’s Office. In addition, we will ensure that we have received assurances that an adequate level of protection of the personal data is achieved (based on a case by case assessment of the circumstances of the transfer), including adequate technical and operational measures in place to protect the personal data.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
DATA RETENTION
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being clients.
In some circumstances you can ask us to delete your data (see below for further information).
We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. Please see clause 2.
YOUR RIGHTS
Under the data protection laws your rights are:
To be informed – We must make this privacy policy (sometimes referred to as a privacy notice) available to you and be transparent over how we process your data.
Access – You are entitled to know what details we hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. You can find out if we hold any of their personal data by making a formal request under the data protection laws. Such requests should be made using the contact details provided in this policy. If we do not hold information about you we will confirm this in writing at the earliest opportunity. If we do hold your personal data we will respond in writing. Our response will:
- confirm that your data is being processed;
- verify the lawfulness and the purpose of the processing;
- confirm the categories of personal data being processed;
- confirm the type of recipient to whom the personal data have been or will be disclosed; and
- let you have a copy of the data in format we deem suitable or as reasonably required by you.
Rectification – We are obliged to correct or update your details. We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.
Erasure – This is also known as the right to be forgotten. Under Data Protection Laws you have the right to require us to erase your personal data under specific circumstances. A request for your personal data to be deleted will be decided on a case by case basis and should be submitted in writing to the contact details provided in this policy.
Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data.
Portability – You have the right to obtain the personal data that you have provided to us in a commonly used machine-readable format and reuse it with a different provider.
Object – You have the right to object to us processing your data in certain circumstances. You have an absolute right to stop your data being used for direct marketing, but in other circumstances we may still be allowed (or required) to process your personal data if we can show you that we have a compelling reason for doing so.
Rights in relation to automated decision making and profiling – We do not use automatic decision making or profiling.
Withdraw consent. Where you have given us consent to process your personal data, you can withdraw that consent at any time either by contacting us using the details set out in this policy, or by following the opt-out links in electronic messages where relevant. We do not penalise individuals who wish to withdraw consent and we act on withdrawals of consent as soon as we can.
Please note that:
- in certain circumstances Data Protection Laws may relieve us of some of our obligations to you under the rights summarised above; and
- you may need to provide identification in order to prove who you are if you wish to invoke any of your rights as provided by the data protection laws and as summarised above.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
APPLICATIONS TO WORK FOR US
If you apply to work for us (directly or indirectly) in any role we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy.
CHANGES TO THE PRIVACY POLICY
We keep our privacy policy under regular review. This version was last updated on 13.03.2024
Cookie Policy
This policy sets out information about our use of Cookies on our website.
“We”, “us” or “our” means Hostsmart Ltd (registered company number 15153667
Our registered address is 19a Hart Street, Henley-On-Thames, RG9 2AR
“Website” means www.hostsmart.co.uk
We are registered with the Information Commissioner’s Office as a data controller under number ZB388729
If you wish to contact us, please click here https://hostsmart.co.uk/contact-us/
What is a cookie?
A ‘cookie’ is a type of data file that is stored on your device when you visit a website or perform actions while visiting a website. A cookie file contains information that is transferred to your device’s memory which is recalled when you revisit our site, or when you perform certain actions on your device. Where we refer to a cookie in this policy, this incorporates similar tracking technologies.
Necessary Cookies
When you first visit our website, we only use necessary cookies. This means that additional cookies (called “Optional Cookies” in this policy) won’t be used unless you agree to accept/enable all cookies, or select your own cookie preferences.
Optional Cookies
Optional cookies are used for analytical, performance, advanced functionality and advertising purposes. More information is set out in this policy. Optional cookies help us improve our website and we believe accepting all optional cookies provides you with the best user experience.
Cookies can be “First Party”, i.e. set by us, or “Third Party”, i.e. placed on your device by another organisation when you visit our website. Third-party cookies may be placed on your device by an organisation providing a service to us or by our business partners, so that they can advertise products and services to you on our website and elsewhere on the internet. Because of how cookies work, our website cannot access third-party cookies stored from other websites; nor can other organisations access the data in the cookies we use on our website.
Changing your preferences
You can select to accept/enable some or all of the optional cookies either within the settings of your own device or by selecting the option provided on our website.
How long will cookies stay on my device?
The length of time a cookie will stay on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies should expire when you stop browsing. Persistent cookies stay on your device until they expire after a set period or are deleted. For each of the cookies used on our website we have set out the duration in the tables below.
The Cookies we use on our website
Necessary Cookies
Necessary Cookies are cookies that are required for the operation of our website. They include, for example, cookies that allow page navigation or enable you to access certain areas of our website. Our website cannot function properly without these cookies. Necessary Cookies can only be disabled by changing your browser preferences but doing so may result in reduced or limited functionality of our website. In some circumstances our website may cease to function as intended if necessary cookies are disabled, deleted or otherwise altered. We do not accept any liability for any loss arising where necessary cookies are disabled, deleted or otherwise altered. We use the following necessary cookies:
Cookie Name Purpose Controller Further Information (including duration of cookie)
PEPSESSID This cookie holds navigation, page id/information and variables crucial to the running of the website Our Cookie This cookie is session based and is deleted the next time you close your browser.
Optional Cookies
We and third parties like to use cookies on this website to enhance your user experience, personalise content and advertisements, provide social media features, and analyse the traffic/visitor actions on our website. Optional cookies help us to provide you with the experience we intend to provide when you browse our website and also allow us to improve our website and the service we provide.
We need to obtain your consent to use Optional cookies; this is usually by way of a pop-up notice. As set out in this policy, you can change your preference at any time.
Advanced functionality, Analytics and Performance (Optional)
We use advanced functionality cookies to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
We use analytical/performance cookies to enable us to recognise and count the number of visitors and to see how visitors use our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
We would like to use the following optional advanced functionality, analytics and performance cookies:
Cookie Name Purpose Controller Further Information (including duration of cookie)
Google Analytics This cookie allows us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our website works, for example by ensuring that users are finding what they are looking for easily Third Party Cookie / Our Cookie [For further information, please visit:http://www.google.com/analytics/]
Social Media Cookies
We use social media cookies to allow you to share our website (or parts of it) on social media.
These cookies are likely to be analytical/performance cookies or targeting cookies. Please note that our social media partners may also use cookies over which we have no control and if you have consented to the use of those cookies elsewhere, as they are on your device without your consent, those cookies will be active. We cannot prevent this. To control the use of these cookies, you will need to contact the controller of that cookie.
We use the following social media platforms:
Cookie Name Purpose Controller Further Information (including duration of cookie)
Instagram Social media [Third Party Cookie / Our Cookie]
Facebook Social media [Third Party Cookie / Our Cookie]
CCTV Policy
POLICY STATEMENT
We have assessed that security cameras, Closed-Circuit Television (CCTV) and other surveillance systems have a legitimate role to play in helping to maintain a safe and secure environment for all our staff and visitors. However, we recognise that this may raise concerns about the effect on individuals and their privacy. This policy is intended to address such concerns. Images and audio recorded by surveillance systems are personal data which must be processed in accordance with data protection laws. We are committed to complying with our legal obligations and ensuring that the legal rights of our visitors and staff, relating to their personal data, are recognised and respected.
DEFINITIONS
For the purposes of this policy, the following terms have the following meanings:
CCTV fixed and domed cameras, smart doorbells, and any other recording equipment designed to capture and record images and audio of individuals and property.
Data information which is stored electronically, or in certain paper-based filing systems. In respect of CCTV, this generally means video images with audio. It may also include static pictures such as printed screen shots.
Data subjects all living individuals about whom we hold personal information as a result of the operation of our CCTV (or other surveillance systems).
Personal data data relating to a living individual who can be identified from that data (or other data in our possession). This will include video images of identifiable individuals.
Data controllers the people who, or organisations which, determine the manner in which any personal data is processed. They are responsible for establishing practices and policies to ensure compliance with the law. We are the data controller of all personal data used in our business for our own commercial purposes.
Data users those of our employees whose work involves processing personal data. This will include those whose duties are to operate CCTV cameras and other surveillance systems to record, monitor, store, retrieve and delete images. Data users must protect the data they handle in accordance with this policy and our Privacy Policy.
Data processors any person or organisation that is not a data user (or other employee of a data controller) that processes data on our behalf and in accordance with our instructions (for example, a supplier which handles data on our behalf).
Processing any activity which involves the use of data. It includes obtaining, recording or holding data, or carrying out any operation on the data including organising, amending, retrieving, using, disclosing or destroying it. Processing also includes transferring personal data to third parties.
Surveillance systems any devices or systems designed to monitor or record images and/or audio of individuals or information relating to individuals. The term includes CCTV systems as well as any technology that may be introduced in the future such as body worn cameras, unmanned aerial systems, smart doorbells and any other systems that capture information of identifiable individuals or information relating to identifiable individuals.
ABOUT THIS POLICY
We currently use CCTV on and around our Property. This policy outlines why we use CCTV on our Property, how we will use CCTV and how we will process data recorded by CCTV cameras to ensure we are compliant with data protection law and best practice. This policy also explains how to make a subject access request in respect of personal data created by CCTV.
We recognise that information that we hold about individuals is subject to data protection legislation. The images of individuals recorded by CCTV cameras in the workplace are personal data and therefore subject to the legislation. We are committed to complying with all our legal obligations and seek to comply with best practice suggestions from the Information Commissioner’s Office (ICO).
This policy covers all guests and visitors of the Property, our staff and contractors. It may also be relevant to visiting members of the public.
The policy will be regularly reviewed to ensure that it meets legal requirements, relevant guidance published by the ICO and industry standards.
PERSONNEL RESPONSIBLE
Emily Courtney of Hostsmart Ltd has overall responsibility for ensuring compliance with relevant legislation and the effective operation of this policy. Day-to-day management responsibility for deciding what information is recorded, how it will be used and to whom it may be disclosed has been delegated to on site managerial staff.
REASONS FOR THE USE OF CCTV
We currently use CCTV around our site as outlined below. We believe that such use is necessary for legitimate business purposes, including:
- to prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime;
- for the personal safety of guests, staff, visitors and other members of the public and to act as a deterrent against crime;
- to support law enforcement bodies in the prevention, detection and prosecution of crime;
- to assist in day-to-day management, including ensuring the health and safety of guests, staff and others;
- in relation to employees and workers, to assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings; and
- to assist in the defence of any civil litigation, including employment tribunal proceedings.
This list is not exhaustive and other purposes may be or become relevant.
MONITORING
CCTV monitors areas within the boundary of the Property 24 hours a day and this data is continuously recorded.
Camera locations are chosen to minimise viewing of spaces not relevant to the legitimate purpose of the monitoring. As far as practically possible, CCTV cameras will only cover entry and exit points, communal and public areas of the Property and will not focus on private spaces which are to be enjoyed by guests. Under no circumstances shall CCTV be installed in, or otherwise focus on, toilets, shower facilities, swimming pool areas, hot tubs, changing rooms, bedrooms or private offices or staff resting areas.
HOW WE WILL OPERATE ANY CCTV
Where CCTV cameras are placed at the Property, we will ensure that signs are displayed at the entrance of the surveillance zone to alert individuals that their image may be recorded. The surveillance zone is the area that the CCTV covers only, not necessarily the whole property. Such signs will contain details of the organisation operating the system, the purpose for using the surveillance system and who to contact for further information, where these things are not obvious to those being monitored.
Live feeds from CCTV cameras will only be monitored where this is reasonably necessary, for example to protect health and safety.
We will ensure that live feeds from cameras and recorded images are only viewed by approved members of staff whose role requires them to have access to such data. This may include HR staff involved with disciplinary or grievance matters.
USE OF DATA GATHERED BY CCTV
In order to ensure that the rights of individuals recorded by the CCTV system are protected, we will ensure that data gathered from CCTV cameras is stored in a way that maintains its integrity and security. This may include encrypting the data, where it is possible to do so.
Given the large amount of data generated by surveillance systems, we may store video footage using a cloud computing system. We will take all reasonable steps to ensure that any cloud service provider maintains the security of our information, in accordance with industry standards.
We may engage data processors to process data on our behalf. We will ensure reasonable contractual safeguards are in place to protect the security and integrity of the data.
RETENTION AND ERASURE OF DATA GATHERED BY CCTV
Data recorded by the CCTV system will be stored digitally using a cloud computing system. Data from CCTV will not be retained indefinitely but will be permanently deleted once there is no reason to retain the recorded information. Exactly how long that data will be retained for will vary according to the purpose for which they are being recorded. For example, where recordings are for the purpose of crime prevention purposes, data will be kept long enough only for incidents to come to light. We will maintain a comprehensive log of when data is deleted outside of our usual retention schedules.
At the end of their useful life, data in all formats will be erased permanently and securely. Any physical matter such as tapes or discs will be disposed of as confidential waste. Any still photographs and hard copy prints will be disposed of as confidential waste.
USE OF ADDITIONAL SURVEILLANCE SYSTEMS
Prior to introducing any new surveillance system, we will carefully consider if they are appropriate by carrying out a privacy impact assessment (PIA).
A PIA is intended to assist us in deciding whether new surveillance systems are necessary and proportionate in the circumstances and whether they should be used at all or whether any limitations should be placed on their use.
Any PIA will consider the nature of the problem that we are seeking to address at that time and whether the surveillance is likely to be an effective solution, or whether a better solution exists. In particular, we will consider the effect a surveillance system will have on individuals and therefore whether its use is a proportionate response to the problem identified.
No surveillance cameras will be placed in areas where there is an expectation of privacy (for example, in changing rooms) unless, in very exceptional circumstances, it is judged by us to be necessary to deal with very serious concerns.
COVERT MONITORING
We will never engage in covert monitoring or surveillance (that is, where individuals are unaware that the monitoring or surveillance is taking place) unless, in highly exceptional circumstances, there are reasonable grounds to suspect that criminal activity or extremely serious malpractice is taking place and, after suitable consideration, we reasonably believe there is no less intrusive way to tackle the issue.
In the unlikely event that covert monitoring is considered to be justified, it will only be carried out with the express authorisation of Hostsmart Ltd. The decision to carry out covert monitoring will be fully documented and will set out how the decision to use covert means was reached and by whom. The risk of intrusion on innocent workers or customers will always be a primary consideration in reaching any such decision.
Covert monitoring will only be carried out for a limited and reasonable period of time consistent with the objectives of making the recording and will only relate to the specific suspected illegal or unauthorised activity.
ONGOING REVIEW OF CCTV USE
We will ensure that the ongoing use of existing CCTV cameras at the Property is reviewed periodically to ensure that their use remains necessary and appropriate, and that any surveillance system is continuing to address the needs that justified its introduction.
REQUESTS FOR DISCLOSURE
We may share data with other group companies and other associated companies or organisations, for example shared services partners where we consider that this is reasonably necessary for any of the legitimate purposes set out above in paragraph 5.
No recordings from our CCTV will be disclosed to any other third party, without express permission being given by Hostsmart Ltd Data will not normally be released unless satisfactory evidence that it is required for legal proceedings or under a court order has been produced.
In other appropriate circumstances, we may allow law enforcement agencies to view or remove CCTV footage where this is required in the detection or prosecution of crime.
We will maintain a record of all disclosures of CCTV footage.
No CCTV footage will ever be posted online or disclosed to the media.
SUBJECT ACCESS REQUESTS
Data subjects may make a request for disclosure of their personal information and this may include CCTV images and, if captured, audio (data subject access request) in accordance with our Privacy Policy.
In order for us to locate relevant footage, any requests for copies of recorded CCTV images must include the date and time of the recording, the location where the footage was captured and, if necessary, information identifying the individual.
We reserve the right to obscure images of third parties when disclosing CCTV data as part of a subject access request, where we consider it necessary to do so.
COMPLAINTS
If you have questions about this policy or any concerns about our use of CCTV, then they should speak to Emily Courtney in the first instance.
REQUESTS TO PREVENT PROCESSING
We recognise that, in rare circumstances, individuals may have a legal right to object to processing and in certain circumstances to prevent automated decision making (see Articles 21 and 22 of the UK General Data Protection Regulation). For further information regarding this, please contact Emily Courtney.