What Are Cookies?

Cookies are small files which are stored on a user’s computer. They are designed to hold a modest amount of data specific to a particular client and website and can be accessed either by the web server or the client computer. This allows the server to deliver a page tailored to a particular user, or the page itself can contain some script which is aware of the data in the cookie and so is able to carry information from one visit to the website (or related site) to the next.

If you would like to know more about cookies, or how to control and delete them, you can visit www.aboutcookies.org

Cookies we set

• To remember if you have seen the cookie policy notification.
• To remember whether you are signed in or not (administration only).

Cookies others set

This website uses Google’s analytics service to measure how many people visit the site, and which pages are visited

Health & Safety statement of Intent:

The Directors of Greenfield Engineering (Sheet Metal) Ltd, regard the promotion of Health & Safety measures as a mutual objective for management, employees, and contractors at all levels.

It is the declared company policy to do all that is reasonably practicable to prevent personal injury, ill health, and damage to property and to protect everyone from foreseeable work hazards within their control, including the public in so far as they come into contact with the company activities either on or off site.

The company commit to providing all employees with a safe working environment by conducting frequent health and safety risk assessments and providing adequate personal protective equipment.

It is the policy of the company, where it is reasonably practicable to ~

• Provide plant and systems of work that are safe and without risk to health.
• Provide a safe handling and transport of articles and equipment.
• Provide comprehensive information, instruction, training, and supervision, ensuring in so far as it is reasonably practicable, the health, safety and welfare of every employee.
• To maintain, so far as is reasonably practicable a safe and risk-free site and provide safe means of access to and egress from the workplace areas within the site.
• Provide and maintain a safe and healthy working environment with adequate welfare facilities and arrangements.
• Eliminate hazards and control OH&S risks.
• Continually improve the OH&S management system
• Promote consultation and participation of workers, and, where they exist, workers’ representatives.

The Health & Safety at Work Act and other relevant legislation are to be complied with at all times. All employees and contractors are encouraged to contribute towards work areas as safe as possible by continually appraising working practices and ensuring that the safest possible methods are adopted. The company is committed to comply with applicable legal requirement to which they subscribe. This includes ~

• Providing the framework for setting and reviewing Occupational Health & Safety objectives.
• Ensuring that the Occupational Health & Safety system is available to interested parties.
• Ensuring that the Occupational Health & Safety system is reviewed annually and remains relevant.

Employees / contractors also have a duty to cooperate in this objective ~

• By working safely and efficiently.
• By using any equipment provided in a safe and efficient manner.
• By using the correct PPE including ear defenders, which supports the company’s “mandatory ear protection policy”
• By reporting any incidents that have led or may lead to injury or damage.
• By adhering to site safe procedures for securing a safe place of work.
• By assisting in the investigation of accidents with the objective of introducing measures to prevent reoccurrence.
• By taking a positive attitude to accident prevention, being vigilant at all times to prevent any mishaps however trivial or seemingly improbable and bringing them to the attention of management for action.

Simon Walker (Operations Director)

Health & Safety at Work Act 1974:

The Health and Safety at work act imposes statutory duties on all employers and employees; the company will carry out these duties. The company will ensure that the responsibilities for Health & Safety are properly assigned, accepted, and fulfilled at all management levels. This will ensure that all practical steps are taken to safeguard the health, safety and welfare of all employees and visitors to the premises, or operations under the control of the company.

The business will endeavour, as far as is reasonably practical, to ensure the following:

(a) Activities and processes are risk assessed with control measures defined and implemented.

(b) Arrangements for the use, handling, storage and transport of articles and substances for use at work are safe with risk to health suitably controlled.

(c) That adequate information is available with respect to articles and substances used at work, detailing the conditions and precautions necessary to ensure that when properly used, they will be safe with risk to health minimised. These details are available from the Health & Safety Advisor.

(d) The company will provide such information, instruction, training, and supervision as is necessary to ensure the health and safety at work of employees.

(e) The maintenance of all plant, machinery and equipment at any premises or operation under the company’s control are safe for employees, contractors and any other person who may be affected by its undertakings.

(f) The working environment of all employees is safe and adequate provision is made with regard to facilities and arrangements for their welfare at work including safe access and egress and suitable arrangements for emergency situations.

(g) The Health & Safety Policy is appraised and updated as and when necessary. All changes will be communicated to employees via the staff intranet, Team Leaders, and Managers.

It is the duty of every employee at work:

(a) To take reasonable steps for the Health & Safety of themselves and others who may be affected by their acts or omissions at work.

(b) To co-operate with the management so far as is necessary to enable that duty or requirement to be performed or complied with. To achieve the above, the company will provide appropriate training for Managers and employees and participate in joint consultation on matters of Health & Safety. The company will provide protective clothing if and when necessary and will at all times engage fully in its responsibilities in Health & Safety matters.

Health & Safety

In common with all other industrial organisations the Company is faced with general hazards relating to fire, means of entrance and exit to the buildings, guarding of machinery, general working conditions, operation of forklift trucks, noise and manual handling and intends to continue to take appropriate action to deal with them. Updated detailed instructions will be issued from time to time and employees will be notified via the intranet, Team Leaders, and Managers.

Handling of Substances

The company provides suitable protective equipment for use when handling materials and substances, on site, all substances are labelled, and CoSHH (control of substances hazardous to health) Health & Safety Material Safety Data Sheets (MSDS) are on the MRP System 123. There is also access on a shared drive.

If you are about to handle a substance with which you are not familiar, you must ask your Team Leader/Manager to show you the appropriate Material Safety Data Sheet and comply with the recommended handling procedure and wear the appropriate protective equipment.

First Aid and Medical Examinations

First aid facilities are available throughout the company, and the names of the first aiders are posted on the noticeboards. All injuries must be treated as necessary and recorded in the accident book, by an appointed first aider.

Any injury requiring 7 days off work, a broken bone (except fingers or toes), an overnight stay in hospital, or other categories of accident/illness as specified by the Health & Safety Executive (HSE) will be reported to the HSE under the RIDDOR (2013) Regulations.

If you sustain an injury at work and it is not reported to a First Aider or recorded in the accident book, sick pay will not be made to you for any time absent from work as a result of the injury.

All employees will be requested to complete a medical questionnaire form prior to commencing employment and will be asked to update it every three years. It is your responsibility to report major changes to your health situation so that the company is aware of any special risk that might attach to you undertaking a specific job and can take appropriate action.

Greenfield Engineering operate a successful occupational health assessment program which is a contractual requirement and is not optional. All employees must attend an OH clinic when invited to do so.

Responsibilities of Individuals

The Health & Safety at Work Act 1974 places a specific responsibility on you as an employee.

It is your duty while at work:

1. a) to take reasonable care for the Health & Safety of yourself and of others who may be affected by your acts or omissions at work.
2. b) co-operate with employers and co-workers to help everyone meet their legal requirements.
3. c) to not intentionally or recklessly interfere with or misuse anything provided in the interest of health, safety, and welfare.
4. d) wear ear protection at all times when on the shopfloor.

In practice the following summarises some of these responsibilities. More detailed Health & Safety instructions will be issued from time to time.

(a) You will be expected to wear adequate workwear supplied by the company and ensure that they are intact. T-shirts cleaned regularly and sweatshirts, safety footwear must be worn as provided. Permanent staff will be provided with safety footwear at the start of employment (where possible) and replaced as required at the expense of the company.

Any employee who arrives at work unsuitably dressed (i.e. not in the correct workwear) will be sent home unpaid.

(b) Personal protective equipment (PPE) is a company requirement for specific operations and failure to wear equipment provided could result in disciplinary action being taken against you. Approved PPE must be worn when specified in the risk assessment and/or safe system of work. Welding visors are provided and must be used for the specific process.

(c) Hearing protection must be worn at all times on the shopfloor. This will also apply to office staff when in the factory.

(d) Smoking, including electronic cigarettes is totally prohibited in all working areas, storage areas, offices and company vehicles also include the operations of all forklift trucks both inside and outside the buildings; not only does smoking constitute a health risk but has severe fire implications. A formal warning will be issued if the “no smoking rules” are not complied with. Smoking is only permitted in designated smoking areas.

(e) Consumption of food in the workshop is prohibited between breaks and owing to the materials in use and oily environment, food must be consumed in the designated area in a sealed container for sweets/drinks etc. Hygiene procedures must be followed; hands should be washed thoroughly before and after visits to the toilet and before the consumption of food.

(f)  You are working in an environment that involves the movement and handling of sharp materials correct gloves must be worn as appropriate. Inevitably cuts may be sustained and it is your responsibility to ensure you have an anti-tetanus injection on a regular basis. If you have any doubt as to your cover check with your doctor.

Risk Assessments

Risk assessments are a legal requirement under the Management of Health & Safety Regulations (1999). Every eventuality must be assessed, and a risk rating or statement made.

Each job process will carry a risk rating. All employees have been made aware of the risks they are exposed to in the working day as the risk assessment is printed and kept in the departmental information points and also stored electronically on the company server.

Risk assessments are carried out for the sole purpose of protecting employees and ensuring that, in your normal working day, you are not exposed to excessive risk that you may be unaware of. Any task involving high risk must be reduced to the minimum amount possible and every reasonably practicable option must be used to protect yourself.

Further Advice and Administration

If you are in doubt about, or do not understand any of the above requirements or statements please   express your concerns in the first instance to your manager.

The Company Health & Safety Advisor will assist in any areas of concern with reference to hazardous substances used on site, machinery safety, personal protective equipment, and any other matters in relation to Health & Safety.

Detailed Safety Instructions

Machinery Safety

The machines that are used in the workplace all have their own inherent hazards. A risk assessment for each machine is stored in the departmental information points and must be read when using a machine that you are not familiar with.

Full training will be given before unsupervised operations can be carried out.

Eye Protection

1. In the interests of safety and to meet statutory requirements, eye protection must be worn for all manufacturing operations, where the risk assessment states.
2. Full face visors are available for grinding, painting degreasing, and using the saw. New visors can be replaced if damaged or scratched, however care must be observed when using this equipment; they must be hung up after use and not laid down on their visor. Safety glasses are provided to all machinists, for use when operating machine tools. If for medical reasons you already require glasses appropriate over goggles are provided and must be worn.
3. The company advises that you attend routine eye tests, to ensure optical health, however the company accepts no costs for such tests.

Failure to wear protective eye equipment for an operation designated above will lead to a formal recorded warning.

Skin Protection

Skin protection is very important in the engineering industry. Occupational Dermatitis is very common if certain procedures are not followed. Wear gloves to protect your hands and apply barrier cream before handling oily parts.

The company provides gloves for use when moving and handling materials in the workshop.

Hand wash is available in each of the toilet areas and should be used by way of squirting a marble sized amount onto the skin prior to wetting, work into the hands, rubbing hands together, and forming lather. Rinse off thoroughly and remove all residues.

It would also be advisable to apply a moisturising hand cream to replace the natural oils lost throughout the working day.

It is very dangerous to wear clothing that has been contaminated with hydraulic oils or cutting fluid and they must be changed at the earliest opportunity.

If you require further information on skin care in the engineering environment, please contact the Company Health & Safety Advisor. (Add Hyperlink)

Work Wear

You will be provided with work wear within one month of commencement of your employment. You will receive 2 pairs of trousers, 5 T-shirts, 2 sweatshirts and overalls if required for your specific job. You are expected to wear the workwear supplied to you when at work.

You will be supplied with safety footwear to the appropriate British Standard, and it is expected that boots will last a 12-month period.

Minor repairs on clothing and overalls will be your own responsibility. If clothing is beyond repair replacement must be requested via your manager. You must show the damaged clothing to your manager prior to replacement being issued.

On cessation of your employment with the Company work wear must be returned. Failure to return your work wear will result in appropriate deduction from your final wage packet.

Ear Defenders

Noise generated in some areas of the factory goes above the action level of 80db(A).

Ear defenders are provided and must be worn in all areas to remove the risk of irreparable damage to your hearing.

In-ear and over-ear type defenders are supplied dependant on the job being carried out so as not to interfere with any other PPE being worn such as a welding helmet.

Failure to wear ear protection on the shopfloor may result in disciplinary action.

The requirements to wear ear defenders set out above also apply to all office staff when entering the shopfloor.

Substances in the Workplace

In the workshop area we use cutting oils, grease, powders, paints, and other industrial and household chemicals. Material safety data sheets (MSDS) are held for all substances in use, which set out how the substances must be used also, what personal protective equipment is required and any other relevant Health & Safety requirements.

MSDS’s are held in departmental information points and if you are not already familiar with the requirements for a specific substance that you have been asked to use, you must refer to your Team Leader.

The data sheets also contain information on First Aid requirements should the substance come into contact with your skin or eyes or become ingested or inhaled.

Workshop Housekeeping

Workshop areas are to be kept as clear as possible and pallets and materials must not be placed on gangways, walkways and near exits. Consideration must be taken so as to not block access to fire exits, fire extinguishers, first aid kits, call points and any other safety related device.

Office areas are to be kept clean and tidy with pedestrian routes kept clear of obstructions and good cable management practiced. Desks and storage cabinets are to be kept clean and tidy.

Housekeeping is everybody’s responsibility; if liquid or oil is spilt on the floor it must be soaked up with absorbent pellets and removed, to reduce the risk of slips.

Team Leaders of each area has the responsibility to ensure that their own work area is kept to an agreed standard.

Steel must only be stored inside or covered fully if moving outside, for loading only, extremes in weather can seriously damage the steel, resulting in wastage of components or time spent cleaning and re-oiling materials.

Tools and equipment must be cleaned and returned or replaced at the end of each job or day, thus ensuring equipment remains in good condition.

NOTE – Good housekeeping is a requirement of the Health & Safety at Work Act 1974 and more recent legislation in the form of Management of Health & Safety Regulations 1999.

Failure to maintain good standards of housekeeping may result in disciplinary action.

Your privacy is very important to us at Greenfield Engineering. If you supply personal details to us through this website then you consent to our maintaining, recording, holding and using such personal data in accordance with our ‘Privacy Policy’. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate and disclose and make use of personal information.

The Following Outlines Our Privacy Policy.

Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.

We will collect and use of personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.

We will only retain personal information as long as necessary for the fulfilment of those purposes. We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.

Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.

We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

We will make readily available to customers information about our policies and practices relating to the management of personal information.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.

INTRODUCTION

Greenfield Engineering needs to gather and use certain information about individuals.

This can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards – and to comply with the law.

WHY THIS POLICY EXISTS

This data protection policy ensures Greenfield Engineering

• Complies with data protection law and follows good practice
• Protects the rights of staff, customers and suppliers
• Is open about how it stores and processes individuals data
• Protects itself from the risk of a data breach

DATA PROTECTION LAW

The Data Protection Act 1998 describes how organisations, such as Greenfield Engineering, must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data must:

• Be processed fairly and lawfully
• Be obtained only for specific, lawful purposes
• Be adequate, relevant and not excessive
• Be accurate and kept up to date
• Not be held for any longer than necessary
• Processed in accordance with the rights of data subjects
• Be protected in appropriate ways
• Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

PEOPLE, RISKS AND RESPONSIBILITIES

POLICY SCOPE

This policy applies to:

• Greenfield Engineering Neet Way Site
• Greenfield Engineering Waldon Way Site
• All Staff of Greenfield Engineering

It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:

• Names of individuals
• Postal addresses
• Email addresses
• Telephone Numbers (incl mobile no:)
• Dates of birth
• Next of kin details
• Payment information incl. Bank details
• ….plus any other information relating to individuals

DATA PROTECTION RISKS

This policy helps to protect Greenfield Engineering from some very real data security risks,

Including:

• Breaches of confidentiality. For instance, information being given out inappropriately.

• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.

• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

RESPONSIBILITIES

Everyone who works for or with Greenfield Engineering has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.

However, these people have key areas of responsibility:

• The board of directors is ultimately responsible for ensuring that Greenfield Engineering meets its legal obligations.

• The Data Protection Officer, Kerris Pass is responsible for:

• Keeping people updated about data protection responsibilities, risks and issues.

• Reviewing all data protection procedures and related policies.

• Arranging data protection training and advice for people covered by this policy.

• Handling data protection questions from staff and anyone covered by this policy.

• Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

• Maintain an ongoing commitment to reviewing systems, processes and procedures and updating if necessary to ensure data is stored and managed in a secure manner.

• The Material Planning & Operation Manager, Daniel Green, is overall responsible for:

• Ensuring all systems, services and equipment used for storing data meet acceptable security standards.

• Performing regular checks and scans to ensure security hardware and software is functioning properly.

• Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.

• Dealing with requests from individuals to see the data Greenfield Engineering holds about them (also ‘subject access requests’)

• Approving any data protection statements attached to communications such as emails and letters.

• Addressing any data protection queries from journalists or media outlets like newspaper and radio broadcasting companies.

• Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.

GENERAL STAFF GUIDLINES

• The only people able to access data covered by this policy should be those who need it for their work.

• Data should not be shared informally. When access to confidential information is required, employees can request it from their managers.

• Greenfield Engineering will provide training to all employees to help them understand their responsibilities when handling data.

• Employees should keep all data secure, by taking sensible precautions and following the guidelines below.

• In particular, strong passwords must be used and they should never be shared. Protocols have been placed to ensure passwords must be strong and changed regularly.

• Personal data should not be disclosed to unauthorised people, either within the company or externally.

• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.

• Employees should request help from their manager or the data protection officer if they are unsure about any aspect of data protection.

• A responsible and common sense based approach must be adopted by all staff to ensure data is handled in the correct manner on a day to day basis.

• Greenfield Engineering will securely hold all personnel data for an agreed period of time as requested by our insurers.

DATA STORAGE

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the Material Planning and Operations Manager.

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see or access it. When data is no longer required it must be shredded immediately and securely.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

• When not required, the paper or files should be securely stored.

• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer or desk.

• Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

• Data should be protected by strong passwords that are changed regularly and never shared between employees or unauthorised personnel.

• If data is stored on removable media (like a HDD or USB), these should be stored securely when not being used.

• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing service.

• Servers containing personal data should be sited in a secure location, away from general office space.

• Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.

• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.

• All servers and computers containing data should be protected by approved security software and a firewall.

DATA USE

Personal data is of no value to Greenfield Engineering unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.

• Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.

• Data must be transferred securely. The Material Planning and Operations Manager can explain how to send data to authorised external contacts.

• Personal data should never be transferred outside of the European Economic Area.

• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

DATA ACCURACY

The law requires Greenfield Engineering to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort Greenfield Engineering should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.

• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.

• Staff should take every opportunity to ensure data is updated. For instance, by confirming a supplier’s/customer’s details when purchase orders are received or raised.

• Greenfield Engineering will make it easy for data subjects to update the information Greenfield Engineering holds about them. For instance, via the company website.

• Data should be updated as inaccuracies are discovered. For instance, if an employee can no longer be reached on their stored telephone number, it should be removed from the database.

SUBJECT ACCESS REQUESTS

All individuals who are the subject of personal data held by Greenfield Engineering are entitled to:

• Ask what information the company holds about them and why.

• Ask how to gain access to it.

• Be informed how to keep it up to date.

• Be informed how the company is meeting its data protection obligations.

• Request for their personal data to be permanently deleted.

If an individual contacts the company requesting this information, this is called a subject access request. If an individual requests for the personal data to be permanently deleted this is known as right to erasure

‘Subject access requests’ and ‘right to erasure’ from individuals should be made by either email to kerris@greenfieldengineering.co.uk or via contact by phone or in person. ‘Subject Access request’ and ‘Right to Erasure’ forms are available on Greenfield Engineering’s intranet site and a hard copy will be supplied to any individual requesting this information.

In order to fulfil these requests and before handing over or permanently deleting any personal data, Greenfield Engineering will need to verify the identity of anyone making these requests by requesting original photographic identification and a completed form. Once completed these request forms will be stored in a secure location for 7 years before being destroyed.

In accordance with GDPR Legislation, there is no fee for this request, and the data controller will provide the relevant data within 31 days of the request being made.

DISCLOSING DATA FOR OTHER REASONS

In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without consent of the data subject.

Under these circumstances, Greenfield Engineering will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

PROVIDING INFORMATION

Greenfield Engineering aims to ensure that individuals are aware that their data is being processed, and that they understand:

• How the data is being used

• How to exercise their rights

To these ends, the company has a privacy policy, setting out how data relating to individuals is used by the company.

Introduction

The Company uses closed circuit television (CCTV) images to protect the Company’s property and to provide a safe and secure environment for employees and visitors to the Company’s business premises. This policy sets out the details of how the Company will collect, use and store CCTV images. For more information on privacy rights associated with the processing of personal data collected through CCTV images please refer to the Company privacy notice and data protection policy.

The Company’s CCTV facility, unless there are exceptional circumstances, will only record images. There is no audio recording i.e., conversations are not recorded on CCTV.

Purposes of CCTV

The Company has felt it is necessary and proportionate to install and use a CCTV system. The data collected from the system will assist in:

• The prevention and detection of crime and malpractice;
• Reporting criminal activity to the appropriate authorities.
• Protecting our property and business interests;
• Monitoring the security of our premises;
• Providing a safe and secure environment for those who work at or visit our premises;
• Ensuring compliance with health and safety rules and procedures;
• Identifying unauthorised activities and unsafe working practices;

Location of cameras

Cameras are located at strategic points throughout the Company’s business premises, principally at the entrance and exit points and building perimeters. The Company has positioned the cameras so that they only cover communal or public areas on the Company’s business premises and they have been sited so that they provide clear images. No camera focuses, or will focus on toilets, shower facilities, changing rooms, staff kitchen areas, staff break rooms or private offices.

All cameras are also clearly visible and the appropriate signs are prominently displayed so that employees, clients, customers and other visitors are aware they are entering an area covered by CCTV.

Any person(s) interfering or obstructing the cameras on purpose will be dealt with using our disciplinary policy.

Recording and retention of images

Images produced by the CCTV equipment are intended to be as clear as possible so that they are effective for the purposes set out above. Maintenance checks of the equipment are undertaken on a regular basis to ensure it is working properly and that the media is producing high quality images.

Images may be recorded in constant real-time 24 hours a day throughout the year.

As the recording system records digital images, any CCTV images that are held on the hard drive of a PC or server are deleted and overwritten on a recycling basis and, in any event, once the hard drive has reached the end of its use, it will be erased prior to disposal.

Images that are stored on, or transferred on to, removable media or which are stored digitally are erased or destroyed once the purpose of the recording is no longer relevant. In normal circumstances, this will be a period of 1 month.

However, where a law enforcement agency is investigating a crime, images may need to be retained for a longer period.

Access to and disclosure of images

Access to, and disclosure of images recorded on CCTV is restricted. This ensures that the rights of individuals are retained. Images can only be disclosed in accordance with the purposes for which they were originally collected.

The images that are filmed are recorded centrally and held in a secure location.

Access to recorded images is restricted to the operators of the CCTV system and to those line managers who are authorised to view them in accordance with the purposes of the system. Viewing of recorded images will take place in a restricted area to which other employees will not have access when viewing is occurring. If media on which images are recorded are removed for viewing purposes, this will be documented.

Disclosure of images to other third parties will only be made in accordance with the purposes for which the system is used and will be limited to:

• The police and other law enforcement agencies, where the images recorded could assist in the prevention or detection of a crime or the identification and prosecution of an offender or the identification of a victim or witness.
• Prosecution agencies, such as the Crown Prosecution Service.
• Relevant legal representatives.
• Line managers involved with Company disciplinaries.
• Individuals whose images have been recorded and retained (unless disclosure would prejudice the prevention or detection of crime or the apprehension or prosecution of offenders).

The Managing Director of the Company (or another senior director acting in their absence) is the only person who is permitted to authorise disclosure of images to external third parties such as law enforcement agencies.

All requests for disclosure and access to images will be documented, including the date of the disclosure, to whom the images have been provided and the reasons why they are required. If disclosure is denied, the reason will be recorded.

Individuals’ access rights

Under the UK’s data protection laws, including the General Data Protection Regulation (GDPR), individuals have the right on request to receive a copy of the personal data that the Company holds about them, including CCTV images if they are recognisable from the image.

If you wish to access any CCTV images relating to you, you must make a written request to a director of the company. The Company will usually not make a charge for such a request, but we may charge a reasonable fee if you make a request which is manifestly unfounded or excessive, or is repetitive. Your request must include the date, approximate time, the reason for the request when the images were recorded and the location of the particular CCTV camera, so that the images can be easily located and your identity can be established as the person in the images.

The Company will usually respond promptly and in any case within one month of receiving a request. However, where a request is complex or numerous the Company may extend this period further.

The Company will always check the identity of the employee making the request before processing it.

The senior management team will always determine whether disclosure of your images will reveal third party information, as you have no right to access CCTV images relating to other people. In this case, the images of third parties may need to be obscured if it would otherwise involve an unfair intrusion into their privacy.

If the Company is unable to comply with your request because access could prejudice the prevention or detection of crime or the apprehension or prosecution of offenders, you will be advised accordingly.

Staff training

The Company will ensure that all employees handling CCTV images or recordings are trained in the operation and administration of the CCTV system and on the impact of the laws regulating data protection and privacy with regard to that system.

Implementation

The Company’s senior management team is responsible for the implementation of and compliance with this policy and the operation of the CCTV system and they will conduct a regular review of the Company’s use and processing of CCTV images and ensure that at all times it remains compliant with the laws regulating data protection and privacy. Any complaints or enquiries about the operation of the Company’s CCTV system should be addressed a director of the company.

Data Protection

The Company will process the personal data collected in connection with the operation of the CCTV policy in accordance with its data protection policy and any internal privacy notices in force at the relevant time. Inappropriate access or disclosure of this data will constitute a data breach and should be reported immediately to a member of the Company’s senior management team in accordance with the Company’s data protection policy. Reported data breaches will be investigated and may lead to sanctions under the Company’s disciplinary procedure.