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provider should be aware of this requirement, and should be able to provide assurances in this regard, but again, it is vital to have someone dealing with this who you know understands the issues, and can say with some con dence that they are able to con rm to you that this requirement has been met. If you do not have anyone internally, then you should consider appointing an external expert to assist.
WHAT ABOUT CCTV?
If you are considering installing CCTV at any premises, you need to have rst carried out a privacy impact assessment, which looks at the potential intrusion to the privacy to individuals in having the system, and the potential bene ts. You must conclude that the bene ts outweigh the potential drawbacks before you can make a decision to install CCTV.
Once up and running you need to ensure that you have plenty of signage in place to alert individuals to the fact that you are using CCTV. You should also have a policy in place that governs how the system operates – including who has access to the images.
DOES THIS MEAN WE CANNOT KEEP ARCHIVE RECORDS?
There is a distinction between operational records and historical records. Both are important for different reasons. In an ideal world you would keep all of your records as they are potentially of historical signi cance for the future, but this is not always possible for practical and legal reasons. The key issue
is whether the records contain any personal data. If they do, the fth data protection principle provides that the data should “not be kept for longer than is necessary for” the purpose for which the data was collected in the rst
place. Therefore, once the data is no longer necessary it should, in principle, be deleted. You should therefore review operational records on a regular basis and, when they are no longer needed, should be deleted. It is advisable to have a clear document retention policy that sets out how long certain types of records should be kept. For example, accounting records should be kept for at least seven years, whereas the notes of an interview with an individual you have not employed, probably do not need to be kept for longer than six months.
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