Privacy notice - closed-circuit television (CCTV) at London office

CCTV is in used within the College building for crime prevention and safety purposes. The recordings capture video footage of individuals inside the building. The following explains how RCPCH captures and uses this information and the way we protect your privacy.

Our contact details

Please contact RCPCH if you wish to make a request or if you have a general enquiry.

Name: Royal College of Paediatrics and Child Health (RCPCH)
Address: 5-11 Theobalds Road, London, WC1X 8SH
Phone: number +44 (0)20 7092 6000
Email: Data Protection Officer (for privacy/data protection enquiries only): information.governance@rcpch.ac.uk

General enquiries can be sent via our contact form or contact the relevant team directly.

Our EEA representative

If you are located in the EEA or EU, you can contact DataRep if you wish to make a request under EU GDPR.

As we sometimes process personal data of individuals in the EU and EEA area, in either the role of ‘data controller’ or ‘data processor’, we have appointed DataRep as our Data Protection Representative in the European Union for the purposes of EU GDPR so that you can contact them directly in your home country. 

If we have processed or are processing your personal data and you are located outside of the UK, you may be entitled to exercise your rights under EU GDPR in respect of that personal data. For more details on your rights in the EU, please refer to the European Commission or the national Data Protection Authority in your country.

If you want to raise a question to RCPCH, or otherwise exercise your rights in respect of your personal data, you may do so by:

When mailing inquiries, it is essential that you mark your letters for ‘DataRep’ and not ‘RCPCH’, or your inquiry will not reach them. Please refer clearly to RCPCH in your correspondence. On receiving your correspondent, RCPCH is likely to request evidence of your identity, to ensure your personal data and information connected with it is not provided to anyone other than you.

Please note this is for GDPR/privacy queries only. If you have a general enquiry, please use the contact details above.

If you have any concerns over how DataRep will handle the personal data they will require to undertake for their services, please refer to their privacy notice.

What information do we collect about you?

Closed-circuit television (CCTV) is in used within the College building for crime prevention and staff safety purposes. The system does not use facial recognition and no audio is collected, only moving images. 

The recordings capture video footage of individuals inside the building which is defined as personal data (any information about a living individual which allows them to be identified) under UK data protection legislation. 

Why do we collect this information?

Data protection law requires that we have one or more of the following lawful bases to process your information:

  • “Consent” – we may ask for your consent to process your personal data. You can withdraw consent at any time. 
  • "Contractual Obligation” – where we need to process your personal data either to take steps to enter into a contract with you or to fulfil a contract we already have with you. 
  • “Legal Obligation” – where we are required to process your personal data by law or to fulfil a statutory obligation.
  • “Vital Interest” – where the processing is necessary to protect someone’s life. 
  • “Public Task” – where the processing is necessary for us to perform a task in the public interest, and it has a clear basis in law. 
  • “Legitimate Interest” – where we have assessed that the benefits of us processing your data are legitimate and not outweighed by your interests or legal rights. 

We collect and process your personal data for the following purposes: 

  • To ensure the RCPCH meets the requirement of addressing staff safety and crime prevention in the legitimate interest of the College (UK GDPR Article 6(f)) 
  • In some circumstances, the processing is necessary in the vital interest of an individual (UK GDPR Article 6(d)). 

Where special category data is processed, such as physical and/or mental health conditions and ethnicity captured on the image, we process as necessary for the substantial public interest for the prevention or detection of an unlawful act where there is a substantial public interest (to prevent further criminal acts) under Article 9(2)(g) of the UK GDPR and Schedule 1, Part 2 (10) of the Data Protection Act 2018. 

We do not use your personal data to make automated decisions or undertake profiling about you.

Who might we share your information with?

We put security measures in place to ensure that your information is securely stored. CCTV is used in line with the College’s Physical Security Policy, current UK data protection legislation and the ICO’s Code of Practice for surveillance cameras and personal information. Your personal data will not be transferred outside of the UK.

Access to the data is restricted to authorised members of RCPCH staff, although footage may be shared when required by other bodies, such as the police or emergency services, in line with our third party disclosure procedure to other bodies. Any footage extracted from the system will be restricted as appropriate, shortened to only the relevant section and either exported as footage or printed as specific stills.

How long do we hold your information for?

We will retain CCTV recordings for up to 70 days before it is automatically overwritten in line with our retention schedule, unless we need to retain them for law enforcement purposes or another legal obligation. The retention will depend on the purpose for which it is being retained and will be extracted and stored separately in a restricted area, and deleted when no longer required.

Your rights

You have the following rights in relation to your data:

  • Ask us for a copy of the information that we hold about you (right of access)
  • Change any factual errors or inaccuracies (right of rectification
  • Delete your personal data (called a right to erasure) where we have no overriding reason to retain the footage  
  • Restrict the use of your data (right of restriction). However, this only applies to certain circumstances
  • Object to processing (right to objection). You can ask that we stop using data that is not necessary for fulfilling our legal obligations

Please contact the RCPCH Data Protection Officer if you wish to make a request, contact details are at the top of this privacy notice.

If you are located in the EU/EEA, wish to make a request, you can contact our EEA Representative, contact details are available to download below.

If you make a request, we have one month to respond to you.

How to contact us or complain

If you are unhappy with how we are using your personal data, you should contact us in the first instance so that we can understand and try to resolve your concern. If we can't resolve the issue you have the right to complain to the Information Commissioners Office (ICO). The ICO is the UK's independent body set up to uphold information rights. 

The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

ICO helpline number: 0303 123 1113

ICO website

If you have any questions about our privacy policy, the information we hold about you or you wish to make a complaint, please send an email to: information.governance@rcpch.ac.uk 

Changes to this privacy notice

We keep our privacy policy under review, and we will place any updates on this web page. This privacy policy was last updated on 24 March 2021.