CCTV & Privacy Policy

Effective date: 01/01/2018
Last updated: 31/03/2026

1. Who We Are

This CCTV & Privacy Policy explains how A & E Property LTD ("we", "us", "our") uses CCTV systems at properties we own and/or manage.

Data Controller:
A & E Property LTD

Registered Address:
33 Lower Croft,
Swanley,
Kent,
BR8 8BA

Email: info@ae-propertyltd.co.uk
Phone: 01634 907 011

2. Purpose of Our CCTV System

We operate CCTV in certain shared communal areas only at some of our managed properties.

The purposes of our CCTV system are to:

• help protect the safety and security of tenants, visitors, contractors and staff;
• help prevent and detect anti-social behaviour, nuisance, damage and misuse of communal facilities;
• help identify issues relating to the management of communal areas, including bin misuse, waste disposal, spillages, sink misuse, blockages, leaks, damage or similar reported problems; and
• support the investigation of incidents when a complaint or report is made.

CCTV is not actively monitored live on a routine basis. Footage is generally only accessed where an issue, complaint, incident, report or concern has been raised and there is a legitimate reason to review it.

3. Where CCTV Is Used

CCTV is limited to communal/shared areas only, which may include:

• entrances and exits;
• shared hallways and corridors;
• shared kitchens and lounges;
• external communal access areas; and
• bin storage or waste disposal areas.

We do not use CCTV in areas where individuals would expect a high level of privacy, such as:

• bedrooms;
• bathrooms or toilets; and
• any private living space intended for the sole use of an individual tenant.

4. Lawful Basis for Processing

Our lawful basis for processing personal data through CCTV is generally legitimate interests, namely the legitimate interests of protecting property, supporting the safe and effective management of communal areas, investigating reported issues, and protecting the interests of tenants, visitors and the business.

5. What We Record

Our CCTV system may capture:

• video images of individuals entering, leaving or using communal areas;
• date and time stamps; and
• activity taking place in those communal areas.

Unless specifically stated otherwise, our system is intended to record video footage only and not audio.

6. How Footage Is Used

Footage may be reviewed where necessary for reasons including:

• investigating tenant or neighbour complaints;
• checking reports of damage, misuse, obstruction, leaks, waste issues or health and safety concerns in communal areas;
• investigating suspected anti-social behaviour or breaches affecting shared areas; and
• assisting with insurance claims, legal claims or law enforcement enquiries where appropriate.

Footage will only be accessed by authorised persons where there is a genuine business, safety or legal reason to do so.

7. Retention of CCTV Footage

CCTV footage is retained for a maximum period of 6 months, after which it is automatically deleted or overwritten, unless we are required to keep it for longer in connection with:

• an ongoing complaint or investigation;
• a legal claim or anticipated legal proceedings;
• an insurance matter; or
• a request from the police, local authority, court, regulator or other lawful authority.

We may retain relevant footage for longer than 6 months where it has been isolated for one of the reasons above and continued retention is necessary and proportionate.

8. Who Footage May Be Shared With

We may share CCTV footage, where lawful and necessary, with:

• the police or other law enforcement agencies;
• local authorities or regulatory bodies;
• insurers, legal advisers or courts;
• contractors or professional advisers involved in investigating an incident; and
• other third parties where disclosure is required or permitted by law.

We do not sell CCTV footage or use it for marketing purposes.

9. Security of Footage

We take reasonable technical and organisational measures to keep CCTV footage secure and to prevent unauthorised access, misuse, loss, alteration or disclosure.

Access is restricted to authorised personnel only and only where there is a legitimate need to review the footage.

10. Signage

Clear signage is displayed at relevant properties to let individuals know that CCTV is in operation, why it is being used and how to contact us for further information.

11. Your Data Protection Rights

Where applicable, individuals whose personal data is captured by our CCTV system may have rights under UK data protection law, including:

• the right to be informed;
• the right to request access to their personal data;
• the right to request correction of inaccurate personal data;
• the right to request erasure in certain circumstances;
• the right to object to processing in certain circumstances; and
• the right to complain.

Requests can be made by contacting us using the details above.

Please note that where footage contains images of other individuals, we may need to redact or limit disclosure, or in some cases we may be unable to provide copies where exemptions apply.

12. Complaints

If you have any concerns about how we use CCTV or your personal data, please contact us first:

A & E Property LTD
33 Lower Croft,
Swanley,
Kent,
BR8 8BA

Email: info@ae-propertyltd.co.uk
Phone: 01634 907 011

If you remain unhappy with how we have handled your concern, you have the right to make a complaint to the Information Commissioner’s Office (ICO).

ICO Website: https://ico.org.uk/make-a-complaint/

13. Changes to This Policy

We may update this policy from time to time. The latest version will always be available on our website.