Closed circuit television (“CCTV”) is installed at Harrigan’s Bar & Grill.

Recognisable images/footage captured by CCTV are Personal Data and are subject to the provisions of the General Data Protection Regulation (EU 2016/679) and the Data Protection Act 2018. Vicar Catering Company (the “Company“) is the data controller of images/footage of individuals captured by way of CCTV.

The purpose of this Policy is to comply with the Company’s obligations under data protection law and ensure that all employees, customers and any other visitors to the premises are aware of the location and purpose of security cameras.

1. PURPOSE AND LAWFUL BASIS OF CCTV
   • CCTV is installed at all relevant locations for the purpose of:
     • Enhancing the security of the premises, and property;
     • Promoting and protecting the health and safety of staff and customers;
     • Deterring and detecting criminal activity and anti-social behaviour;
     • Investigating accidents or dangerous occurrences and to assist in the resolution of incidents and the establishment or defence of claims against the Company;
     • enabling the investigation of suspicious activity, both inside and outside of our premises, including any issues that give rise to, or arise during the course of, disciplinary or grievance processes and/or investigations into criminal or potentially criminal matters by An Garda Síochána; and
     • To assist in investigating complaints, allegations, accidents, health, safety, and security incidents including use in any staff disciplinary processes;
     • Assisting in identifying, apprehending and prosecuting offenders.
   • Under Data Protection law, the processing of Personal Data requires a lawful basis. The lawful bases for the Company’s use of CCTV is as follows:
     • The processing of Personal Data by way of CCTV is necessary for the Company to comply with its legal obligations under the Occupiers’ Liability Act, 1995 and under Sections 8 and 12 of the Safety, Health and Welfare at Work Act 2005.
     • The processing of Personal Data by way of CCTV is necessary for the purposes of the Company’s legitimate interests as well as the legitimate interests of staff and customers. Specifically, these legitimate interests include:
       • The Company’s legitimate interests in protecting and promoting the health and safety of staff and customers;
       • The Company’s legitimate interests in protecting the Company’s buildings and other assets, both during and after hours;
       • The Company’s legitimate interests in investigation suspicious activity, both inside and outside of our premises, including any issues that give rise to, or arise during the course of, disciplinary or grievance processes and/or investigations into criminal or potentially criminal matters by An Garda Síochána; and
       • The Company’s legitimate interests in ensuring fair outcomes in the context of an employee disciplinary process; and
       • The Company’s legitimate interests in ensuring that the interests of the Company are adequately protected in the event of workplace accidents or other incidents.
       • The Company’s legitimate interests in establishing or defending legal claims.
       • The legitimate interests of staff and customers in being safe while on the premises.
     • CCTV will not be deployed in a manner that infringes employees’ rights to privacy in the workplace. Live feeds from CCTV cameras will only be monitored where this is reasonably necessary to achieve the purposes set out above. Otherwise, recorded images may be spot checked or accessed where necessary to achieve these purposes.

2. Storage and Retention
   • As data controller we will retain recorded data for a period of no more than 30 days on a rolling basis, except in the event of an incident where it may be deemed necessary for the Company to retain it for a longer period.
3. Location of CCTV cameras:

 

• CCTV are installed in common areas to the interior and exterior of these premises. Signage is in place at each location at which CCTV is sited to indicate that CCTV is in operation.

4. THIRD PARTY ACCESS
   • In certain circumstances, CCTV footage may be disclosed to:
   • An Garda Síochána where the Company are required by law to make a report regarding the commission of a suspected crime;
   • An Garda Síochána on foot of a request when a crime or suspected crime has taken place and/or when it is suspected that illegal/anti-social behaviour is taking place on Company property;
   • To the Company’s insurance company (and their legal advisors) where the insurance company requires same in order to pursue or defend a claim; and/or
   • To any other third party where the Company has a legal obligation to do so.
   • Third Party Security Companies where necessary
5. YOUR RIGHTS:
   • Subject Access Requests
     • Any person whose image has been recorded on a CCTV has a right to be given a copy of the information recorded which relates to them, subject to certain exceptions. To exercise your right of access, applications should be made in writing to the Company by contacting info@harrigans.ie or you can make a postal request in writing to:

Madison Hospitality ltd:

Lower Main Street,

Newbridge.

Co Kildare.

• Please provide all the necessary information to assist us in locating the recorded CCTV images, such as the date, time and location of the recording.
• In giving a person a copy of their Personal Data, other people’s images will be obscured before the data is released.

• Right to erasure of Personal Data
  • You have the right to request that your Personal Data be deleted or removed from our systems and records. However, this right only applies in certain circumstances and there may be circumstances in which we are entitled or obliged not to comply with your request.
• Right to object to processing of Personal Data
  • You have the right to object to our use of your Personal Data in certain circumstances.
• Right to complain to the relevant data protection authority
  • If you think that we have processed your Personal Data in a manner that is not in accordance with data protection law, please contact us.
  • If you are not satisfied with the response you receive from us in relation to your request, then you are entitled to make a complaint to the Data Protection Commission who may investigate the matter for you. The Data Protection Commission’s website is dataprotection.ie or you can contact their office by email at info@dataprotection.ie or by post to Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28.

For further information regarding your rights to personal data and GDPR guidelines, please visit: www.dataprotection.ie/en/individuals