This policy is designed to explain how Fragola Matta Ltd (trading as Cafazzini and hereafter referred to as 'we', 'us' or 'our') processes personal data relating the use of CCTV equipment. Our company information is as follows:

Purpose and Lawful Basis of Collecting Data
We operate CCTV at our premises for the purposes of maintaining the security of property and premises and for preventing and investigating crime. CCTV footage may also be used in the defence of a claim made against us or to monitor staff during the performance of their tasks, including being used as evidence in disciplinary matters or for assessing health and safety concerns.

These processing activities are undertaken in the legitimate interest of Fragola Matta Ltd. To this end, we have conducted all necessary Legitimate Interest Assessments and Data Protection Impact Assessments to ensure that any processing is necessary and proportionate to achieve our identified purposes.

Types of Personal Data
CCTV devices capture visual images of persons in or around our buildings and facilities. In addition to this, audio recording is also in operation where stated in the associated signage located at points CCTV recording is in effect.

Processing of Personal Data
Fragola Matta is the legal entity who initiated the processing of personal data and who determines the objective of this processing activity. The Managing Director is responsible for the CCTV systems operation.
The images can be accessed by a small number of trained employees. Access to the hard-disc recorder is highly limited, password protected and recording any log or action undertaken. The data cannot be accessed without the authorisation of the Managing Director.

Source of Personal Data
This personal data is collected through the CCTV cameras operated by the Fragola Matta – no information is collected from publicly available sources.

Recipients of Personal Data and Transfers to Third Parties
This data will only be processed by the Fragola Matta for this purpose however copies of video images may be backed up using a secure CCTV backup provider, utilising AWS data centres in Ireland. This provider, and AWS, shall be acting as a Data Processor for the purpose of storing data.
In certain circumstances we may be required to disclose CCTV images to certain authorities, such as the police following a valid disclosure request.
CCTV Privacy Notice

Retention Periods
We process CCTV footage for a maximum of 180 days after the date of capture, although we may process footage for a longer period, for example if the footage is relevant to an investigation.

Your Data Protection Rights
Under the UK GDPR, you have the following rights:

Right of access - You have the right to ask us for copies of your personal data, including information about how your data is processed.

Right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. We may need to verify the accuracy of the new information you provide to us.

Right to erasure - You have the right to ask us to erase your personal information. Please note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances. This enables you to ask us to suspend the processing of your personal information, for example in situations where you wish to establish the accuracy of the data we hold, where you do not wish data to be erased or where you have objected to processing and we have yet to establish whether we have an overriding legitimate interest to use this data.

Right to object to processing - You have the right to object to the processing of your personal information in certain circumstances. This includes where we rely on legitimate interest as a lawful basis. You also have the right to object where we're processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. Please note that this right is not applicable to personal data processed under the lawful basis of legitimate interest – this includes our processing of CCTV images or related audio data.

You are not required to pay any charge for exercising your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may require additional information or clarification to facilitate certain requests, for example where there is a need to confirm your identity. In these cases we will contact you without undue delay in order to gather any additional information we need.

If you make a request, we have one month to respond to you. We try to respond to all legitimate requests within this timeframe, however, it may occasionally it take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you wish to make a request under one of the rights highlighted above, or have questions about how your data is processed, please contact us at info@fragolamatta.com or by writing to us at:

Fragola Matta Ltd Mellish Industrial Estate
Unit 2B - 2D Harrington Way
London
SE18 5NR

Profiling and Automated Decision Making
Under the UK GDPR, you have specific rights relating to profiling of individuals and regarding any automated decision making, including the right to have human intervention and to challenge any automated decisions made.

We do not process data gather by, or related to, CCTV or the above processing activities in such a way as to profile individuals or make automated decisions relating to them.

How to Complain
If you have any concerns about our use of your personal information, you can make a complaint to us at info@fragolamatta.com or by writing to us at:

Fragola Matta Ltd Mellish Industrial Estate
Unit 2B - 2D Harrington Way
London
SE18 5NR

You can also complain to the ICO if you are unhappy with how we have used your data. You can contact them on the below:
Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

Further Information

Please note that we may have to amend this Notice on occasion, for example if we change our systems or a change to our internal processes requires us to provide updated information. If we do that, we will publish the amended version. In that situation we will endeavour to alert you to the change, but it's also your responsibility to check regularly to determine whether this Notice has changed.

You can ask us for a copy of this Notice by writing to the above address or by emailing us at info@fragolamatta.com