CCTV Policy
Reference: GCPOL003 Version: v1.0.0 Date: 19/09/2026
Data controller: Greenham Control Tower Ltd (GCTL), ICO registration ZA861884
Contact: privacy@greenhamtower.org.uk · 01635 44145 · Greenham Control Tower, Burys Bank Road, Thatcham RG19 8BZ
1. Why we operate CCTV
CCTV operates at Greenham Control Tower for the prevention and detection of crime, the safety of visitors, volunteers and staff, the protection of a Grade II listed building and its exhibits, including objects on loan, and the protection of staff and volunteers against unfounded allegations.
Greenham Control Tower Ltd operates the system as sole data controller. Our lawful basis is legitimate interests. Greenham Control Tower Trading Ltd, which runs the café, is not a controller of the system; a request from it for footage is handled as a disclosure under section 7.
Where footage is examined because an offence is suspected, we rely on the condition for preventing or detecting unlawful acts in Schedule 1 to the Data Protection Act 2018. The Appropriate Policy Document that this condition requires was adopted by the Board on 3 September 2026 and is available on request.
2. What the system does, and does not do
Cameras record when they detect motion. One camera on the tower turns automatically to follow movement near the building; it records in the same way as the fixed cameras. There is no continuous recording and no live monitoring service – the cameras are not watched by anybody in real time.
No sound is recorded. Facial recognition is disabled and will remain disabled.
The café camera faces the servery, so the till is in view: protecting cash, and the people handling it, is among the reasons it is there. It is positioned so that a PIN entered at the card reader cannot be read from the recording, and that is checked when the system is commissioned and again if the till or the card reader moves.
Cameras cover the outside of the building, its approaches, the adjacent car park, and a small number of internal areas including the café servery, the hallways, one exhibition room, the electrical room and the control room.
There are no cameras in the toilets, the volunteer rest area, the kitchen, or anywhere else where privacy is reasonably expected.
3. Number plate reading
Four cameras – those covering the east entrance, the oil tank compound, and the curtilage and car park from the tower – read vehicle number plates. The north entrance is for people on foot and its camera does not read plates.
Number plates are recorded, not matched against any list; no watchlists are operated. A search of stored number plates is made only in connection with an identified incident. Number plate data is kept and deleted with the footage it belongs to.
4. The café screen
One camera on the tower relays a live view of the top-floor outlook to a screen in the café, so that visitors who cannot use the stairs can experience the view. The building’s listed status rules out a lift, and this feed is the practical alternative.
The screen shows wide views in which nobody is identifiable, and no view in which a person is identifiable is ever displayed.
5. How long recordings are kept
Recordings are kept for ninety days and then deleted automatically.
Footage relating to a specific incident may be exported and kept for as long as the incident requires; every export is logged with the date, the reason and who authorised it.
6. Who can view recordings, and when
Access is limited to a short list of people authorised by role, held by the Data Protection Lead. Every account uses multi-factor authentication, and the system logs every access. Recordings are never played back in public areas.
The list holds two kinds of account. Authorised viewers may watch and archive recordings. Administrators may do the same and may also change how the system is set up.
Three people hold accounts: the Data Protection Lead and the lead of our IT group, as administrators, and the Chair, as an authorised viewer. The list is reviewed once a year. The Community Heritage Venue Manager and the operational team do not hold accounts; they report incidents, and examination follows the route below.
Examining footage is authorised by the Data Protection Lead, or by the Chair where the Lead is connected to the matter, and the authorisation is logged with the reason for it.
The recorder is kept on a network separated from the general site network. Recordings can be viewed away from the building, through the manufacturer’s encrypted remote access service, using the same accounts and the same logging as on site. The recordings themselves stay on the recorder at the Tower.
Footage is examined only to investigate an incident, answer a subject access request, meet a lawful disclosure request, or check the system is working. It is never browsed routinely, and it is never used to monitor anyone’s performance, productivity, timekeeping or working patterns.
Where there are reasonable grounds to suspect a specific incident of crime, dishonesty or serious misconduct, footage of the relevant time and place may be examined on that authorisation – including where it clears the person concerned. Anyone whose footage is relied on in a disciplinary or grievance process is told and given the opportunity to view it.
7. Sharing footage
Footage may be disclosed to the police or to our insurers where the law allows or requires it. Every disclosure is logged.
8. Your rights
You have the right to ask for the footage we hold of you. Requests go to the Data Protection Lead at privacy@greenhamtower.org.uk, or by post to the address above, and are answered within the statutory period of one calendar month; other people visible in the footage are masked where showing them would be unfair.
You also have rights to object to the processing and to ask for erasure, which are considered case by case. Full details of your rights are on the Information Commissioner’s website at https://ico.org.uk. GOV.UK also explains how to request CCTV footage of yourself: https://www.gov.uk/request-cctv-footage-of-yourself.
9. Complaints
If you have a concern about the CCTV system or how footage has been used, write to the Data Protection Lead at privacy@greenhamtower.org.uk, or to the address above. We will acknowledge your complaint within thirty days and respond without undue delay.
If you remain unhappy, you can complain to the Information Commissioner’s Office: https://ico.org.uk/make-a-complaint, helpline 0303 123 1113.
10. Temporary deployments
Cameras may be temporarily positioned to protect a particular exhibition or object on loan. Any such deployment follows this policy in full, is signed at the room it covers, and ends when the need does.
11. The car park
The car park beside the Tower is operated by BBOWT and falls within our coverage, including number plate reading. Before recording begins, we notify BBOWT in writing and arrange signage at the car park naming us as the operator.
12. Signage
Signs at the entrances, inside the building, at any room covered by a temporary deployment (section 10), and at the car park state that CCTV is in operation, that number plates are read, who operates the system, and how to contact us.
13. Responsibility and review
The Board of Trustees adopts this policy and the Data Protection Impact Assessment behind it, and approves any change to what they require. Day-to-day responsibility sits with the Data Protection Lead, who reviews both annually and whenever the system changes, and who may make changes that bring this policy into line with the assessment the Board has already approved.
14. Definitions
Data Protection Lead – the trustee appointed by the Board to be responsible for data protection across Greenham Control Tower Ltd and Greenham Control Tower Trading Ltd, and the person to contact about this policy (sections 8 and 9).
Data controller – the organisation legally responsible for deciding why and how personal data is used. For this CCTV system, that is Greenham Control Tower Ltd alone.
Personal data – information about a living person who can be identified from it. CCTV footage is personal data where the people in it can be recognised.
Legitimate interests – the lawful basis in UK data protection law that allows an organisation to use personal data where it has a real need, the use is proportionate, and people’s rights are respected. Our assessment of that balance is in the Data Protection Impact Assessment.
Facial recognition – technology that matches faces against stored faces to establish who someone is. It is different from simply detecting that a person is present. Facial recognition is disabled on our system.
Number plate reading – the reading of vehicle number plates from the camera image so that a plate can be found in stored footage. Plates are read and kept with the footage, deleted with it, and never matched against any list.
Subject access request – the legal right to ask for a copy of the personal data an organisation holds about you, including CCTV footage of you (section 8).
| Adopted by the Board of Greenham Control Tower Ltd | 19/09/2026 |