Alliance Law Firm (the “Firm” “We” “Our”) operates a circuit television system (CCTV System) within its premises. This policy details the purpose, use and management of the CCTV system within the premises. This policy applies to all CCTV systems operational within the premises of the firm. The firm will observe the provisions of the Nigeria Data Protection Regulation 2019 and other relevant laws including Freedom of Information Act 2011 in its operation of system.
The firm has CCTV systems installed at the entrance of the firm, the reception, the conference room, within the corridors of the firm but not in the offices where employees stay. The CCTV is operational for 24hours a day, every day of the year. The cameras are monitored in the IT room which is secure and not accessed by unauthorized persons. The whole operation of the CCTV is in accordance with the Nigeria Data Protection Regulation 2019.
PURPOSE OF THE CCTV
The CCTV are installed for the following reasons:
- For crime prevention, detection and investigation.
- To ensure safety of employees and other staff
- To ensure security and protection of clients’ personal information and firm’s property.
The installed CCTV will monitor the firm’s premises and identify incidents that will require attention and response. This surveillance will be undertaken in a manner that will respect the fundamental rights and freedom of individuals.
Our lawful justification for deploying these CCTV is our legitimate interest to protect our employees, staff, services, premises and client information. We have assessed our legitimate interest and have arrived at the conclusion that there is balance of interest in the processing activities.
We only keep CCTV images for a specified period of time. Except where required for evidential purpose, investigation of offence or by law to be kept for longer period, we will only retain the CCTV image no longer than 3 months from the date of recording. The images will be overwritten after this period. Images held in excess of the retention period will be reviewed occasionally to determine the necessity and proportionality of retaining them. Access to CCTV image is restricted to only authorized persons.
DISCLOSURE OF CCTV IMAGES TO THIRD PERSON
We may disclosure the CCTV footage to a third in the following limited circumstances such where disclosure is required by law for the purpose of preventing or detecting crime, where sought as evidence by investigating officer in relation to a crime committed in our premises.
We have put implemented adequate technical and organizational measures to prevent any unauthorized access, disclosure, alteration, accidental losses or destruction of the CCTV footage. These includes putting in place a password activated door to where the CCTV system resides, encrypting the storing and transmission of the footage, using password protection to limit access to the CCTV footage and conducting regular audit.
RIGHTS OF ACCESS
An individual has right to access the CCTV Footage about themselves and to be provided with a copy of it. In exercising this right an individual must provide sufficient information to ascertain his/her identity and to enable us locate the exact footage. Provided that this request is made within the retention period stated above. We may not be able to fulfil this obligation if the CCTV footage has been deleted after the expiration of 3 months. This right may be exercised by contacting us @ email@example.com or send a letter to our physical office @ Alliance House, 71 Ademola Street, South-West Ikoyi, Lagos State, Nigeria.
All complaint concerning the use of CCTV or its disclosure should be made @ firstname.lastname@example.org or send a letter to our physical office @ Alliance House, 71 Ademola Street, South-West Ikoyi, Lagos State, Nigeria.
This policy will be updated occasionally to comply with relevant provisions of law and to accommodate new development in the use of our CCTV.