COMPANY POLICY REGARDING CCTV CAMERAS
ON BUS TRAVEL NZ LIMITED BUSES, PREMISES AND WORK LOCATIONS
1 INTRODUCTION
The Purpose of the Bus Travel NZ Limited CCTV Policy (Policy) is to explain the manner in which Bus Travel NZ Limited’s CCTV systems are used in Bus Travel NZ Limited’s buses, and in its workplaces and operating premises, including the manner in which information obtained via CCTV is obtained, used, and stored.
Bus Travel NZ Limited is committed to implementing and using our CCTV systems in a way that does not breach any individual’s privacy rights and recognises our obligations as an agency to observe the privacy principles of the Privacy Act 1993.
2 BACKGROUND
Bus Travel NZ Limited operates services within the Auckland Airport precinct, including but not limited to its surrounding suburbs (e.g. Mangere).
It is an operational requirement of Bus Travel NZ Limited that all buses, the company’s operating premises encompassing the depot in spaces shared by multiple tenants, the entire fleet parking area, and the company-allocated staff room at Auckland Airport Park & Ride car park are equipped with fully functioning cameras to enhance the safety of our drivers and vehicles and for further situations as listed below.
3 SCOPE
This Policy is authorised by Bus Travel NZ Limited and is applicable to all Bus Travel NZ Limited employees, contractors and members of the public who are present of the locations listed in this Policy, regardless of the purpose.
Where this Policy refers to CCTV systems or cameras the Policy is referring solely to CCTV systems or cameras operating in Bus Travel NZ Limited’s:
- Buses;
- The following locations at the operating premises at 21 Brigade Road, Airport Oaks, Mangere:
- Entire fleet parking area
- In spaces shared by multiple tenants
- Company-allocated staff room at Auckland Airport Park & Ride car park
- The depot
This Policy does not apply to covert CCTV cameras, which may be used, when required, in accordance with the Privacy Act 1993.
4 PURPOSE
CCTV monitoring and access to the CCTV footage is permitted for the purpose of:
- Allowing a government department, body, or law enforcement agency (in relation to security matters) to investigate a security issue;
- Investigating a motor vehicle accident to ascertain the party at fault and the circumstances around the accident;
- Investigating a complaint for tampering of or theft of a vehicle/otherproperty;
- Investigating a complaint of a crime;
- Investigating a complaint from a passenger or member of the public;
- Investigating an injury complaint, incident, accident or near miss such as rear door entrapment or a passenger falling over whilst the bus is moving;
- Meeting our operational requirements (such as our contractual obligations to third parties);
- Observing and assisting in driver training where necessary;
- Assisting in any disciplinary processes involving a Bus Travel NZ Limited employee;
- Ensuring compliance with Bus Travel NZ Limited’s health and safety obligations; and
- Such purposes as provided for in the Privacy Act 1993.
5 EQUIPMENT
Bus Travel NZ Limited uses the following equipment for our CCTV system:
- Installation of CCTV cameras to capture the images and audio inside and outside the buses, at the company’s depot, operating premises, fleet parking area, in spaces shared by multiple tenants, and the company-allocated staff room at Auckland Airport Park & Ride car park.
- Software on a safe computer in Bus Travel NZ Limited’s office that is able to download the CCTV footage from the buses or fixed cameras for the purposes contained in this Policy. The safe computer is password protected. Only approved Bus Travel NZ Limited employees know the password.
6 INSTALLATION AND CONFIGURATION
The installation of all CCTV system components must be approved by Brent Early (Managing Director) or Jacki Landon Lane (Human Resources Manager)
- Cameras may have pan, tilt and zoom functions.
- CCTV cameras will be installed and positioned Bus Travel NZ Limited in locations which align with the purposes outlined in this Policy.
- CCTV cameras must be located and programmed to avoid capturing images in locations where there would be a reasonable expectation of privacy.
- The CCTV system described in this Policy shall be connected to a secure private network which may only be accessed by authorised persons.
- No part of the CCTV system shall be connected to the public internet.
7 STAFF MEMBER RESPONSIBLE FOR CCTV
The General Manager for the Scheduled Services of Bus Travel NZ Limited is responsible for the CCTV system and is authorised to oversee the use of CCTV monitoring for safety and security purposes.
Brent Early, Managing Director of Bus Travel NZ Limited is responsible for handling media and external enquiries that involve the CCTV system.
Nozer Bharucha, General Manager for the Scheduled Services of Bus Travel NZ Limited is responsible for training staff on compliance with CCTV policies and procedures.
Sam Early, Managing Director of S&S Security Solutions Limited is responsible for installing and maintaining the hardware used for the CCTV system.
8 SIGNAGE
Signage informing employees, contractors and members of the public that CCTV cameras are in operation in Bus Travel NZ Limited’s buses will be displayed in easy to view locations on all Bus Travel NZ Limited’s buses and will comply with the Privacy Act 1993.
A privacy notice will be located on Bus Travel NZ Limited’s website as well as The Yellow Bus website explaining how Bus Travel NZ Limited’s collects and uses CCTV footage on our buses.
9 COLLECTION, MONITORING AND USE
The CCTV systems will be operating on the following Bus Travel NZ Limited’s bus routes at all times and may be monitored continuously in real time:
- All Auckland Airport Park & Ride services
- All Auckland Airport Inter Terminal Transfer services
- All Airport Hotel Shuttle services (The Yellow Bus)
The CCTV systems will be operating at the below locations at Bus Travel NZ Limited’s business premise being 21 Brigade Road, Airport Oaks, Mangere at all times and may be monitored continuously in real time:
- Entire fleet parking area
- In spaces shared by multiple tenants
- Company-allocated staff room at Auckland Airport Park & Ride car park
Collection, monitoring and use of CCTV footage shall be conducted in a way that is consistent with the intent of this Policy, the purposes of collection of the CCTV footage, and the Privacy Act 1993. Specifically, CCTV footage shall not be used where it might unreasonably intrude on an individual’s privacy. We will not disclose personal information collected through CCTV footage to third parties except where:
- The individual(s) concerned have authorised the disclosure;
- The disclosure is required by our operational requirements (such as to meet our contractual obligations to third parties);
- We are required to provide the personal information by law;
- Disclosure is required for safety and security and data assurance purposes;
- Disclosure is for the purpose of collecting the data (as is outlined in this Policy);
- Disclosure is necessary following a transfer of our rights and duties;
- Disclosure is necessary to market, review, audit or improve our services or facilities or those of our business partners; or
- Disclosure is authorised by the Privacy Act 1993.
Prior to using an individual’s personal information we will take such steps (if any) as are, in the circumstances, reasonable to ensure that, having regard to the purpose for which the information is proposed to be used, the information is accurate, up to date, complete, relevant, and not misleading.
Persons permitted to monitor Bus Travel NZ Limited’s CCTV footage are:
- General Manager;
- Lead Supervisor
The Human Resources Manager shall maintain a register of those persons accessing CCTV footage.
When CCTV footage is shared, Bus Travel NZ Limited will ensure they are accurate, complete, and relevant to the purposes of collection.
10 STORAGE AND RETENTION
Storage of CCTV footage will be kept to a minimum to not unfairly invade on the privacy of individuals.
Bus Travel NZ Limited CCTV footage is overwritten after six weeks, unless the CCTV footage is manually saved, in which case it will be destroyed after it is no longer required for the purposes of collection in accordance with this Policy.
11 ACCESS
CCTV footage access for Bus Travel NZ Limited employees is limited to the following staff of Bus Travel NZ Limited:
- Managing Director
- Human Resources Manager
- Lead Supervisor
- General Manager of Bus Travel NZ Limited.
CCTV footage may only be accessed using the secure password held by the General Manager.
Requests by employees, contractors or members of the public, to access their personal information captured through Bus Travel NZ Limited’s CCTV cameras (Requests) are to be referred to the General Manager.
Requests will only be accepted by Bus Travel NZ Limited if they are made in accordance with the Privacy Act 1993.
Prior to granting access to CCTV footage, pursuant to a Request, Bus Travel NZ Limited will confirm that the individual making the Request is the individual featured in the CCTV footage.
If the CCTV footage relevant to the Request includes other identifiable individuals, Bus Travel NZ Limited must consider options to protect those identifiable individuals’ privacy before providing the CCTV footage in accordance with the Request, such as:
- If the CCTV footage is damaging or embarrassing towards another identifiable individual, Bus Travel NZ Limitedmay consider allowing the person who made the Request to view or listen to the CCTV footage on site, but not provide a copy of it;
- Where appropriate, Bus Travel NZ Limited may blur or pixelate the faces of other identifiable individuals on a copy of the footage, before providing the footage to the person who made the Request; or
- If there is no reasonable way to provide the footage, pursuant to the Request, without unreasonably breaching another individual’s privacy, Bus Travel NZ Limited may provide the person with a written description of what the CCTV footage shows, instead of providing the actual CCTV footage.
If the Request relates to CCTV footage which is connected to a criminal investigation, Bus Travel NZ Limited will check with the Police before disclosing the CCTV footage.
If the Police make a request for the CCTV footage without a warrant, Bus Travel NZ Limited will assess granting the Police’s request by requesting responses to the following information:
- The event the Police are interested in;
- The location where they think the event took place;
- The approximate time the event took place;
- The specific offence being investigated;
- The name and contact details of the Police Officer making the request; and
- The date of the request.
Bus Travel NZ Limited will keep a log of people, companies, organisations, and government bodies who have requested access to any form of CCTV footage, including the details of the requests and the reason for allowing or denying access to the requests.
12 AUDIT
Bus Travel NZ Limited is committed to regular audits of our CCTV systems and footage to ensure their effectiveness and to ensure that the CCTV systems are being used in accordance with the purposes of collection and this Policy.
During this audit the following aspects will be reviewed:
- Checking the CCTV equipment and procedures as these might need an upgrade or update. This includes:
- CCTV camera zoom function;
- CCTV camera rotation function;
- CCTV camera recording function;
- Image and sound quality of recordings and whether it is at the appropriate standard and fit for purpose;
- Security of transmission, storage and deletion of CCTV footage; and
- The performance of any Intelligent Surveillance Technologies.
- Collecting statistics about the CCTV system to assess our strengths and weaknesses. This information can include but is not limited to:
- The number of incidents captured by the CCTV system;
- The types of incidents captured by the CCTV system;
- The times/days of the week when incidents occurred;
- Which CCTV cameras capture the most and the fewest incidents;
- The number and types of CCTV system repairs and problems;
- The amount of money spent on the CCTV system; and
- The number of requests to access CCTV footage and how many times access was provided.
- Checking that Bus Travel NZ Limited contractors and employees are complying with this Policy and whether any changes to the Policy are required.
13 TRAINING
All workers who are involved in the CCTV system’s operations will be provided with adequate training to ensure that this Policy and Bus Travel NZ Limited’s obligations under the Privacy Act 1993 are being complied with.
14 BREACHES OF THE POLICY
If an employee of Bus Travel NZ Limited is found to have breached this Policy Bus Travel NZ Limited may consider the breach to amount to serious misconduct and a disciplinary process may follow.
If a contractor of Bus Travel NZ Limited is found to have breached this Policy Bus Travel NZ Limited may consider the breach to amount to a breach of contract warranting termination of the agreement with the contractor.