Video Surveillance Policy

1. Introduction

At Alfa Financial Software Inc, ("We," "Us," "Alfa"), our priority is to provide a safe and secure environment for both our staff and visitors. To this end, the deployment of security camera systems plays a crucial role. Security camera systems not only enhance workplace safety and security but also serve as a deterrent to crime, ensuring the protection of our personnel and property. A security camera, as defined here, encompasses video surveillance technology designed to record activities with the aim of detecting, deterring, preventing, or investigating crime or other threats to public safety.

Recognizing our responsibility to safeguard personal privacy and civil liberties, Alfa is committed to taking appropriate measures when utilizing security camera systems. Therefore, no security camera will be installed in any office location where individuals have a reasonable expectation of privacy.

2. Scope

Alfa uses CCTVs in its office for the following purposes:

  • Ensuring the personal safety of staff and visitors
  • Assisting in the investigation of suspected breaches of Alfa policies by staff or contractors
  • Assisting law enforcement in the prevention, detection, and investigation of crime and other workplace incidents

Alfa seeks to operate its security camera systems in a manner that is consistent with respect for the privacy of staff and visitors at all times. To ensure this, the installed CCTV cameras are set up for purely visual recording and Alfa will display warning signs clearly and prominently wherever CCTV is in operation

3.  Operation

Alfa will only collect information that is necessary and relevant for the stated purposes and will not further process that information in a manner that is incompatible with those purposes. Alfa will ensure that the siting of CCTV cameras will be made with consideration for individuals right to privacy and its intended purposes. All reasonable measures will be taken to ensure the accuracy of information through regular activities such as checking the quality of images and accuracy of time stamps.

4. Storage

CCTV recordings will be stored securely and retained for up to 30 days from the date the information was recorded unless required for the stated purpose/s or to fulfill a legal obligation. All recordings older than 30 days will be automatically overwritten unless recordings are required to be retained as part of an ongoing request, investigation or to fulfill a legal obligation.

5. Security

Alfa will take all reasonable steps to maintain the confidentiality, availability, and integrity of information captured by the CCTV cameras including, but not limited to:

  • Ensuring access to CCTV recordings is strictly controlled and limited only to authorized individuals who require access as part of their role at Alfa.
  • Applying security methods such as encryption, where necessary, when storing CCTV recordings
  • Providing and mandating completion of appropriate training for individuals with responsibility or access to CCTV recordings.

6.  Access and Disclosure

6.1. Internal Requests

Where a suspicion of misconduct arises and at the formal request or approval by the Global Data Protection Officer, the Operations Team may provide access to CCTV recordings for use in staff disciplinary cases.

6.2. External Requests

Requests received from third parties such as law enforcement or other individuals not featured in the information captured by the CCTV recordings should be made in writing to the Global Data Protection Officer at DPO@alfasystems.com who will, at a minimum:

  • Assess whether the information can lawfully be disclosed. Any decision to refuse a request is made at the discretion of the Global Data Protection Officer unless there is an overriding legal obligation. For example, a court order
  • Advise on appropriate measures to ensure any such disclosures are made securely and in a timely manner
  • Record the date of the disclosure along with details of who we have provided the information to (the name of the person and the organization they represent), why they required it, and the justification for doing so

7.  Complaints

Complaints concerning Alfa ’s use of its CCTV system or the disclosure of CCTV recordings should be made in writing to the Global Data Protection Officer at DPO@alfasystems.com.