Legal Requirements

TERMS AND CONDITIONS

GENERAL
Hydrangea House, Hythe is a subsidiary of Kent Conversions Ltd a company incorporated in England and Wales. Registered office is at 2 Acott Fields, Yalding, Maidstone, Kent, ME18 6DQ.

A contract between you (the Guest) and the owners (We/Us) will come into existence when we receive payment and accept your booking by issuing a confirmation of booking for the holiday dates shown in the rental agreement. This period is hereafter referred to as ‘The Holiday’. The contract binds you & all the members of your party. It is your responsibility to ensure that all members of your party accept the terms of the contract set out in these terms & conditions of booking. Failure to disclose all relevant information or comply with these terms may lead to termination of the contract & loss of the booking.

Please read these Terms carefully and check that the details on the Booking and in these Terms are complete and accurate before you submit the Booking. If you think that there is a mistake or require any changes please contact us to discuss. We will confirm any changes in writing to avoid any confusion between you and Us. If you make a Booking over the telephone then these Terms will apply to such a Booking. The Party Leader must be at least 18 years of age at the time of the booking. No students or all male/female parties accepted unless by prior arrangement.

Whilst we keep our illustrations, photographs and other imagery as up to date as possible, any illustrations, photographs and other imagery displayed are for illustrative purposes only and subject to change. The activities that may be shown in our literature are outside our control and not supplied by us. If you wish to carry out any activity at or near the property, we strongly recommend you book the activity with the relevant provider.

ACCESSIBILITY REQUIREMENTS
If you have accessibility requirements, please discuss this with us at the time of Booking so we can advise you on the suitability of the Property.

THE HOLIDAY
Rentals are for a maximum of four weeks and commence at 16.00hrs on the first day of the rental and end at 10.00hrs on the day of departure unless otherwise notified and agreed by Us in writing. On some occasions there may be a short delay on Check In due to the additional Covid Cleaning/Disinfection that is now undertaken.  The Guest will be liable for any cost, of whatever nature, incurred because of an unauthorized extension. The letting does not confer a short hold tenancy or give rise to a relationship of Landlord and Tenant (Schedule 1, Paragraph 9 of the Housing Act 1988). We will make every effort to make the Accommodation available to you on time. However, there may be delays due to an Event Outside Our Control

GUESTS OBLIGATIONS
You will take good care of the property, furniture, utensils, equipment, fixtures and fittings and leave it in a clean and tidy condition at the end of the Holiday.

A cleaning service is not provided during the Holiday unless otherwise specified.

We may make an additional, reasonable charge for professional cleaning after you and your Guests' occupancy as may be required to return the Property to its original state of cleanliness and tidiness.

Linen, bathroom towels and beach towels are provided. Linen is changed between tenancies and weekly during tenancies.

We appreciate the need for you to have an enjoyable time whilst on your holiday; however we would also ask you to respect our neighbours and not disturb or cause offence in any way. We operate a strict quiet zone between 22.30hrs and 09.00hrs within the grounds of the Property.

Smoking (including vaping) is strictly prohibited in the Property.

The maximum number of people who can stay in the Property will be notified to you as part of the Booking process. You promise that you will not exceed that number.

For your safety and security we have installed a noise monitor and surveillance cameras operate at both front and back entrances.

Friends are able to visit you in the property with prior written agreement from Us. However, friends are not allowed to stay overnight unless they have been pre-notified to us on the Booking Form as members of your party. This is an insurance and health & safety issue and is non-negotiable; clients will be asked to vacate a property if they do not adhere to this condition of their stay.

Any damage should be reported immediately so issues can be put right. We reserve the right to reclaim any costs incurred attributable to losses or damages to the property and contents caused by the Guest or a member of their party (reasonable wear and tear excluded).

You must allow Us or our Employees access to the property during reasonable hours, except where an emergency problem needs to be remedied immediately and you are out of contact, in which case, we or our Employee may enter the property without your prior agreement.

We only supply the Accommodation for domestic and private use. You agree not to use the property for any commercial, business or resale purpose. It is not permitted for any commercial enterprise or supplier of leisure activities to visit the property during your stay without Our consent. Failure to adhere to this clause may result in additional charges and may result in your Holiday being immediately terminated.

PETS
Pets are only permitted in the Property if specified within the Booking.

Pets should be kept under control and exercised off the property.

Responsibility for the safety of your pet remains with the owner at all times.

Please do not leave your Pet unsupervised as this can result in considerable damage to the Property and distress to the pet.

Pets are not permitted in the Hot Tub.

We supply a mat, throws, towels and bowls but appreciate you may prefer to bring your own pet provisions.

Pets should be cleaned and fully dried off before entering the property after being outside. There are cleaning facilities for your convenience.

In the interests of hygiene, health and safety and out of consideration for others it is important that you clean-up after your pet and dispose of any mess in a sanitary and responsible manner.

You are responsible for any damage caused by your pet, whether inside or outside the property.

If extra cleaning is required as a result of the Guest or member of their Party having pets in the property, this may be chargeable.

HOT TUB
Guests are responsible for their own safety with regards to usage. Guidelines are provided below and on site.

In line with our 'Quiet Hours' we politely request that the Hot Tub is vacated at 22.30hrs.

  • No solo bathing.
  • Don’t exceed 15 minutes immersion at a time.
  • Use the toilet and shower before use.
  • Don’t wear suntan lotions, spray tans or skin creams.
  • Don’t exceed the maximum number of bathers specified for the hot tub (one per seat).
  • Supervise all children in or around the tub at all times.
  • Don’t take food or drink into the hot tub.
  • Keep glass objects out of the hot tub.
  • It’s recommended that hot tubs are not used after a heavy meal or while under the influence of alcohol or sedatives.
  • Seek medical advice before using if you are pregnant or have health problems or are immunocompromised.
  • Don’t allow children under four years or those who cannot keep their head out of the water when seated to use the tub.
  • It’s not recommended for children under eight to use a hot tub.

LEGAL RIGHTS
As a consumer, you have legal rights in relation to Accommodation not offered to you with reasonable skill and care, or if the materials We use are faulty or not as described. Advice about your legal rights is available from your local Citizens' Advice Bureau or Trading Standards office. Nothing in these Terms will affect these legal rights.

LIABILITIES
If We fail to comply with these Terms, We are responsible for loss or damage you suffer that is a foreseeable result of Our breach of the Terms or Our negligence, but We are not responsible for any loss or damage that is not foreseeable. Loss or damage is foreseeable if they were an obvious consequence of our breach or if they were contemplated by you and Us at the time We entered into this contract. For the avoidance of doubt, We are not responsible for any transport and/or alternative accommodation costs.

We only supply the Accommodation for domestic and private use. You agree not to use the Accommodation for any commercial, business or re-sale purpose, and We have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.

Broadband Internet access is available but We cannot promise that service will be available constantly and that it is provided for recreational and not for business use. Neither a minimum speed, unrestricted bandwidth nor uninterrupted provision of an internet access service can be guaranteed and nor will We be liable for any form of compensation or expenses claimed by any guest in respect of the provision of internet services or telephone services not being available or failing.

We shall have no liability for any death or personal injury unless this results from Our negligence or our Employees, Agents or Subcontractors (providing they were at the time acting in the course of their employment).

We accept no liability for loss of or damage to the Guest’s possessions on the Property or land.

COMPLAINTS
All complaints should be notified as soon as possible. We may be required to carry out an immediate investigation and if necessary take remedial action. Guests have a legal obligation to mitigate their loss. If We are denied access or the opportunity to put matters right during the Holiday, then the Guest will waive all rights.

BREACH OF CONTRACT
By the Guest or any member of your party. We reserve the right to re-enter the property and end the Holiday and ask the Guest and their party to leave.
By Us. The Guests have the right to end the Holiday and leave.

COVID CANCELLATIONS

If you have to cancel you booking because UK Government public health measures mean it is unlawful to travel to or to make use of the Accommodation, you may choose to:

- transfer your booking to a later date free of any administration charges, subject to availability - you will have to pay any difference in price if the cost of the new booking is higher or be reimbursed the difference if the cost of the new booking is lower;

- obtain a refund of the amount already paid by you for the booking.

CANCELLATION BY THE GUEST Up to 14 days before the Holiday start date. The Party Leader may cancel by contacting Us in writing with a copy of the Booking Confirmation. We will confirm your cancellation in writing to you.  Both deposit and any additional deposits will be refunded. Less than 14 days before the Holiday start date. We request The Party Leader contacts us by telephone immediately and also confirms cancellation in writing with a copy of the Booking Confirmation. We will confirm you cancellation in writing to you. If we are unable to offer the Accommodation to another party we reserve the right to invoice You for an amount up to 100% of the cost for Accommodation as outlined in the Booking.

CANCELLATION BY US We reserve the right to refuse or cancel any booking, for whatever reason, within a 48hr cooling off period of the booking being received. If We have to cancel a Booking before the start date of the Holiday, due to an Event Outside our Control or the unavailability of key personnel or key materials without which We cannot provide the Holiday, We will contact you promptly and confirm the cancellation in writing. Any payments made in advance of the Holiday will be refunded. An Event Outside our Control means any act or event beyond Our reasonable control, including without limitation, strikes, lock-outs or other industrial action by third parties, civil commotion, riot, invasion, terrorist attack or threat of terrorist attack, war (whether declared or not) or threat or preparation for war, fire, explosion, storm, flood, earthquake, subsidence, epidemic or other natural disaster, or failure of public or private telecommunications networks, power networks or water supplies, local building works or road works, transport interruptions, delays or cancellations. If, for any reason, we are unable to offer the Property to you for the duration of the Holiday then we shall use reasonable endeavours to find suitable alternative accommodation for you. If this is not possible then We shall refund any fees paid to us in accordance with the Booking.

CANCELLATION FEE:

All Refunds will be subject to a £20 administration fee.

GOVERNING LAW AND JURISDICTION
The contract embodied in the booking is governed by English Law and subject to the exclusive jurisdiction of the English courts. Your statutory rights are not affected by anything contained within these booking conditions.
We and the Guest and all members of their party are required to abide by the law of the land at all times during the Holiday.

GDPR (GENERAL DATA PROTECTION REGULATION - EU)

The EU General Data Protection Regulation (GDPR) came into effect on 25 May, 2018 and places new obligations on organisations based in the EEA or which hold or process personally identifiable information (PII) about EU residents.

  • Introduction
  1. At Hydrangea House, we are committed to protecting and respecting your privacy. Please read this policy as it contains important information about how we use personal data that we collect from you or that you provide to us. This policy has been adopted by all of the companies and businesses in our group including Kent Conversions Ltd.
  2. By accessing the website or providing information, you agree to our privacy practices as set out in this privacy statement. We may change this policy from time to time. You should check this policy frequently to ensure you are aware of the most recent version.
  3. If you have any questions regarding this policy or about our privacy practices, please contact us at the relevant address set out below in the ‘Contact Us’ section.
  • Who are we?
    1. When we say ‘we’ or ‘us’ or 'our' in this policy, we are generally referring to Kent Conversions Ltd, a company registered in England and Wales (Company No. 10759427) with our registered office at 2 Acott Fields, Yalding, Maidstone, Kent ME18 6DQ. Kent Conversions Ltd also trading as Hydrangea House, Hythe
  • Information we collect from you?
    1. Personal data is information that can be used to uniquely identify or contact a single person. We will collect and process information about users of our website and customers’ hotel guests, in order to provide our services. Therefore, we may process any information, including personal data, that our customers’ hotel guests provide to the hotel or to any online travel agency relating to the hotel guests’ arrangements.
    2. Personal data processed by us may include, but is not limited to: name, address, e-mail address, phone number, date of birth, records of our interactions and travel information.
    3. All Debit & Credit Card Details are stored directly and securely by Stripe Inc. We do not store or have access to your full card payment details. 'We' are fully compliant with the Payment Card Industry Data Security Standard (PCI DSS).

      Stripe has certified to the EU-U.S. and Swiss-U.S. Privacy Shield Framework. Their Privacy Shield Policy is available here.

      In addition to Privacy Shield, Stripe continues to employ additional compliance measures to ensure an adequate level of protection of personal data transferred outside the European Economic Area.

      If you have additional questions, reach out to their Privacy team at privacy@stripe.com.

    4. We will hold your personal data on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us. We review our retention periods for personal data on a regular basis. We are legally required to hold some types of information to fulfill our statutory obligations.
  • How do we collect your information?
    1. We collect personal data from and about users of our website and our customers’ hotel guests through the provision of our services. We also collect information from conferences we attend.
      • Information you give us.
        • This is information about you that you give us directly through our website or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our website or services, when you report a problem with our website and when you provide us with details relating to the nature of any query or problem.
        • Details you provide relating to your proposed travel arrangements, including relevant bookings and related information.
      • Information we collect about you.
        • When you visit our website we will automatically collect:
          • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions and operating system and platform;
          • Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
      • Information we receive from other sources.
        • This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers).
        • Personal information that is provided to us by travel agencies or online travel sites using Booking Portals
  • How we might use your information?
    1. We use information held about you in order to administer any contracts between you and us and for the legitimate interests of our business, for example, the processing of hotel guest data in order to register the guest’s booking.
      • Information you give to us. We will use this information:
        • to provide you with information, products or services that you request from us;
        • to carry out our obligations under any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
        • to ensure that content from our website is presented in the most effective manner for you and for your computer;
        • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about, if you have consented to this;
        • If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you;
        • If you change your mind and decide that you do not want us to use your data in this way, simply get in touch using our details below in the 'Contact Us' section;
        • We do not share, sell, lease or distribute your data to third parties.
      • Information we collect about you. We will use this information:
        • to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
        • to improve our website to ensure that content is presented in the most effective manner for you and for your computer or other device;
        • to allow you to participate in interactive features of our service, when you choose to do so;
        • as part of our efforts to keep our website safe and secure;
        • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
        • to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them.
      • Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive) and to facilitate the booking and related services of guests.
    2. We may aggregate your data into an anonymised form to help us provide more useful information to our customers and to understand which parts of the website are of most interest to visitors.
  • Who we might share your information with
    1. We may from time-to-time make certain personal information available to strategic partners that work with Kent Conversions Ltd, such as the following:
      • Various affiliates of Kent Conversions Ltd, which means our current subsidiaries. It also includes such other affiliates as we may add in the future;
      • Travel agencies and online travel sites through which you have arranged travel, but only the personal information that is needed for successful access to or processing of your travel arrangements;
      • Service providers we use to support our business who provide services such as information processing, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys;
      • In the event of merger, acquisition, or any form of sale of some or all of our assets, in which case personal data we hold about our customers will be among the assets transferred to the buyer.
    2. If we engage a third party to process an individual’s personal data on our behalf, that third party will be bound by our data privacy policies or have similar contractual obligations in relation to the storage and processing of your personal information.
    3. We may also disclose your personal information to third parties to:
      • Comply with any court order or other legal obligation or when data is requested by government or law enforcement authorities;
      • Enforce or apply our terms of use and any other agreements;
      • Protect the rights, property, or safety of us, our employees, customers, or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
  • Your rights
    1. You have the right to ask us not to process, or to stop processing, your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us on the details set out below in the ‘Contact Us’ section.
    2. Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
  • How you can access and update your information
    1. You have the right to access the personal information that we hold about you in many circumstances. This is called a subject access request. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge except in exceptional circumstances.
    2. Before providing personal information to you or another person on your behalf, we may ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal information.
    3. We strive to maintain accurate, complete, and relevant personal information for the purposes identified in this privacy statement. If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it.
    4. You have the right to object to us processing your personal information if we are not entitled to use it any more or to have your information deleted or have its processing restricted in certain circumstances. You also have the right to port your personal data in certain circumstances.
    5. If you would like to exercise any of these rights, please contact us using the details set out below in the ‘Contact Us’ section.
    6. You also have the right to lodge a complaint with the supervisory data protection body that regulates us if you have concerns about how we use your personal information. For information on how to do this, please see the ‘Contact Us’ section.
  • Security precautions in place to protect against the loss, misuse or alteration of your information
    1. We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.
    2. These include:
      • physical security and access to all Kent Conversions Ltd premises;
      • all access to computer hardware is password protected, with encryption and default security firewalls in place;
      • staff access to personal information is given on a need to know basis only.
      • Regular training of staff in relation to storage; and
      • Otherwise in accordance with 'Our' Data Protection Policy.
    3. The safety and security of your information also depends on you. Any content, including personal information, that you contribute to be shared, published or transmitted to other users of the website, is visible to other users and can be read, collected, or used by them. We urge you to be careful about giving out information in public areas of any of the website. You understand and acknowledge that, even after removal, copies of your content, including personal information, that you contribute to be shared, published or displayed on a website, or transmitted to other users of a website, may remain viewable in cached and archived pages. Although we take efforts to protect your personal information, we cannot guarantee the security of your personal information transmitted to a website. Any transmission of personal information is at your own risk.
  • Cookies
    1. The website may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us to improve and to deliver a better and more personalized service by enabling us to:
      • Estimate our audience size and usage patterns;
      • Store information about your preferences, allowing us to better customize the services according to your individual interests;
      • Speed up your searches;
      • Recognize you when you return to the website; and
      • Deliver targeted advertising based on products or content you have shown an interest in.
    2. You may refuse to accept cookies by activating the appropriate settings on your browser. Check with your provider to find out how to disable cookies. Please note that certain features of the website may not be available if cookies are disabled.
  • Contact Us

    If you have any questions regarding this policy or about our privacy practices, please e-mail us at: admin@hydrangeahousehythe.com or write to: 2 Acott Fields, Yalding, Kent, ME186DQ Attn: Data Controller

  • Supervisory Data Protection Authority:
    Information Commissioner’s Office:
    https://ico.org.uk/

 

ELECTRICAL CHARGING VEHICLE POLICY

1.              About this policy

1.1           This policy sets our how Electric Vehicles (EV) should be recharged while at the Property and the responsibilities of EV owners in respect of safe charging. 

1.2           Any reference to "Property" in this policy is a reference to the Property including any garden, grounds, outbuildings, garages or communal spaces.

1.3           This policy forms part of our contract with you. A breach of this policy will constitute a breach of the contract between us.

2.              Who does this policy apply to?

2.1           This policy applies to all members of the Booking Party and such other visitors of the Property. It shall be the responsibility of the Lead Guest to inform all members of the Booking Party and any visitors of this policy.

3.              What is an Electric Vehicle?

3.1           For the purpose of this policy an EV is any vehicle that uses electric motors, either fully or partially, to drive its wheels. It will derive some or all its power from rechargeable batteries which requires connection to the electricity grid (plug-in). This  includes fully chargeable and plug-in hybrid cars, motorbikes, buggies, scooters, mopeds, bicycles, utility vehicles and tracked vehicles.   

4.              Domestic chargers are not permitted at the Property

4.1           Most EVs are supplied with a domestic charger, commonly known as a 'granny charger' or a ‘trickle charger’. These cables recharge the EV using a domestic power source via a 3-pin wall socket.

4.2           Domestic chargers are not suitable for use in the Property and will create a fire hazard. The use of domestic chargers is strictly forbidden.

4.3           We retain the right to carry out reasonable inspection, on a without notice basis, to ensure that granny chargers are not in use in the Property.

4.4           You are solely liable for any damage or loss suffered by us as a result of your unauthorised use of domestic chargers.

5.              Dedicated charging points

5.1           We do not have on-site charging facilities at the Property and you must make your own arrangements for EV charging. The closest charge points to the Property can be found using http://www.zap-map.com/live/:

CCTV POLICY

1.              POLICY STATEMENT

1.1           We have assessed that security cameras, Closed-Circuit Television (CCTV) and other surveillance systems have a legitimate role to play in helping to maintain a safe and secure environment for all our staff and visitors. However, we recognise that this may raise concerns about the effect on individuals and their privacy. This policy is intended to address such concerns. Images and audio recorded by surveillance systems are personal data which must be processed in accordance with data protection laws. We are committed to complying with our legal obligations and ensuring that the legal rights of our visitors and staff, relating to their personal data, are recognised and respected.

2.              DEFINITIONS

2.1           For the purposes of this policy, the following terms have the following meanings:

CCTV

fixed and domed cameras, smart doorbells, and any other recording equipment designed to capture and record images and audio of individuals and property.

Data

information which is stored electronically, or in certain paper-based filing systems. In respect of CCTV, this generally means video images with audio. It may also include static pictures such as printed screen shots.

Data subjects

all living individuals about whom we hold personal information as a result of the operation of our CCTV (or other surveillance systems).

Personal data

data relating to a living individual who can be identified from that data (or other data in our possession). This will include video images of identifiable individuals.

Data controllers

the people who, or organisations which, determine the manner in which any personal data is processed. They are responsible for establishing practices and policies to ensure compliance with the law. We are the data controller of all personal data used in our business for our own commercial purposes.

Data users

those of our employees whose work involves processing personal data. This will include those whose duties are to operate CCTV cameras and other surveillance systems to record, monitor, store, retrieve and delete images. Data users must protect the data they handle in accordance with this policy and our Privacy Policy.

Data processors

any person or organisation that is not a data user (or other employee of a data controller) that processes data on our behalf and in accordance with our instructions (for example, a supplier which handles data on our behalf).

Processing

any activity which involves the use of data. It includes obtaining, recording or holding data, or carrying out any operation on the data including organising, amending, retrieving, using, disclosing or destroying it. Processing also includes transferring personal data to third parties.

Surveillance systems

any devices or systems designed to monitor or record images and/or audio of individuals or information relating to individuals. The term includes CCTV systems as well as any technology that may be introduced in the future such as body worn cameras, unmanned aerial systems, smart doorbells and any other systems that capture information of identifiable individuals or information relating to identifiable individuals.

3.              ABOUT THIS POLICY

3.1           We currently use CCTV on and around our Property. This policy outlines why we use CCTV on our Property, how we will use CCTV and how we will process data recorded by CCTV cameras to ensure we are compliant with data protection law and best practice. This policy also explains how to make a subject access request in respect of personal data created by CCTV.

3.2           We recognise that information that we hold about individuals is subject to data protection legislation. The images of individuals recorded by CCTV cameras in the workplace are personal data and therefore subject to the legislation. We are committed to complying with all our legal obligations and seek to comply with best practice suggestions from the Information Commissioner's Office (ICO).

3.3           This policy covers all guests and visitors of the Property, our staff and contractors. It may also be relevant to visiting members of the public.

3.4           The policy will be regularly reviewed to ensure that it meets legal requirements, relevant guidance published by the ICO and industry standards.

4.              PERSONNEL RESPONSIBLE

The Data Controller has overall responsibility for ensuring compliance with relevant legislation and the effective operation of this policy. Day-to-day management responsibility for deciding what information is recorded, how it will be used and to whom it may be disclosed has been delegated to on site managerial staff.

1.              REASONS FOR THE USE OF CCTV

1.1           We currently use CCTV around our site as outlined below. We believe that such use is necessary for legitimate business purposes, including:

1.1.1             to prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime;

1.1.2             for the personal safety of guests, staff, visitors and other members of the public and to act as a deterrent against crime;

1.1.3             to support law enforcement bodies in the prevention, detection and prosecution of crime;

1.1.4             to assist in day-to-day management, including ensuring the health and safety of guests, staff and others;

1.1.5             in relation to employees and workers, to assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings; and

1.1.6             to assist in the defence of any civil litigation, including employment tribunal proceedings.

This list is not exhaustive and other purposes may be or become relevant.

2.              MONITORING

2.1           CCTV monitors areas within the boundary of the Property 24 hours a day and this data is continuously recorded.

2.2           Camera locations are chosen to minimise viewing of spaces not relevant to the legitimate purpose of the monitoring. As far as practically possible, CCTV cameras will only cover entry and exit points, communal and public areas of the Property and will not focus on private spaces which are to be enjoyed by guests. Under no circumstances shall CCTV be installed in, or otherwise focus on, toilets, shower facilities, swimming pool areas, hot tubs, changing rooms, bedrooms or private offices or staff resting areas.

3.              HOW WE WILL OPERATE ANY CCTV

3.1           Where CCTV cameras are placed at the Property, we will ensure that signs are displayed at the entrance of the surveillance zone to alert individuals that their image may be recorded. The surveillance zone is the area that the CCTV covers only, not necessarily the whole property. Such signs will contain details of the organisation operating the system, the purpose for using the surveillance system and who to contact for further information, where these things are not obvious to those being monitored.

3.2           Live feeds from CCTV cameras will only be monitored where this is reasonably necessary, for example to protect health and safety.

3.3           We will ensure that live feeds from cameras and recorded images are only viewed by approved members of staff whose role requires them to have access to such data. This may include HR staff involved with disciplinary or grievance matters.

4.              USE OF DATA GATHERED BY CCTV

4.1           In order to ensure that the rights of individuals recorded by the CCTV system are protected, we will ensure that data gathered from CCTV cameras is stored in a way that maintains its integrity and security. This may include encrypting the data, where it is possible to do so.

4.2           Given the large amount of data generated by surveillance systems, we may store video footage using a cloud computing system. We will take all reasonable steps to ensure that any cloud service provider maintains the security of our information, in accordance with industry standards.

4.3           We may engage data processors to process data on our behalf. We will ensure reasonable contractual safeguards are in place to protect the security and integrity of the data.

5.              RETENTION AND ERASURE OF DATA GATHERED BY CCTV

5.1           Data recorded by the CCTV system will be stored digitally using a cloud computing system. Data from CCTV will not be retained indefinitely but will be permanently deleted once there is no reason to retain the recorded information. Exactly how long that data will be retained for will vary according to the purpose for which they are being recorded. For example, where recordings are for the purpose of crime prevention purposes, data will be kept long enough only for incidents to come to light. We will maintain a comprehensive log of when data is deleted outside of our usual retention schedules.

5.2           At the end of their useful life, data in all formats will be erased permanently and securely. Any physical matter such as tapes or discs will be disposed of as confidential waste. Any still photographs and hard copy prints will be disposed of as confidential waste.

6.              USE OF ADDITIONAL SURVEILLANCE SYSTEMS

6.1           Prior to introducing any new surveillance system, we will carefully consider if they are appropriate by carrying out a privacy impact assessment (PIA).

6.2           A PIA is intended to assist us in deciding whether new surveillance systems are necessary and proportionate in the circumstances and whether they should be used at all or whether any limitations should be placed on their use.

6.3           Any PIA will consider the nature of the problem that we are seeking to address at that time and whether the surveillance is likely to be an effective solution, or whether a better solution exists. In particular, we will consider the effect a surveillance system will have on individuals and therefore whether its use is a proportionate response to the problem identified.

6.4           No surveillance cameras will be placed in areas where there is an expectation of privacy (for example, in changing rooms) unless, in very exceptional circumstances, it is judged by us to be necessary to deal with very serious concerns.

7.              COVERT MONITORING

7.1           We will never engage in covert monitoring or surveillance (that is, where individuals are unaware that the monitoring or surveillance is taking place) unless, in highly exceptional circumstances, there are reasonable grounds to suspect that criminal activity or extremely serious malpractice is taking place and, after suitable consideration, we reasonably believe there is no less intrusive way to tackle the issue.

7.2           In the unlikely event that covert monitoring is considered to be justified, it will only be carried out with the express authorisation of our Data Controller. The decision to carry out covert monitoring will be fully documented and will set out how the decision to use covert means was reached and by whom. The risk of intrusion on innocent workers or customers will always be a primary consideration in reaching any such decision.

7.3           Covert monitoring will only be carried out for a limited and reasonable period of time consistent with the objectives of making the recording and will only relate to the specific suspected illegal or unauthorised activity.

8.              ONGOING REVIEW OF CCTV USE

8.1           We will ensure that the ongoing use of existing CCTV cameras at the Property is reviewed periodically to ensure that their use remains necessary and appropriate, and that any surveillance system is continuing to address the needs that justified its introduction.

9.              REQUESTS FOR DISCLOSURE

9.1           We may share data with other group companies and other associated companies or organisations, for example shared services partners where we consider that this is reasonably necessary for any of the legitimate purposes set out above in paragraph 5.

9.2           No recordings from our CCTV will be disclosed to any other third party, without express permission being given by our Data Controller. Data will not normally be released unless satisfactory evidence that it is required for legal proceedings or under a court order has been produced.

9.3           In other appropriate circumstances, we may allow law enforcement agencies to view or remove CCTV footage where this is required in the detection or prosecution of crime.

9.4           We will maintain a record of all disclosures of CCTV footage.

9.5           No CCTV footage will ever be posted online or disclosed to the media.

10.           SUBJECT ACCESS REQUESTS

10.1        Data subjects may make a request for disclosure of their personal information and this may include CCTV images and, if captured, audio (data subject access request) in accordance with our Privacy Policy.

10.2        In order for us to locate relevant footage, any requests for copies of recorded CCTV images must include the date and time of the recording, the location where the footage was captured and, if necessary, information identifying the individual.

10.3        We reserve the right to obscure images of third parties when disclosing CCTV data as part of a subject access request, where we consider it necessary to do so.

11.           COMPLAINTS

11.1        If you have questions about this policy or any concerns about our use of CCTV, then they should speak to our Data Controller in the first instance.

12.           REQUESTS TO PREVENT PROCESSING

12.1        We recognise that, in rare circumstances, individuals may have a legal right to object to processing and in certain circumstances to prevent automated decision making (see Articles 21 and 22 of the UK General Data Protection Regulation). For further information regarding this, please contact our Data Controller.