Privacy Policy

Clarks Beach Waiau Pa Community & Business Association (CBA) Inc. Privacy Policy 2025

1. Introduction

This Closed-Circuit Television (CCTV) Privacy Policy outlines the approach of the Clarks Beach Waiau Pa Community & Business Association Inc. [hereafter called the ‘Association’] to the collection, use, storage, and disclosure of CCTV footage. It ensures CCTV operations are lawful, transparent, and respect individual privacy rights in accordance with:

The Privacy Act 2020 (NZ)
The Office of the Privacy Commissioner’s CCTV Guidelines (2021)
Any other applicable legal or community obligations

The policy also sets out safeguards to prevent misuse of CCTV footage. It does NOT cover other visual media such as drones, photographs, or live streaming.

All CCTV use will be reasonable and proportionate, minimising unnecessary intrusion into people’s privacy.

2. Objective

Enhance safety and security for the community
Deter and assist in the prevention and detection of crime
Monitor and respond to traffic incidents, civil defence situations, and other safety risks
Provide lawful evidence to the Police, courts, or public agencies when required

3. Application

This policy applies to all CCTV networks owned and operated by the Association. It covers:

Association members, engaged contractors, volunteers, and authorised Police staff accessing Association-owned CCTV
All public and semi-public spaces (e.g. streets, community structures, playgrounds) monitored under the Association’s CCTV network

This policy must be read alongside the Privacy Act 2020 and related CCTV guidance.

4. Policy Principles

The Association commits to the following principles, as expanded in the Privacy Act 2020

Collecting CCTV footage only for the purposes stated in this policy (Principle 1)
Notifying the public through clear signage where cameras are in operation (Principle 3)
Keeping footage secure and limiting access to authorised personnel (Privacy Principle 5)
Retaining footage no longer than necessary (Privacy Principle 9)
Allowing individuals to request access to footage of themselves, except where it unreasonably affects others’ privacy or is of a frivolous, vexatious or trivial nature (Privacy Principle 6)
Reporting any privacy breaches promptly to the Privacy Commissioner and affected individuals
Periodic refresher training for authorised users and regular audits of access logs to prevent misuse

5. CCTV Camera Placement

Cameras will NOT monitor private property or areas where there is a reasonable expectation of privacy (e.g., toilets, changing rooms)
A Privacy Impact Assessment (PIA) will be completed for any new camera location or new technology (e.g., AI analytics)
Camera placement is reviewed periodically to ensure it remains necessary and proportionate

6. Signage

Visible signs will be installed in all CCTV areas and are easily visible. The signs use messages such as: “Surveillance cameras are in operation”
The Clarks Beach Waiau Pa Community & Business Association (CBA) website, www.clarksbeachwaiaupa.co.nz/ gives contact details for any queries or requests
Additional details on camera locations are available on written request

7. Operating Hours

CCTV cameras may operate continuously, 24/7, unless specified otherwise.

8. Automatic Number Plate Recognition (ANPR)

ANPR cameras may be used only for community safety, traffic monitoring, or crime prevention
Any sharing of ANPR data with third parties (e.g. Safer Cities) requires:
a. A written data-sharing agreement
b. Compliance with Privacy Principle 11 (lawful disclosure)
c.Appropriate security and retention safeguards

9. Data Retention

Footage is stored on secure servers with password protection, encryption, and restricted user authenticati
Footage is retained for 90 days unless required for investigations, legal proceedings, or evidential purposes
If footage is retained beyond 90 days, the reason must be documented
Footage used for training or community reporting must be de-identified (e.g., faces blurred)

10. Management and Access of Footage

All third-party access (e.g., contractors, partner organisations) is covered by written agreements and subject to the same privacy safeguards. Authorised personnel include:

The Association’s CCTV team
The courts, or public sector agencies where legally required
Safer City for ANPR recording
New Zealand Police
Franklin Community Cameras (FCC) operators acting under Police direction
Approved volunteers from Pukekohe Community Patrol (PUCP) assigned to FCC duties

These individuals may access footage solely for the purposes of crime prevention, incident response, and lawful investigation, as outlined in this policy.

All personnel operate under formal agreements and privacy protocols, including training and compliance with the Privacy Act 2020. Access is logged and monitored, and any unauthorised use, disclosure, or retention of footage is strictly prohibited.

11. Individual Access Requests

Where a member of the public believes a crime has been committed which may have been captured by a camera, they should, in the first instance, report the matter to the Police.
Individuals can request footage of themselves by writing to the Association
Proof of identity is required
Access may be refused or restricted if:
a. It would breach another person’s privacy
b. It would compromise an ongoing investigation
c. It is impractical to isolate the requester’s footage
d. Access may not be granted where the request is clearly frivolous, excessive, or would place an unreasonable burden on the Association
If access is refused, a written explanation will be provideThe Association will respond within 20 working days of receiving a valid request, unless an extension is permitted under the Privacy Act
Footage is NOT disclosed to the general public or media, unless de-identified and approved by the Association

12. Breach & Incident Response

Any accidental loss, access, or disclosure of CCTV footage will

Reported to the Association’s Executive Committee
Notified to the Privacy Commissioner if required by the Privacy Act 2020
Communicated to affected individuals where appropriate
Affected individuals will be notified as soon as reasonably practicable after the Association becomes aware of a breach.

13. Complaints

Privacy-related complaints should be made in writing to the Executive Committee. If unresolved, complaints can be escalated to the Office of the Privacy Commissioner.

14. Complaints

This policy will be reviewed every 5 years, or sooner if required by law or technology changes.

15. Glossary

Access Log A record of who accessed CCTV footage, when, and for what purpose, used to monitor compliance and prevent misuse.
ANPR (Automatic Number Plate Recognition) Technology that captures and processes vehicle number plates for traffic monitoring and crime prevention.
Association. Clarks Beach Waiau Pa Community & Business Association Incorporated (CBA)
Authorised Personnel Individuals formally approved to access CCTV footage under privacy protocols, including the Association’s CCTV team, Police, and designated volunteers.
Breach Notification The process of informing affected individuals and the Privacy Commissioner of any unauthorised access, loss, or disclosure of CCTV footage.
CCTV (Closed-Circuit Television) A video surveillance system used to monitor public or semi-public areas for safety, security, and lawful evidence gathering.
Data Retention The period during which CCTV footage is stored before being securely deleted, unless required for legal or investigative purposes.
De-identified Footage CCTV footage that has been altered to remove or obscure personal identifiers (e.g., blurred faces) to protect privacy.
Executive Committee The governing body of the Association responsible for oversight of CCTV operations and privacy compliance.
Franklin Community Cameras (FCC) A local CCTV initiative operated under Pukekohe Police direction, with access granted to approved volunteers.
Frivolous, Vexatious or Trivial Request A request for footage that lacks serious purpose, is excessive, or places an unreasonable burden on the Association.
Individual Access Request A formal request by a person to view footage of themselves, subject to identity verification and privacy safeguards.
Privacy Act 2020 New Zealand legislation governing the collection, use, and disclosure of personal information, including CCTV footage.
Privacy Commissioner The independent authority responsible for overseeing privacy rights and compliance with the Privacy Act in New Zealand.
Privacy Impact Assessment (PIA) A formal evaluation of how a proposed CCTV installation or technology may affect individual privacy, used to ensure compliance and proportionality.
Privacy Principles The 13 principles outlined in the Privacy Act 2020 that guide lawful handling of personal information.
Public and Semi-Public Spaces Areas accessible to the general public, such as streets, playgrounds, and community structures, where CCTV may be installed.
Pukekohe Community Patrol (PUCP) A volunteer group authorised to assist with FCC operations under formal privacy protocols.
Safer Cities A third-party organisation that receives ANPR data under formal agreements for community safety initiatives.
Secure Server A protected digital storage system with encryption and restricted access used to store CCTV footage.

16. Document control

Title: Clarks Beach Waiau Pa Community & Business Association Inc (CBA) CCTV Policy 2025

Adoption Date: 28 August, 2025

Next Review: 2030

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