City of York Council (CYC) current data protection notification is registered with the Information Commission’s Office (ICO) - reference Z5809563.
We regularly review this privacy notice, and it was last updated in October 2026.
CYC contracts with Gough & Kelly Security Ltd. (G&K) to provide the CCTV services. G&K is an Information Commission's Office (ICO) registered data controller (Z1585966) and a National Security Inspectorate (NSI) Gold approved company contracted to the council to manage CCTV in York. The NSI is recognised as the leading certification body for the security and fire protection sectors in the UK.
For the purposes of data protection legislation, CYC is the data controller and G&K are the data processor and are both responsible to you under the law for the processing set out in this privacy notice.
CYC is committed to ensuring that information is handled in accordance with the principles set out in data protection legislation and guidance from the Information Commission’s Office (ICO).
This privacy notice tells you what to expect when we process your information, and it applies to CCTV in York.
You can contact the council’s Data Protection Officer on email: information.governance@york.gov.uk, or telephone: 01904 555719, or write to:
West OfficesStation Rise
York
YO1 6GA
You can contact G&K’s Data Protection Officer on email: enquiry@gkgroup.uk, or telephone: 0344 8807100, or write to:
Gough & KellyUnit 2, Railsfield Mount
Bramley
Leeds
LS13 3AX
This privacy notice should be read in conjunction with other CYC privacy notices that are available in our Privacy Notice and/or CYC policies and procedures.
When appropriate we will provide a ‘just in time’ notice to cover any additional processing activities not mentioned in this privacy notice.
- How we collect your information
- What personal data we process and why
- Automated decision-making
- Collecting information automatically
- Children's information
- Lawful basis for processing your personal data
- How long we keep your personal data
- Data sharing
- Data processors and/or third parties
- Transfers of personal data
- How we protect your information
- Your rights in relation to this processing
How we collect your information
We get information about you from the following sources:
- our CCTV systems
- when using body worn systems
- when using redeployable CCTV systems
- from other organisations such as the NHS and the police
- from our commissioned partners or contractors who undertake work on our behalf
Find more details about our CCTV public spaces locations.
What personal data we process and why
Our CCTV systems will process personal data, special categories of personal data and criminal offence data for the below purposes:
- monitoring and managing public spaces including traffic and travel
- event management (such as cycle events, York Marathon, York Races)
- 'Storenet', a service to retail and licensed premises, including a radio link with registered Security Industry Authority (SIA) operatives
- barrier control such as on-street rising bollards, car park barriers and Hostile Vehicle Mitigation (HVM) barriers
- production of evidence for example to police, solicitors, insurance companies, court proceedings where it is appropriate to do so
- welfare and security checks for individuals where it is appropriate to do so
- for operational, planning and analytical purposes, including manual footfall monitoring and counts
When you complete an online form on the council’s website and you have provided your email address, we will send you a copy of your completed online form.
If attending a council site or attending an event at a council venue that is covered by our public space CCTV you can find details in this CCTV Privacy Notice.
Use of Artificial Intelligence
We may use Artificial Intelligence (AI) technologies to support or enhance council services. Where AI is involved in a process that directly affects your interaction with us, we will inform you before your user journey begins. This ensures transparency and helps maintain trust in how we use AI.
Our use of AI complies with the UK General Data Protection Regulation (UK GDPR), including the principles of lawfulness, fairness, transparency, accountability, and accuracy. We conduct Data Protection Impact Assessments (DPIAs) where AI systems are likely to result in high risks to individuals’ rights and freedoms, such as automated decision-making or profiling.
If generative AI tools are used, we do not use personal or end-user data to train AI models. This helps ensure compliance with the purpose limitation and data minimisation principles under UK GDPR.
AI for Staff Productivity and Accessibility
Where AI tools are used solely by staff to assist with drafting, research, or accessibility - for example, to improve writing efficiency or summarise information - these uses do not form part of a business process that affects service delivery or decision-making. As such, no specific notification will be provided for these internal productivity uses.
These uses are considered low risk and do not involve automated decision-making that produces legal or similarly significant effects. They are also subject to internal governance and safeguards to ensure responsible use.
Examples include:
- drafting internal reports or meeting notes
- summarising lengthy documents for quicker review
- assisting with spelling, grammar, or formatting tasks
We may use your information to create reports and statistics that are anonymous and cannot be linked back to you or individuals such as:
- for statistical analysis
- for statutory returns
- for audit frameworks
- to see how the council and its partners are supporting individuals
- to help design better services
- to inform funding decisions
Automated decision-making
We do not carry out any automated decision-making in our use of CCTV in York
Collecting information automatically
Please see our Cookies Policy for further information about the information we collect automatically when you use our website.
Children’s information
Where we provide services directly to children or young people, the information in the relevant parts of this notice applies to children and young people, as well as adults.
Lawful basis for processing your personal data
Any personal data, special categories data and criminal offence data that we process about individuals is done so in accordance with one or more of the following Article 6, 9 and 10 of the UK GDPR and Schedule 1 of the Data Protection Act 2018 (DPA 2018).
- Article 6(1)
- (c) Legal obligation: the processing is necessary for the council to comply with the law (not including contractual obligations)
- (d) Vital interests: the processing is necessary to protect someone’s life
- (e) Public task: the processing is necessary for the council to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law
- (f) Legitimate interests: the processing is necessary for the council’s legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks)
- Article 9(2)
- (b) Employment, social security and social protection (if authorised by law)
- (c) Vital interests
- (g) Reasons of substantial public interest (with a basis in law)
This is supported by Schedule1, Part 2 (6) of the Data Protection Act 2018 and the following legal framework:
- Protect Duty which is known as ‘Martyn’s Law’
- Prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties including the safeguarding against and the prevention of threats to public security
- Crime and Disorder Act
- Safeguarding vulnerable groups Act 2006
- Traffic Management Act 2004
Where we process information relating to criminal convictions, offences, alleged offences, court proceedings, investigations, or related security measures, it will only be where it is necessary and where we are authorised to do so by law and in accordance with Article 10 UK GDPR and the Data Protection Act 2018. This may be for the purpose of carrying out our statutory duties and powers, safeguarding children and adults, preventing and detecting crime or fraud, undertaking regulatory and enforcement activities, protecting the public, managing legal proceedings, or complying with legal obligations. Appropriate safeguards are applied to protect individuals' rights and freedoms, and access is limited to those who need the information to carry out their official duties.
Some of the Schedule 1 conditions for processing special category and criminal offence data require an Appropriate Policy Document (APD) to be in place, which sets out and explains the procedures for securing compliance with the principles in Article 5 and policies regarding the retention and erasure of such personal data. This document explains this processing and satisfies the requirements of Schedule 1, Part 4 of the DPA 2018 and supplements this privacy notice.
Our Appropriate Policy Document provides further information about this processing.
How long we keep your personal data
Information recorded by the council's CCTV service is normally retained for a maximum of 31 days. After this period, recordings are automatically and securely overwritten.
Where there is a lawful basis to do so, specific recordings may be isolated from the standard retention cycle and retained for a longer period. This may include, but is not limited to, the prevention and detection of crime, public safety incidents, legal proceedings, insurance investigations, complaints, regulatory requirements, or where disclosure is required by law.
Any footage retained beyond the standard 31-day period will be kept only for as long as necessary to fulfil the purpose for which it has been secured
You can find details about how long the council keeps records at the council retention schedule.
Data sharing
We will only share your information where it is appropriate to, with:
- other CYC services
- other councils, government departments and agencies
- other organisations such as the NHS and the police
- third parties including our data processors, partners or contractors, who undertake work on our behalf
- retail and licensed premises who use ‘Storenet’ including SIA licensed operatives
- internal and external auditors
In some circumstances, such as under a court order or safeguarding, we are legally obliged to share information.
We will always satisfy ourselves that we have a lawful basis on which to share the information and document our decision-making.
Additionally, we are required under the Public Records Act 1958 (as amended) to transfer records to the City or National Archives (TNA) for permanent preservation. Full consideration will be given to Data Protection and Freedom of Information legislation when making decisions about whether such records should be open to the public.
Data processors and/or third parties
When we have third parties providing parts or all of our services, systems, software, platforms, applications (apps) etc for us, we have contracts or agreements in place with them. These include:
- Gough and Kelly’s policies and accreditations and Gough and Kelly's GDPR policy
- Security industry authority privacy notice
- National security inspectorate privacy notice
- The council’s use of Avada Connect Ltd in CCTV service, read the Avada Connect Ltd Privacy Policy
- the council's use of Canon (UK) Ltd as its main multi-functional print devices. You can find out how they use information in the Canon UK (Ltd) Privacy Notice
- Forvis Mazars, who provide external audit services to the council. See more information about Local Government Audits in England - Forvis Mazars
- the council’s use of Microsoft 365 as its main operating system and platform. Read the Microsoft Privacy Statement alongside our contract with Phoenix Software Limited, read the Phoenix Software Limited data protection page
- Microsoft Forms, as part of MS365. You can find out how they use your information in the Microsoft Privacy Statement
- Microsoft Teams, to contact you, to gather information from you, or if we are recording or transcribing our discussion or meeting with you, we will let you know. You can find more details about this in the City of York Council Microsoft Office 365 (MS365) Teams Meeting recording and transcription privacy notice
- Veritau Public Sector Limited (VPS), who provides services to the council such as internal audits. You can find out how they use your information in the Veritau Privacy Policy
- WhatsApp, to contact you. You can find out how they use your information in the WhatsApp Privacy Policy
- YouTube, where we provide information in British Sign Language via the City of York Council YouTube channel, please read YouTube Privacy Settings and Google Privacy Policies
- organisations to support the council’s corporate transformation programme such as Impower. Read the Impower Privacy Notice
Transfers of personal data
We do not routinely transfer personal data, special categories of personal data or criminal offence data, outside of the UK but when this is necessary, we ensure that we have appropriate safeguards in place and that is done in accordance with the UK data protection and privacy legislation.
How we protect your information
We're committed to keeping your information safe and secure. There are several ways we do this, such as:
- IT security safeguards such as firewalls, encryption, and anti-virus software
- on-site security safeguards to protect physical files and electronic equipment
- training for all staff and elected councillors
- policies and procedures
Your rights in relation to this processing
To find out about your rights under data protection law, you can go to the Information Commission's Office website.
You can also find information about your rights in our Privacy Notice.
If you have any questions about this privacy notice, want to exercise your rights, or if you have a complaint about how your information has been used, please contact us on email: information.governance@york.gov.uk, or on telephone: 01904 555719, or write to:
Data Protection OfficerCity of York Council
West Offices
Station Rise
York YO1 6GA