CLAYHALL EXECUTIVE CARS LTD

Vehicle CCTV & Telematics Privacy Notice

Effective Date: 2 July 2026

Review Date: 2 July 2027

 

1. Introduction

Clayhall Executive Cars Ltd is committed to protecting the privacy of everyone who travels in our vehicles or whose personal information may be captured by our vehicle CCTV and telematics systems. Our vehicles are fitted with Kasava CCTV and telematics systems to support passenger safety, safeguarding, security and the safe operation of our transport services.

This Privacy Notice explains:

• what information we collect;
• why we collect it;
• how we use it;
• who we may share it with;
• how long we keep it; and
• your rights under UK data protection law.

 

2. Who We Are

Clayhall Executive Cars Ltd is the Data Controller for personal information collected through our vehicle CCTV and telematics systems. If you have any questions about this Privacy Notice or wish to exercise your data protection rights, please contact us using the details below.

Contact Details

Clayhall Executive Cars Ltd

3 Seven Ways Parade
Woodford Avenue
Gants Hill
Ilford
Essex
IG2 6XH

Telephone: 020 8550 6767

Email: cecstaff@live.com

3. Our Vehicle CCTV & Telematics System

Our vehicles are equipped with Kasava vehicle technology.

Depending upon the vehicle, the system may record:

• forward-facing video;
• rear-facing video;
• in-cabin video;
• GPS location;
• vehicle movement;
• journey history;
• date and time information;
• driving event information.

Audio recording is not routinely enabled. Where audio recording functionality exists, it will only be activated where there is a lawful and legitimate reason to do so, such as protecting life, responding to a serious safeguarding concern or complying with a legal obligation.

 

4. Why We Use CCTV & Telematics

The safety and wellbeing of our passengers is always our primary consideration.

We use vehicle CCTV and telematics to:

• protect passengers;
• support safeguarding;
• protect Drivers and Passenger Assistants;
• investigate accidents and collisions;
• investigate complaints;
• investigate safeguarding concerns;
• assist with insurance claims;
• protect against false allegations;
• prevent and detect crime;
• protect Company vehicles and property;
• improve road safety;
• support operational management.

 

5. What Personal Information We Collect

Depending on the circumstances, we may collect:

• CCTV images;
• video recordings;
• images of passengers;
• images of Drivers and Passenger Assistants;
• images of parents, carers, school staff or visitors entering the vehicle;
• images of members of the public outside the vehicle;
• GPS location;
• journey information;
• vehicle movement;
• driving event information;
• date and time records.

Where CCTV captures identifiable individuals, those recordings may constitute personal data under the UK General Data Protection Regulation (UK GDPR).

 

6. Our Lawful Basis for Processing

We process information collected through vehicle CCTV and telematics systems under one or more lawful bases contained within the UK General Data Protection Regulation (UK GDPR).

These include:

• Legitimate Interests – to operate safe, secure and accountable transport services.
• Legal Obligation – where processing is necessary to comply with applicable laws, regulatory requirements or contractual obligations.
• Vital Interests – where processing is necessary to protect someone’s life or safety, particularly during emergencies or safeguarding incidents.

Where special category personal information is processed, we will do so only where an appropriate legal condition applies under the Data Protection Act 2018.

 

7. Who We May Share Information With

We will only share CCTV or telematics information where there is a lawful reason to do so.

This may include:

• Police forces;
• emergency services;
• insurers;
• legal advisers;
• courts and tribunals;
• local authorities;
• schools (where appropriate);
• safeguarding agencies;
• Transport for London (TfL);
• regulatory authorities.

We will never sell your personal information.

 

8. How Long We Keep Your Information

We retain CCTV footage and telematics information only for as long as necessary to fulfil the purposes for which it was collected. Routine CCTV footage is retained in accordance with the configured retention settings of our Kasava system.

Where footage is required for:

• safeguarding concerns; 
• accident or collision investigations; 
• insurance claims; 
• complaints; 
• disciplinary investigations; 
• legal proceedings; 
• Police investigations; or 
• regulatory enquiries, 

the relevant footage may be securely retained for longer until the matter has been concluded and any applicable legal or regulatory retention requirements have been met.

Further information is available within our Record Retention & Secure Disposal Policy.

 

9. How We Protect Your Information

We take the security of your personal information seriously. Only authorised personnel with a legitimate business need are permitted to access recorded information.

To protect CCTV and telematics information, we have implemented appropriate technical and organisational security measures, including:

• restricted access to recorded information; 
• secure user authentication; 
• password-protected systems; 
• controlled access permissions; 
• secure cloud storage provided through the Kasava platform; 
• staff training on confidentiality and data protection. 

 

10. Your Data Protection Rights

Under the UK General Data Protection Regulation (UK GDPR), you have a number of rights regarding your personal information.

These may include the right to:

• request access to your personal information; 
• request correction of inaccurate personal information; 
• request restriction of processing in certain circumstances; 
• object to processing where applicable; 
• request erasure where the legal conditions are met; 
• lodge a complaint with the Information Commissioner’s Office (ICO). 

Please note that some rights are subject to legal exemptions and may not apply in every situation.

 

11. Requesting CCTV Footage

If you believe you have been recorded by one of our vehicle CCTV systems, you may submit a Subject Access Request (SAR) to request access to your personal information. Before releasing any information, we may ask you to provide proof of your identity.

To help us locate the relevant footage, please provide as much information as possible, including:

• the date of the journey or incident; 
• the approximate time; 
• the vehicle registration (if known); 
• the journey details; 
• any other relevant information. 

 

12. When We May Not Be Able to Provide Footage

While we will always consider requests fairly, there are occasions where we may be unable to provide CCTV footage in full.

For example, where the footage:

• contains images of other identifiable individuals; 
• may prejudice an ongoing investigation; 
• contains legally privileged information; 
• is subject to an exemption under the UK GDPR or the Data Protection Act 2018. 

Where appropriate, we may instead:

• provide footage with third parties blurred or redacted; 
• provide still images instead of video; 
• explain why certain information cannot be disclosed. 

Our aim is always to balance your rights with the privacy rights of other individuals.

13. Automated Decision-Making

The CCTV and telematics systems used by Clayhall Executive Cars Ltd are not used to make automated decisions about passengers. While telematics information may assist with operational management, safeguarding, accident investigations or driver safety, decisions affecting individuals are always made by appropriately authorised members of staff.

 

14. International Transfers

CCTV footage and telematics information are normally stored within secure systems provided by our technology provider. Where personal information is transferred outside the United Kingdom, we will ensure that appropriate safeguards are in place to protect your information in accordance with UK data protection legislation.

 

15. Children’s Privacy

A significant proportion of our transport services are provided to children, including children with Special Educational Needs and Disabilities (SEND). We recognise our enhanced safeguarding and data protection responsibilities when processing children’s personal information. We process children’s personal information with particular care and only where there is a lawful basis for doing so.

Vehicle CCTV is operated primarily to:

• protect children during transport; 
• support safeguarding; 
• investigate incidents; 
• protect Drivers and Passenger Assistants; 
• assist schools, local authorities and emergency services where appropriate. 

 

16. Contacting Us

If you have any questions about this Privacy Notice or how Clayhall Executive Cars Ltd processes your personal information, please contact us using the details below. We will respond to requests and enquiries in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

 

Contact Details

Clayhall Executive Cars Ltd

3 Seven Ways Parade
Woodford Avenue
Gants Hill
Ilford
Essex
IG2 6XH

Telephone: 020 8550 6767

Email: cecstaff@live.com

 

17. Complaints

If you are unhappy with how we have handled your personal information, we encourage you to contact us first so that we have the opportunity to resolve your concerns. 

If you remain dissatisfied, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

Contact Details

Information Commissioner’s Office

Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline: 0303 123 1113

Website: https://ico.org.uk/

18. Changes to this Privacy Notice

Clayhall Executive Cars Ltd may update this Privacy Notice from time to time to reflect:

• changes in legislation; 
• guidance issued by the Information Commissioner’s Office; 
• changes to our business operations; 
• changes to our vehicle technology; 
• improvements to our information governance arrangements. 

The latest version will always be available on our website.

Where significant changes are made, we will take reasonable steps to make affected individuals aware.

19. Privacy at a Glance

Why do we use CCTV?

We use CCTV and telematics to:

• keep passengers safe; 
• support safeguarding; 
• investigate accidents and complaints; 
• protect Drivers and Passenger Assistants; 
• prevent and detect crime; 
• support insurance and legal claims; 
• improve road safety. 

 

What do we record?

Depending on the vehicle, we may record:

• video images; 
• vehicle location (GPS); 
• journey information; 
• driving events; 
• date and time information. 

Audio recording is not routinely enabled.

 

Who can access the footage?

Only authorised personnel with a legitimate business need may access recorded information.

Where necessary, footage may also be shared with organisations such as:

• Police; 
• insurers; 
• local authorities; 
• schools (where appropriate); 
• safeguarding agencies; 
• courts and regulators. 

 

How long is footage kept?

Routine CCTV footage is retained in accordance with the configured retention settings of our Kasava system.

Where footage is required for an investigation, complaint, safeguarding concern, accident, insurance claim or legal proceedings, it may be retained for longer in accordance with our Record Retention & Secure Disposal Policy.

 

Your Rights

You have the right to:

• request access to your personal information; 
• request correction of inaccurate information; 
• object to certain processing where applicable; 
• request restriction of processing in certain circumstances; 
• complain to the Information Commissioner’s Office. 

 

Need More Information?

If you have any questions about this Privacy Notice or wish to make a Subject Access Request, please contact Clayhall Executive Cars Ltd using the contact details provided in this notice.

 

Document Information

Document Title: Vehicle CCTV & Telematics Privacy Notice

Version: 1.0

Effective Date: 2 July 2026

Review Date: 2 July 2027

Document Owner: Director

Final Statement

Clayhall Executive Cars Ltd is committed to protecting the privacy and personal information of our passengers, parents, carers, employees, contractors and members of the public. Our use of vehicle CCTV and telematics is based on the principles of safety, safeguarding, transparency, accountability and respect for privacy. We continually review our practices to ensure that personal information is processed lawfully, fairly and securely while delivering safe, reliable and professional transport solutions.