Benana Music Studios Ltd
Effective date: July 2026
Version: 2.0
Last reviewed: July 2026
1. Policy Statement
Benana Music Studios Ltd (“Benana”, “we”, “our” or “us”) operates CCTV at certain premises used for its music teaching activities. CCTV is used to support the safety and security of students, parents and guardians, staff, teachers, contractors and visitors; support safeguarding; protect people, premises and property; and assist with the investigation of specific incidents.
Benana Music Studios Ltd is the data controller for CCTV processing carried out for the purposes of Benana’s operations at its teaching locations. Benana determines why the CCTV is used and makes decisions about access to, use, disclosure and retention of footage.
The CCTV service is provided and maintained by Zappie Ltd. CCTV footage is stored locally on Network Video Recorder (NVR) systems at the relevant premises. Zappie Ltd may have limited remote technical access where necessary to maintain, troubleshoot or support the system.
Benana’s CCTV system operates through a single CCTV account covering multiple locations. CCTV operated for the purposes of Pure Rehearsal Studios Ltd at Pure Rehearsal Studios is subject to separate data protection responsibilities and is covered separately by Pure Rehearsal Studios Ltd.
This policy explains how Benana uses and manages CCTV in accordance with applicable UK data protection law, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Data (Use and Access) Act 2025.
Our primary lawful basis for CCTV processing is our legitimate interests under Article 6(1)(f) UK GDPR. These interests include maintaining a safe and secure teaching and working environment, supporting safeguarding, protecting people and property, managing premises and investigating specific incidents.
We have carried out a Legitimate Interests Assessment (LIA) and a Data Protection Impact Assessment (DPIA) to assess the necessity and proportionality of our CCTV use and its impact on the rights and freedoms of individuals.
The use of CCTV does not replace or reduce the importance of other safeguarding measures, policies, procedures or codes of conduct.
2. Scope
This policy applies to CCTV systems operated by Benana Music Studios Ltd at its teaching locations.
It applies to personal information captured about:
- students;
- children and young people;
- parents and guardians;
- staff;
- teachers;
- contractors;
- visitors; and
- other individuals entering monitored areas.
This policy covers recorded video, recorded audio where enabled, live camera views, exported CCTV clips and still images or screenshots taken from CCTV footage.
3. Purposes of CCTV
Benana uses CCTV only for specified and legitimate purposes, which may include:
- promoting the safety and security of students, staff, teachers, contractors and visitors;
- supporting safeguarding, particularly in environments where children and young people receive one-to-one tuition;
- providing an objective record where a safeguarding concern, complaint, allegation or incident arises;
- supporting the safety of teachers and other individuals who may be lone working;
- deterring and investigating theft, vandalism, unauthorised access, misconduct, abuse or other inappropriate behaviour;
- protecting premises, equipment and other property;
- investigating accidents, health and safety incidents, complaints or other specific concerns;
- verifying what occurred during a particular lesson or incident where there is a legitimate reason to investigate;
- investigating suspected misconduct or a specific failure to follow procedures;
- checking whether premises are secure;
- investigating maintenance, environmental or property-related issues;
- monitoring specific environmental conditions, such as recording evidence of room temperature, where reasonably necessary for health and safety, property management or discussions with a landlord or other responsible party;
- supporting insurance claims, legal proceedings or regulatory investigations; and
- establishing, exercising or defending legal claims.
CCTV is not used for routine supervision of teaching, routine monitoring of staff performance or continuous observation of staff, teachers or students.
However, relevant footage may be accessed and reviewed where a specific complaint, safeguarding concern, suspected misconduct, incident, safety concern or other legitimate matter requires investigation.
4. CCTV Locations
Queens Terrace – City Centre
Benana operates two CCTV cameras:
- one in Studio 1; and
- one in Studio 2.
These cameras record video and audio.
The wider Queens Terrace building may also contain CCTV operated independently by the building owner or manager. Benana does not control CCTV systems operated independently by the building owner or manager, and those systems are not covered by this policy.
Bitterne Park – Dimond Road
Benana operates four CCTV cameras covering:
- three teaching rooms; and
- the corridor.
These cameras record video and audio.
Shirley
Benana does not currently operate CCTV at its Shirley teaching location.
If CCTV is introduced at this or any other location, we will assess the proposed use before deployment and update our privacy information, signage, DPIA, LIA and this policy where appropriate.
Pure Rehearsal Studios
CCTV is also in operation at Pure Rehearsal Studios. CCTV operated for the purposes of Pure Rehearsal Studios Ltd is covered by separate CCTV and privacy information.
Where Benana provides lessons or activities at Pure Rehearsal Studios, students, parents, staff, teachers and visitors may be captured by CCTV operating at those premises.
5. CCTV in Teaching Rooms and Safeguarding
Some CCTV cameras are located in teaching rooms.
The use of CCTV in teaching rooms reflects the particular circumstances of music tuition, including that:
- many students are children or young people;
- lessons are frequently delivered on a one-to-one basis;
- teachers may work alone with individual students;
- teachers may be lone working; and
- CCTV may provide an objective record if a safeguarding concern, complaint, allegation or other serious incident arises.
The presence of CCTV does not replace appropriate safeguarding practices, safer working procedures, staff training, professional boundaries or other safeguarding controls.
CCTV footage is not routinely watched for the purpose of supervising individual lessons.
Where a parent, guardian or other individual has concerns about CCTV, they may contact us using the details in Section 17. Any objection will be considered in accordance with applicable data protection law and the circumstances of the processing.
6. Audio Recording
CCTV cameras at Benana’s monitored locations currently record both video and audio.
Audio recording is more privacy-intrusive than video recording and is therefore subject to additional consideration within our Data Protection Impact Assessment and Legitimate Interests Assessment.
We keep the use of audio recording under review and assess whether it remains necessary and proportionate for the purposes for which the CCTV system is operated.
Where audio is recorded:
- clear signage informs individuals that video and audio recording are in operation;
- access is restricted to authorised individuals;
- recordings are not routinely listened to or monitored;
- audio is accessed only where there is a legitimate and proportionate reason to review the relevant recording; and
- recordings are subject to the same security, access and retention controls as CCTV video footage.
7. How the CCTV System Operates
Benana’s CCTV system records 24 hours a day, seven days a week at locations where cameras are installed.
CCTV footage is not routinely monitored live.
The authorised Directors may access both live camera views and recorded footage remotely through a secure application where there is a legitimate operational, security, safeguarding or incident-related reason to do so.
Examples may include:
- responding to a security concern;
- checking whether premises are secure;
- investigating a specific incident;
- responding to a safeguarding or safety concern;
- investigating a maintenance or property issue; or
- obtaining specific evidence of environmental conditions, such as room temperature.
Remote access does not mean that staff, teachers, students or premises are continuously or routinely monitored.
8. Access to CCTV
Direct access to Benana’s CCTV system is restricted to:
- Ben Faux, Director;
- Anna Supova, Director; and
- authorised Zappie Ltd technical personnel where access is necessary for system maintenance, troubleshooting or technical support.
The Operations Manager, administrative staff, teachers and safeguarding personnel do not have routine direct access to the CCTV system.
Where appropriate, relevant footage may be shown or disclosed to the Designated Safeguarding Lead or another appropriate safeguarding professional where this is necessary and lawful in connection with a safeguarding matter.
Access to CCTV footage must be limited to what is necessary for the relevant purpose.
9. Staff, Teacher and Contractor Investigations
CCTV is not used for routine staff surveillance, continuous performance monitoring or routine supervision of teachers or contractors.
However, footage may be reviewed where there is a specific and legitimate reason, including to:
- investigate a complaint;
- investigate suspected misconduct;
- investigate a safeguarding concern or allegation;
- verify what occurred during a particular lesson or incident;
- investigate a suspected failure to follow an important safety, safeguarding or operational procedure; or
- establish, exercise or defend legal claims.
Any such access must be necessary and proportionate to the matter being investigated and must be handled confidentially.
10. Areas Where CCTV Is Not Used
Benana does not install CCTV in toilets or other areas where individuals would reasonably expect a particularly high degree of privacy.
Camera positioning is reviewed to ensure that surveillance is limited to areas reasonably necessary for the purposes described in this policy.
11. Storage and Security
CCTV footage is stored locally on password-protected NVR systems located at the relevant premises.
Footage is not routinely stored in cloud storage by the CCTV system.
Access to the CCTV system, live views, recorded footage and system settings is restricted to authorised individuals.
Benana applies appropriate technical and organisational measures to protect CCTV information, including:
- password-protected access;
- restricted user access;
- secure remote access;
- local NVR storage;
- limited access to exported footage and screenshots; and
- secure deletion when information is no longer required.
Zappie Ltd may have remote technical access where necessary to maintain, troubleshoot or support the system.
Where CCTV footage, clips or screenshots are exported from the main CCTV system, they must be handled securely and access must be restricted to those who require the information for the relevant purpose.
12. Retention
CCTV footage is normally retained for a maximum of approximately 28 days and is then automatically overwritten.
Footage may be exported and retained for longer where it is reasonably necessary for a specific purpose, including:
- a safeguarding matter;
- an incident investigation;
- a complaint;
- suspected misconduct;
- an accident or health and safety matter;
- a police or other official investigation;
- an insurance claim;
- a property or landlord matter;
- legal proceedings; or
- the establishment, exercise or defence of legal claims.
Where footage is retained beyond the normal retention period, it will be kept only for as long as reasonably necessary for the relevant matter and securely deleted when it is no longer required.
13. CCTV Screenshots and Still Images
Benana may occasionally create a screenshot or still image from CCTV footage where reasonably necessary for one of the purposes described in this policy.
This may include evidence relating to:
- a specific incident;
- safeguarding;
- security;
- health and safety;
- environmental conditions, including temperature;
- maintenance or property issues;
- landlord discussions;
- insurance matters; or
- legal or regulatory matters.
Screenshots and still images are treated as personal information where an individual is identifiable.
Where screenshots are temporarily stored on an authorised Director’s device, they must be kept only for as long as necessary for the relevant purpose and deleted when no longer required.
14. Disclosure of CCTV Footage
CCTV footage will not be disclosed to third parties routinely.
Where necessary, proportionate and lawful, relevant footage may be shared with:
- the police or other law enforcement bodies;
- insurers;
- courts or tribunals;
- solicitors and other professional legal advisers;
- local authority safeguarding teams;
- the Local Authority Designated Officer (LADO);
- social services or other relevant safeguarding bodies;
- the Information Commissioner’s Office or another regulator;
- other public authorities where disclosure is required or permitted by law; or
- other parties where necessary for the establishment, exercise or defence of legal claims.
Before disclosing CCTV footage, we will consider the purpose of the request, the lawful basis for disclosure, the rights and privacy of other individuals captured in the footage, and whether disclosure is necessary and proportionate.
15. Individual Rights and Subject Access Requests
CCTV footage and audio recordings may constitute personal information where an individual can be identified.
Under UK data protection law, individuals may have rights in relation to CCTV information about them, including the right to request access to their personal information and, in certain circumstances, to object to or request restriction of processing.
Requests relating to Benana CCTV should be sent to:
benanamusicstudio@gmail.com
To help us locate relevant footage, we may ask the requester to provide information such as:
- the date and approximate time;
- the location;
- a description of themselves; and
- other information reasonably necessary to identify the relevant footage.
We may request reasonable evidence of identity where necessary to ensure that personal information is not disclosed to the wrong person.
When responding to a request, we will carry out reasonable and proportionate searches as required by data protection law.
CCTV footage may contain personal information relating to other individuals. Before disclosing footage in response to a request, we will consider the rights and privacy of those individuals. Where necessary, we may blur, redact or otherwise obscure identifiable third parties before disclosure, or use another appropriate method to protect their personal information.
In some circumstances, we may provide still images, extracts or other appropriate information instead of the original unedited footage. We may also withhold information where disclosure would adversely affect the rights and freedoms of another person and it is not reasonable or lawful to disclose it.
A request will not be refused solely because footage contains other individuals. Each request will be considered individually in accordance with applicable data protection law.
We will respond within the timeframes required by data protection law, normally within one month.
16. Signage and Transparency
Appropriate CCTV signage is displayed at monitored premises and in or around relevant monitored areas.
Signage is designed to inform individuals, as appropriate, that:
- CCTV is in operation;
- video and audio are recorded where applicable;
- the purpose of the surveillance;
- the identity of the relevant data controller; and
- how to obtain further information or contact us.
Further information about our use of personal information is available in the Benana Music Studios Ltd Privacy Notice.
17. Data Protection Complaints and Contact Details
Questions, requests, objections or complaints about Benana’s use of CCTV should be sent to:
Benana Music Studios Ltd
Email: benanamusicstudio@gmail.com
Telephone: 07728 836428
Address: 33 Queens Terrace, Southampton, England, SO14 3QB
We will handle data protection complaints in accordance with our data protection complaints procedure and applicable data protection law.
If you remain dissatisfied with how we have handled your personal information, you have the right to complain to the Information Commissioner’s Office (ICO).
18. Governance, DPIA and Legitimate Interests Assessment
Benana maintains a Data Protection Impact Assessment and Legitimate Interests Assessment covering its use of CCTV.
These assessments consider matters including:
- the purposes of the CCTV system;
- the use of cameras in teaching rooms;
- the recording of children and young people;
- one-to-one teaching and safeguarding;
- audio recording;
- 24-hour recording;
- remote access;
- camera locations and positioning;
- access controls;
- retention;
- subject access requests;
- staff, teacher and contractor privacy;
- operational uses of CCTV;
- screenshots and exported footage; and
- the availability of less intrusive alternatives.
The DPIA and LIA will be reviewed regularly and whenever there is a significant change to the CCTV system, including:
- the installation of new cameras;
- a change in camera location;
- a new purpose for surveillance;
- a significant change in technology;
- a change to audio recording;
- a change in retention;
- a significant change in access arrangements; or
- a change in applicable law or regulatory guidance.
The Directors, Ben Faux and Anna Supova, are jointly responsible for oversight of CCTV compliance.
19. Service Providers and Equipment
Zappie Ltd provides and maintains the CCTV service and may have limited remote technical access where necessary for maintenance, troubleshooting or support.
CCTV equipment is subject to separate equipment financing or ownership arrangements. Those commercial arrangements do not, by themselves, determine responsibility for the processing of personal information.
Benana will ensure that appropriate data protection arrangements are in place with service providers that process personal information on its behalf.
20. Review of This Policy
This policy will be reviewed at least annually and sooner where:
- CCTV technology or equipment changes;
- cameras are added, removed or repositioned;
- the purposes for which CCTV is used change;
- audio recording arrangements change;
- there is a significant incident or complaint;
- the DPIA or LIA identifies a need for change; or
- applicable law or regulatory guidance changes.
Policy owner: Benana Music Studios Ltd
Responsible for oversight: The Directors
Version: 2.0
Last reviewed: July 2026
Contact:
For questions or data access requests, contact:
Benana Music Studio Ltd, Pure Rehearsal Studios Ltd
benanamusicstudio@gmail.com, booking@purerehearsal.co.uk
