Privacy & Body-Worn Camera Policy

1. Personal Information We May Collect

Depending on your dealings with Vanta Tiling, we may collect information such as your name, telephone number, email address, project/property address, quotation and invoice information, correspondence, project instructions, photographs of the work area, and information reasonably required to provide our services.

Where a body-worn camera is used, personal information may also include images and, where justified and enabled, audio of people who are present in or around the work area.

2. Why We Use Personal Information

We may use personal information to respond to enquiries and prepare quotations; arrange and carry out agreed works; communicate about a project; purchase or arrange materials; issue invoices and maintain accounting records; document existing site conditions and the progress or completion of works; protect property and establish what occurred if an incident, allegation or damage occurs; deal with complaints, insurance matters and legal disputes; comply with legal, regulatory, tax and insurance requirements; and establish, exercise or defend legal claims.

3. Lawful Bases

We process personal information only where we have an appropriate lawful basis under applicable UK data-protection law.

Depending on the circumstances, this may include processing necessary to perform a contract or take steps at a customer's request before entering into a contract, compliance with a legal obligation, or our legitimate interests.

Where we rely on legitimate interests, these may include documenting work and site conditions, protecting Vanta Tiling and customers against disputed allegations or damage, maintaining appropriate business and insurance records, improving accountability, and establishing, exercising or defending legal claims. We consider whether the processing is necessary and proportionate and whether the individual's rights and interests override those interests.

Consent will be used where consent is the appropriate lawful basis. Consent is not treated as the default legal basis for all body-worn video recording.

4. Body-Worn Camera Use

Vanta Tiling may use a body-worn camera during certain stages of installation or associated works.

The principal purpose is to create an objective record of relevant site conditions and work being undertaken, particularly where such evidence may reasonably be required for insurance, property-damage, safety, complaint or dispute purposes.

The camera is not intended for general or covert surveillance of customers, occupants or visitors. Recording should be limited to what is reasonably necessary for the identified purpose and, where practicable, focused on the work area rather than individuals.

We will take reasonable steps to inform affected people before recording begins or make it otherwise clear when recording is taking place. This may include a verbal notification, a visible camera/recording indicator, signage, or directing people to this policy.

Recording should not normally take place in circumstances where a person would reasonably expect a particularly high level of privacy unless there is a compelling and lawful reason to do so.

5. Audio Recording

Audio is more intrusive than video alone. Where the equipment allows audio and video to be controlled separately, audio should normally remain disabled unless recording sound is reasonably necessary and proportionate for the particular purpose.

If the equipment cannot record video without audio, Vanta Tiling will consider whether recording both is justified before using the device in the circumstances.

6. Children, Visitors and Other People

Work may occasionally take place where family members, visitors, neighbours, other tradespeople or children are present.

Vanta Tiling will take reasonable steps to minimise unnecessary recording of people who are not relevant to the work. Particular care will be taken where children or other vulnerable individuals may be captured.

Customers are encouraged to tell other occupants or visitors that body-worn video may be used while work is taking place.

7. Storage and Security of Body-Worn Footage

Body-worn footage will be protected against unauthorised access, loss, disclosure or alteration using appropriate technical and organisational security measures.

Access will be limited to Vanta Tiling and, where necessary, authorised service providers or recipients who have a legitimate need to access the footage.

Where supported by the equipment or storage service, appropriate measures such as access controls, passwords and encryption will be used. Footage will not ordinarily be copied to personal social-media accounts or made publicly available.

8. Retention and Deletion

Routine body-worn footage that is not required for an incident, complaint, insurance matter or legal purpose will normally be deleted within 14 days after completion of the relevant work, or sooner where it is no longer necessary.

Relevant footage may be isolated from routine recordings and retained for longer where it is reasonably necessary for an actual or reasonably anticipated complaint, insurance claim, property-damage issue, legal claim, regulatory matter or other documented purpose.

In those circumstances, the footage will be reviewed and deleted when the relevant purpose no longer applies, subject to any applicable legal, insurance or evidential retention requirement.

Vanta Tiling will not retain body-worn footage indefinitely merely because it might possibly be useful in the future.

9. Sharing Body-Worn Footage

Footage will not normally be shared with third parties unless there is a legitimate and lawful reason.

Where necessary and permitted by law, footage may be shared with insurers, insurance investigators, legal advisers, courts, law-enforcement authorities, regulators, data-protection authorities, relevant contractors or service providers, or other parties where reasonably necessary to establish, exercise or defend legal rights.

Before disclosure, consideration will be given to the privacy rights of other identifiable people appearing in the footage. Where appropriate, footage may need to be redacted, blurred, muted or otherwise limited before disclosure.

10. Photographs and Other Project Images

Vanta Tiling may take photographs or videos of the work area to document existing conditions, installation stages, completed work, defects, damage or other project matters.

Operational or evidential photographs are treated separately from promotional use. Identifiable images will not automatically be used for advertising or social-media purposes merely because they were collected to document a project.

Where images are used for marketing, reasonable steps will be taken to avoid unnecessarily identifying customers, occupants or private personal information and to obtain permission where appropriate.

11. Other Personal Data Retention

Business records such as quotations, invoices, payment records and project correspondence may be retained for periods appropriate to contractual, tax, accounting, insurance and legal requirements.

Different categories of information may therefore be kept for different periods. We periodically consider whether information remains necessary and securely delete or anonymise it when it is no longer required.

12. Your Data-Protection Rights

Depending on the circumstances and the lawful basis being used, individuals may have rights in relation to their personal information, including rights of access, rectification, erasure, restriction of processing, data portability and objection.

In particular, where Vanta Tiling relies on legitimate interests, you have the right to object to processing based on your particular situation. This right does not necessarily require processing to stop where there are compelling legitimate grounds or where the information is required for legal claims.

A person who believes they have been recorded may request access to personal information relating to them. Sufficient information may be required to locate the relevant footage, such as the date, approximate time, property/project and description of the circumstances.

Where footage also contains personal information relating to other people, it may be necessary to redact or restrict parts of the footage before providing access.

13. Requests About Your Information

To exercise a data-protection right or ask a question about how Vanta Tiling uses personal information, contact:

We may need to verify identity before releasing personal information. Requests will be handled within the time limits required by applicable data-protection law.

14. Complaints to the ICO

If you have concerns about how your personal information has been handled, please contact Vanta Tiling first so that we have an opportunity to investigate.

You also have the right to raise a concern with the Information Commissioner's Office (ICO), the UK regulator for data protection.

15. Data Protection Impact Assessment and Review

Before routinely deploying body-worn video, Vanta Tiling will assess the privacy risks associated with the system and its intended use, including through a Data Protection Impact Assessment where required or appropriate.

The use of body-worn video, its security, retention period and this policy will be reviewed periodically and when there is a material change to the technology or the way it is used.

16. Changes to This Policy

This policy may be updated from time to time to reflect changes in Vanta Tiling's services, technology, working practices or legal and regulatory requirements.

The current version will be made available through the Vanta Tiling website or on request.