Surveillance Policy

Closed Circuit Television (CCTV) refers to camera surveillance devices that capture images of people and activity, and includes other surveillance devices of the same or similar nature.

Surveillance by Ryman

CCTV is operated by Ryman and used throughout Ryman’s villages and construction sites to:

• help ensure the safety and security of our residents, staff, contractors, visitors and property;
• detect and deter criminal behaviour; and
• investigate and manage complaints, misconduct and challenging behaviour.

• help monitor and manage the work that is taking place; and
• visually connect our projects to people in our offices through live streaming of construction activity.

Any footage collected will be used solely for these purposes or as required or permitted by law.

Footage that sufficiently identifies individuals which is collected via CCTV is considered personal information and is therefore subject to the Privacy Act 2020 (the Privacy Act).

CCTV operates 24 hours a day, seven days a week. Footage of events and the movements of people will be captured. Ryman does not use any facial recognition technology or other ‘intelligent surveillance’ technology.

CCTV cameras are located throughout villages and construction sites but are not installed in bathrooms or other personal areas, including resident’s rooms.

Footage will not be linked to or accessible via any person’s file or records, except as set out below.

Footage collected via CCTV will be kept securely for up to 90 days. Stored footage can only be accessed by authorised Ryman managers and staff. It will only be reviewed if required to investigate an incident/complaint, if a security problem is identified, to review construction work that has taken place or as otherwise required or permitted by law. It will only be retained for longer than 90 days if needed for evidential purposes and, with the approval of the Privacy Officer, may be stored in the investigation file.

Covert surveillance devices may be used in exceptional circumstances; where management has strong grounds to suspect that theft or misconduct is occurring. In these circumstances a surveillance device may be installed and used without the knowledge of employees. Approval from Regional Management (for Operations) and National Management (for Construction) is required before a covert surveillance device may be installed. Consent will always be obtained from residents and their families before covert surveillance devices are used in residents’ rooms.

If any criminal behaviour is recorded via CCTV, the footage may be provided to the Police.

Surveillance by third parties

Surveillance devices (either visual or audio) installed and operated by a third party without Ryman’s knowledge and consent are prohibited in Ryman villages and on Ryman construction sites in any areas where the devices may:

• surveil or record Ryman staff without their knowledge or consent;
• surveil or record residents (or anyone else) without their knowledge or consent in such a way that is intrusive or breaches their privacy.

Ryman has the right to immediately disconnect any such devices, and ask that they be removed effective immediately, in reliance on the following grounds:

1. clauses 2.3(e), 2.2(f) and 2.2(g) of Ryman’s standard-form resident occupation agreement used in Ryman villages;

2. a breach of the information privacy principles under the Privacy Act, and provisions in the Privacy Act requiring Ryman to protect the privacy of its employees and safeguard personal information collected about them;

3. offences within the Crimes Act 1961 relating to the interception of private communications and intentionally making intimate visual recordings of another person;

4. protections afforded to residents under the Protection of Personal and Property Rights Act 1988; and

5. the age related resident care (ARRC) agreements between Ryman and the DHBs, which require Ryman to protect the dignity and privacy of residents.

Questions/complaints

If you have any questions or complaints about the use of CCTV or other surveillance devices within Ryman’s villages or construction sites, please contact Ryman’s Privacy Officer.