The Club uses closed circuit television (CCTV) images to provide a safe and secure environment for members and visitors to the Clubs’ premises, and to protect the Club’s property.
The Club is registered with the Information Commissioners office as a data controller reg No: ZA099214.
This policy sets out the use and management of the CCTV equipment and images in compliance with the General Data Protection Regulations (GDPR) and the CCTV Code of Practice.
The Club’s CCTV facility records images only. There is no audio recording i.e. conversations are not recorded on CCTV.
Purposes of CCTV
The purposes of the Club installing and using CCTV systems include:
- To assist in the prevention or detection of crime or equivalent malpractice.
- To assist in the identification and prosecution of offenders.
- To monitor the security of the Clubs’ premises.
- To ensure that safety rules and Club procedures are being complied with.
- To assist with the identification of unauthorised actions or unsafe practices that might result in disciplinary proceedings being instituted against members and to assist in providing relevant evidence.
Location of cameras
Cameras are located at strategic points throughout the Club’s premises, principally at the entrance and exit points. The Club has positioned the cameras so that they only cover communal or public areas on the premises and they have been sited so that they provide clear images. No camera focuses, or will focus, on toilets, shower facilities or changing rooms.
All cameras are also clearly visible.
Appropriate signs are prominently displayed so that members and visitors are aware they are entering an area covered by CCTV.
Recording and retention of images
Images produced by the CCTV equipment are intended to be as clear as possible so that they are effective for the purposes set out above. Maintenance checks of the equipment are undertaken on a regular basis to ensure it is working properly and that the media is producing high quality images.
Images may be recorded either in constant real-time (24 hours a day throughout the year), or only at certain times, as needs dictate.
As the recording system records digital images, any CCTV images that are held on the hard drive of a PC or server are deleted and overwritten on a recycling basis and, in any event, are not held for more than 8 days. Once a hard drive has reached the end of its use, it will be erased prior to disposal.
Images that are stored on, or transferred on to, removable media such as CDs are erased or destroyed once the purpose of the recording is no longer relevant. However, where a law enforcement agency is investigating a crime, images may need to be retained for a longer period.
Access to and disclosure of images
Access to, and disclosure of, images recorded on CCTV is restricted. This ensures that the rights of individuals are retained. Images can only be disclosed in accordance with the purposes for which they were originally collected.
The images that are filmed are recorded centrally and held in a secure location. Access to recorded images is restricted to the operators of the CCTV system and Club officials who are authorised to view them in accordance with the purposes of the system. Viewing of recorded images will take place in a restricted area to which other members will not have access when viewing is occurring. If media on which images are recorded are removed for viewing purposes, this will be documented.
Monitoring of CCTV images may be carried out remotely by authorised officers of the club.
Disclosure of images to other third parties will only be made in accordance with the purposes for which the system is used and will be limited to:
- The police and other law enforcement agencies, where the images recorded could assist in the prevention or detection of a crime or the identification and prosecution of an offender or the identification of a victim or witness.
- Prosecution agencies, such as the Crown Prosecution Service.
- Relevant legal representatives.
- Individuals whose images have been recorded and retained (unless disclosure would prejudice the prevention or detection of crime or the apprehension or prosecution of offenders).
The Chairman (or another officer of the club acting in their absence) is the only person who is permitted to authorise disclosure of images to external third parties such as law enforcement agencies.
All requests for disclosure and access to images will be documented, including the date of the disclosure, to whom the images have been provided and the reasons why they are required. If disclosure is denied, the reason will be recorded.
Individuals’ access rights
Under the GDPR, individuals have the right on request to receive a copy of the personal data that the Club holds about them, including CCTV images if they are recognisable from the image.
If you wish to access any CCTV images relating to you, you must make a written request to the Club’s Data Protection Officer. Your request must include the date and approximate time when the images were recorded and the location of the particular CCTV camera, so that the images can be easily located and your identity can be established as the person in the images. The Club will respond promptly and in any case within 30 calendar days of receiving the request. The data protection officer can be reached by email at DPO1066RPC@Yahoo.com or in writing at 1066 Rifle & Pistol Club, Rock Lane, Hastings, East Sussex,TN35 4NY.
The Club will always check the identity of the person making the request before processing it.
The Data Protection Officer will first determine whether disclosure of your images will reveal third party information as you have no right to access CCTV images relating to other people. In this case, the images of third parties may need to be obscured if it would otherwise involve an unfair intrusion into their privacy.
If the Club is unable to comply with your request because access could prejudice the prevention or detection of crime or the apprehension or prosecution of offenders, you will be advised accordingly.
The Club will ensure that all members handling CCTV images or recordings are trained in the operation and administration of the CCTV system and on the impact of the GDPR with regard to that system.
The Club’s Data Protection Officer is responsible for the implementation of and compliance with this policy and the operation of the CCTV system and will conduct a regular review of the Club’s use of CCTV. Any complaints or enquiries about the operation of the Club’s CCTV system should be addressed to him.
Version number 1.0 by Mark Cobb 19th May 2018.