Wandgas Sports and Social Club Ltd
Closed Circuit Television Policy
Several pieces of legislation govern the operation of Closed Circuit Television (“CCTV”) systems. It is therefore essential for the correct procedures to be followed in relation to CCTV, as described in this policy.
- The CCTV Scheme
CCTV is used for the following purposes :
- the prevention and detection of crime;
- dealing with and resolving complaints and disciplinary matters;
- defending and/or exercising the Company’s legal rights;
- public and employee safety; and
- compliance with licensing conditions, where appropriate
- Camera Locations
Camera locations must adhere to the following principles:-
- cameras should only be able to monitor public areas (which includes areas
used only by staff such as kitchen/behind bar but excludes private areas like changing rooms or toilet cubicles)
- Quality of Images
The images produced by the system should be as clear as possible. Therefore, we will:-
- periodically check digital systems (where applicable) to ensure the recording
quality has not deteriorated;
- ensure accuracy of the system’s date and time references, where provided,
and these should be checked monthly; and
- regularly maintain the system and protect it against vandalism or damage to
ensure it remains in working order.
- Processing of Images
Images recorded by the system should not be retained for longer than necessary and while images are retained, it is essential that their integrity is maintained and that they are kept securely. Therefore:-
- we will not retain images for longer than is necessary. Except where the
images might be required in legal proceedings.
- when the retention period has expired we will ensure that the images are erased;
- if images are retained (e.g. in connection with a complaint or query), they should be removed from the system and stored in the safe;
- access to the CCTV equipment and recording medium (where applicable) must be restricted to management and it should be kept in a restricted area;
- if images are removed, the removal must be documented
- Access to and Disclosure of Images to Third Parties
It is important that access to and disclosure of the images recorded by the system are carefully controlled, because we have an obligation to protect the privacy of everyone who appears on the CCTV footage, not just the person asking to see it. The Directors will only ever give permission for footage to be released when the reason it is requested is compatible with the reason for which the images were recorded (e.g. crime).
We will ensure that employee access to images is restricted to only those who need it. Staff should not be shown CCTV images unless they need to see them (e.g. to help the police identify someone). Management and Directors may also see CCTV images to the extent necessary for disciplinary procedures.
If the police request CCTV we must obtain a record of receipt (signed where possible) when the footage are handed over the police and you must complete an electronic Incident Report Form with as much detail as possible about the police request, including crime number (where applicable) and details of the police officer(s) name, collar number and contact details. If a data subject is identified by the police, this should also be recorded. If the police collect CCTV footage at a later date, then you must update the original Incident Report Form to reflect this.
Except for requests from the police, only the Directors may approve a request for CCTV images.
- Access by the Data Subject
The data protection legislation gives data subjects the right of access to images of them stored by the Company in certain circumstances. If we are asked to provide CCTV footage to someone, you must take the following steps:-
- Pass the request to the Directors immediately. UNDER NO CIRCUMSTANCES ARE STAFF AUTHORISED TO GIVE OUT COPIES OF CCTV FOOTAGE TO ANYONE OTHER THAN THE POLICE or Responsible Authority
- Immediately burn a CD containing the images in question and retain them in the safe. Do not hand them over to the person who has requested them, contact the Directors.
- On receipt of a request, the Directors will assess whether the request can be granted or not.
- Legally, anyone who requests CCTV footage must receive a response to their request within one month of making it, so it is critical that you contact the Directors immediately if you are asked to provide CCTV images to anyone other than the police.
- Requests to Prevent Processing
We recognise that, in rare circumstances, individuals may have a legal right to object to processing and in certain circumstances to prevent automated decision making (see Articles 21 and 22 of the General Data Protection Regulation). For further information regarding this, please contact the Directors.
- Remote Viewing
For security purposes images are available from a mobile phone. This facility is limited to the following people:-
- Bar Manager
- Hudson Security
Closed Circuit Television Operation Guide
This supplemented guide is intended to give further guidance on the responsibilities and practicalities of operating your CCTV system to ensure compliance with the CCTV policy.
The Bar Manager is responsible for ensuring that:-
- The CCTV system is working correctly at all times
- All cameras are recording
- The monitors are always switched on
- In the event of a fault the matter is reported immediately to Hudson Security on 07795 160975
- Access to the CCTV equipment is restricted to the Bar Manager and the equipment is kept in a restricted area (i.e. the office, which should be locked)
- As part of the daily opening procedure, a spot check is made to ensure that the system is recording correctly and on all cameras. This should be done by rewinding the system to a certain place and then checking the recording quality
- Daily checks are carried out to ensure that the cameras have not been tampered with or moved and that all cameras are recording
- If images are retained (e.g. in connection with a complaint or query), they should be removed from the system and stored in a duty safe
- If the system features date and time references, that these are accurate. The time should be checked monthly by telephoning the speaking clock and of course, must be changed immediately at the end and beginning of British Summer Time
- Make sure all maintenance visits are completed according to the schedule provided by the Bar Manager.