Introduction
The purpose of this Policy is to regulate the management, operation and use of the closed circuit television (CCTV) system at Yorkshire Dales SC. The system comprises of a number of fixed cameras located on the gable ends of the top dinghy store and clubhouse. Cameras are controlled from the top dinghy store or via remote access and the system can only be accessed by the nominated Security Officer or Alarm call out key holders. The Club owns the CCTV system. The Policy will be subject to review by the Committee. This Policy follows the Data Protection Act guidelines.
Objectives of the CCTV Policy
The objectives of the Club’s use of CCTV are:
a) To help protect the club buildings, equipment and members’ property stored at the club
b) To support the Police in a bid to deter and detect crime
c) To assist in identifying, apprehending and potentially prosecuting offenders
Statement of Intent
The CCTV Scheme has been registered with the Information Commissioner under the terms of the Data Protection Act 1998 and will seek to comply with the requirements both of the Data Protection Act and the Commissioner’s Code of Practice. The Club will treat the system and all information, documents and recordings obtained and used as data protected by the Act. Cameras will be used to monitor activities within the Club grounds in the vicinity of the dinghy park and clubhouse to identify adverse activity actually occurring, anticipated or perceived. Static cameras are positioned to ensure they do not focus on private homes, gardens and other areas of private property. At no time will a camera be directed to follow or track an individual as all the currently deployed cameras are fixed. Materials or knowledge secured as a result of CCTV use will not be used for any commercial purpose. Images will only be released for use in the investigation of a specific crime and with the written authority of the police. Images will never be released to the media for purposes of entertainment. The planning and design has endeavoured to ensure that the CCTV Scheme will give maximum effectiveness and efficiency within the available budget, but it is not possible to guarantee that the system will cover or detect every single incident taking place in the areas of coverage. Warning signs, as required by the Code of Practice of the Information Commissioner, have been posted in appropriate places.
Operation of the System
The CCTV system will be administered and managed by the Club in accordance with the values and objectives expressed in the code. The day to day management will be the delegated responsibility of the Security Officer. The CCTV system will operate 24 hours each day, every day of the year, recording all activity when the system detects any motion within the field of vision of the cameras.
Control and Liaison
The Security Officer will periodically check and confirm the efficiency of the system and, in particular, that the equipment is properly recording and that cameras are functional.
Monitoring Procedures
Camera surveillance may be maintained at all times when motion is detected and recorded images are held on the system hard disk drive or on secure cloud storage. Depending on the duration of movement detected, up to 30 days of history will be recorded. Oldest recordings are automatically overwritten as the hard disk drive or remote cloud storage becomes full. To maintain and preserve the integrity of any USB or other storage medium (“USB”) used to store data from the hard drive and the facility to use them in any future proceedings, the following procedures for their use and retention will be strictly adhered to:
(a) Each USB must be identified by a unique reference number.
(b) Before using, each USB must be cleared of any previous recording.
(c) The person responsible for recording will register the date and time of the recording, including the USB reference number.
(d) Each USB required for evidential purposes must be sealed, witnessed, signed by the Security Officer dated and stored securely. Images may be viewed by the Police for the prevention and detection of crime. A record will be maintained of any USB released to the Police or other authorised applicants. A register will be maintained for this purpose.
Viewing of footage by the Police or any external individual must be recorded in writing and entered in the register. Requests by the Police can only be authorised under section 29 of the Data Protection Act 1998. Should images be required as evidence, a copy may be released to the Police under the procedures described in this paragraph of this Code. Images will only be released to the Police on the clear understanding that the USB remains the property of the Club, and both it and images on it are to be treated in accordance with this code. The Club also retains the right to refuse permission for the Police to pass to any other person the USB or any part of the images contained thereon. The Police may require the Club to retain any stored USB Images for possible use as evidence in the future. Such USB Images will be properly indexed and securely stored until the Police need them.
Applications received from outside bodies (e.g. solicitors) to view or release footage stored on USB’s will be referred to the Commodore. In these circumstances the USB Images will normally be released where satisfactory documentary evidence is produced showing that they are required for legal proceedings, or in response to a Court Order. A fee may be charged in such circumstances.
Breaches of the Code (including Breaches of Security)
The Commodore will initially investigate any breach of the Code of Practice by the Security Officer or any other Club member.
Complaints
Any complaints about the Club’s CCTV system should be addressed to the Commodore. Complaints will be dealt with in accordance with the ICO Code of Practice.
Access by the Data Subject
The Data Protection Act provides Data Subjects (individuals to whom “personal data” relate) with a right to data held about them, including those obtained by CCTV. Requests for Data Subject Access should be made through the Commodore. The Club reserves the right to make a charge of up to £10 (currently the statutory amount as permitted by Parliament).
Public Information
Copies of this policy will be available to the public from the Club website.
Issued by the Commodore
Reviewed December 2020