The purpose of this policy is to set out the position of North Cheshire Cruising Club Limited (NCCC) as to the use of the CCTV system across the wharf, car parks and club buildings, and the management and operation of the system.
- North Cheshire Cruising Club Limited uses a CCTV system on the premises (Close Circuit Television).
- This policy applies to all members, visitors to North Cheshire Cruising Club Limited and the surrounding area and all other persons whose images maybe captured by the CCTV system.
- This policy for North Cheshire Cruising Club Limited takes account of all applicable legislation and guidance which includes.
- General Data Protection Regulations (GDPR)
- Data Protection Act 2018 along with the Data Protection legislation
- CCTV code of Practice produced by the ICO.
- Human Rights Act 1988
- The policy sets out the position of North Cheshire Cruising Club Limited in relation to its use of CCTV.
What is the Purpose of the CCTV System
- The Directors of North Cheshire Cruising Club Limited will use the CCTV System for the following purposes:
- To provide a safe and secure environment for staff and visitors when at North Cheshire Cruising Club Limited
- To prevent any loss or damage to the Companies buildings and or assets
- To assist in the prevention of crime and assist the Police in apprehending criminals.
The Description of the CCTV System
- North Cheshire Cruising Club Limited will have a number of cameras in the club house, and also around the grounds of the club.
- The cameras have no audio recording capacity but do have video recording capacity and there is also a number of moveable cameras as well as fixed cameras. All the cameras are linked back to the operation system which is located in the CCTV/Small Office inside North Cheshire Cruising Club Limited.
Position of the Cameras
- All CCTV cameras are situation in such a way that meets the purposed for which the CCTV is operated. Cameras are sited in prominent position where they are visible to members and visitors.
- Signs are erected around the grounds of North Cheshire Cruising Club Limited and also inside the club house in the areas where the cameras are erected.
- Cameras are not sited in areas where members of North Cheshire Cruising Club Limited and visitors to the club have an expectation of privacy such as toilets, showers and changing rooms.
- Cameras maybe located in communal areas of North Cheshire Cruising Club Limited, and where this maybe the case, visitors and members will be made aware by the use of signage. Access to the footage is restricted and will only be used the fill the purposes as listed in the sections ‘Purposes of the CCTV System – point two’.
Privacy Impact Assessment
- Prior to the installation or positioning of the CCTV cameras and system, a privacy impact assessment has been conducted by North Cheshire Cruising Club Limited which ensures the proper installation which is compliant.
- The company has adopted a privacy by design approach when installing new cameras and systems which takes into account the purpose of the cameras so to avoid recording and storing of excessive amounts of personal data.
Management of Access to the CCTV System
- The CCTV system within North Cheshire Cruising Club Limited will be managed by a member of the board with a limited number of other board members or company officials given access. Once that member leaves the board or as a company official, there access will be revoked.
- Any allegations against a member of the club will be referred to the Chairman, and only he will determine who needs to view the footage and the course of action necessary.
- The CCTV system is not operated on a daily basis by members of the club and is a stand-alone system. The current specified personally who check the system have been trained in the operation of the system.
- The viewing of live CCTV images will be restricted to the specified personal only, any IT or service personal which will ensure that the purposes in ‘Purposes of the CCTV System – point one’ are satisfied.
- Recorded images which are stored by the CCTV system will be restricted as in point four above. Relevant images maybe shared with the Board of North Cheshire Cruising Club Limited which will allow them to review any incidents where disciplinary matters or complaints need to be addressed.
- No other individuals will have to right to view or access any CCTV images unless in accordance with the terms of this policy.
- The CCTV system in check on a regular basis to ensure that the system is operating effectively.
Storage and Retention of CCTV Images
- Any images that are record by the CCTV system will be retained only for as long as necessary for the purpose for which they were originally recorded.
- Recorded images are stored for a maximum of three weeks (twenty-one days) unless there is a specific purpose for which they are retained for a longer period.
- North Cheshire Cruising club will ensure that appropriate security measures. The measures that are in place are:
- CCTV recording system is located in a restricted access area – accessed only be a keypad locking system.
- The system is encrypted and also password protected.
- Restriction of the ability to make copied specified members of the club.
- A log of the access to the CCTV images, including time and dates of access and a record of the individual accessing the images will be maintained by North Cheshire Cruising Club Limited.
Disclosure of Images to Data Subjects.
- Any individual recorded in a CCTV Image is a ‘data subject’ for the purposes of the Data Protection legislation and has a right to request access to those images.
- Any individual who requests access to images of themselves will be considered to have made a ‘Subject Access Request’ Such a request should be considered in the context of the Subject Access Request Policy.
- When a request is made the appropriate individual with access to the CCTV footage (as Management of Access to the CCTV System point 4) will review the CCTV footage in respect of relevant time periods where appropriate and in accordance with the request.
- If the footage contains only the individual making the request, then the individual may be permitted to view the footage. This must be strictly limited to that footage which contains only images of the individual make the request. The individual accessing the footage must take appropriate measures to ensure that the footage is restricted in this way.
- If the footage contains images of other individuals, then North Cheshire Cruising Club Limited must consider whether
- The request required the disclosure of the images of individuals other than the requester, for example where the images can be distorted so as not to identify other individuals.
- The other individuals in the footage have consented to the disclosure of the images or their consent could be obtained or
- If not, then whether it is otherwise reasonable in the circumstances to disclose those images to the individual making the request.
- A record must be kept and held securely of all disclosures which sets out:
- When the request was made
- The process followed by to the individual with access to the CCTV footage in determining where the images contained third parties.
- The considerations as to whether to allow access to those images.
- When the individuals that were permitted viewed the images
- Whether a copy of the images were produced, and if so to whom, when and in what format.
Note that, when a subject access request is made then, unless an exemption applies (such as in relation to third party data that it would be unreasonable to disclose) then the requester is entitled to a copy in a permanent form. There is reference here only to “access” as opposed to a “permanent copy” as North Cheshire Cruising Club Limited may consider it preferable in certain circumstances to seek to allow access to images by viewing in the first instance without providing copies of images. If an individual agrees to viewing the images only then a permanent copy does not need to be provided. However, if a permanent copy is requested then this should be provided unless to do so is not possible or would involve disproportionate effort.
Disclosure of CCTV Images to Third Parties
- North Cheshire Cruising Club Limited will only disclose recorded CCTV Images to third parties where it is permitted to do so in accordance with the Data Protection Legislation.
- CCTV images will only be disclosed to the Police in line with the purposes for which the CCTV system is in place.
- If North Cheshire Cruising Club Limited receives a request from the Police for the disclosure of CCTV images that the individual with access to the CCTV footage must follow the same process as above in relation to subject access requests. Details must be obtained from the Police as to exactly what they want the CCTV images for, and any particular individuals of concern. This will then enable proper consideration to be given to what should be disclosed and the potential disclosure of any third party images.
- The information must be recorded in relation to the disclosure.
- If an order is granted by Court for the disclosure of the CCTV images, then this should be complied with. However very careful consideration must be given to exactly what the Court order requires. If there are any concerns as to the disclosure of the Data Protection Officer should be contacted in the first instance and appropriate legal advice may be required.
North Cheshire Cruising Club’s Review of Policy and CCTV System
This policy will be reviewed every year or earlier should the need arise.
Misue of North Cheshire Cruising Club’s CCTV System
The misuse of the CCTV system could constitute a criminal offence.
Complaints relating to this Policy.
Any complaints relating to this policy of to the CCTV system operated by North Cheshire Cruising Club Limited should be made in accordance with North Cheshire Cruising Club Limited’s complaints procedure.
This policy was written and approved by North Cheshire Cruising Club Limited on 4 October by Heather Stanley Company Secretary