Introduction

Lee Chapel Fishing Club uses closed circuit television (CCTV) images to protect the Clubs’s property. This policy sets out the details of how the Club will collect, use and store CCTV images. For more information on your privacy rights associated with the processing of your personal data collected through CCTV images please refer to the Clubs Privacy Policy.

The Club’s CCTV, records images when triggered by humanoid activity within the area being monitored.

 

Purposes of CCTV

The Club has carried out a data protection impact assessment and on the basis of its findings it considers it necessary and proportionate to install and use a CCTV system. The data collected from the system will assist in:

•         Prevention or detection of crime.

•          Identification and prosecution of offenders.

•         Monitoring of the security of the Clubs property.

 

Location of cameras

Cameras are located at strategic points around Club Properties.  The Club has positioned the cameras so that they only cover public areas at Lee Chapel Lake have been sited so that they provide clear images.  All cameras are also clearly visible.

Appropriate signs are prominently displayed so that members, visitors and members of the public are made aware as to the presence of CCTV cameras.

 

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 are only recorded when the cameras are triggered by humanoid activity within the areas being monitored.

As the recording system records digital images, any CCTV images that are held on the hard drive of a PC, Server or SD Card are deleted and overwritten on a recycling basis and, in any event, once the 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 or which are stored digitally are erased or destroyed once the purpose of the recording is no longer relevant.  In normal circumstances, this will be a period of 40 days.  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 to the officers of the Club.  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. 

Access to recorded images is restricted to the operators of the CCTV system (Officers of the Club) Viewing of recorded images will take place in a private If media on which images are recorded are removed for viewing purposes, this will be documented.

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.

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•        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).

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The Chairman of the Club (or another Club Officer 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 UK’s data protection laws, including the General Data Protection Regulation (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 Clubs Secretary. This can be done by using this email address leechapelfishingclub@gmail.com.  The Club will usually not make a charge for such a request, but we may charge a reasonable fee if you make a request which is manifestly unfounded or excessive or is repetitive. 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 usually respond promptly and in any case within one month of receiving a request. However, where a request is complex or numerous the Club may extend the one month to respond by a further two months.

The Club will always check the identity of the requestor making the request before processing it.

The Club Committee will always 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.

  

Officer Training                                                                   

The Club will ensure that all Officers handling CCTV images or recordings are trained in the operation and administration of the CCTV system and on the impact of the laws regulating data protection and privacy with regard to that system. 

 

Implementation

The Club Committee is responsible for the implementation of and compliance with this policy and the operation of the CCTV system and they will conduct a regular review of the Club’s use and processing of CCTV images and always ensure that it remains compliant with the laws regulating data protection and privacy.  Any complaints or enquiries about the operation of the Club's CCTV system should be addressed to the Club Chairman.

 

Data Protection

The Club will process the personal data collected in connection with the operation of the CCTV policy in accordance with its data protection policy and any internal privacy notices in force at the relevant time. Inappropriate access or disclosure of this data will constitute a data breach and should be reported immediately to the Club Chairman. Reported data breaches will be investigated and may lead to sanctions under the Clubss disciplinary procedure. The Club DPO will delete any non-required images from the System once it has determined no criminal activity has taken place.  This will take place at a minimum of once per week.