Closed Circuit Television (CCTV) Policy
Key Messages
The main objectives of this policy are to:
- Inform Stour Sailing Club (SSC) Officers, Committee Members, guests and users of SSC premises of the arrangements for the placement and management and purposes of CCTV on SSC premises.
- Provide information about the retention of CCTV images where the SSC has responsibility for the systems in use
Does this policy relate to me?
The policy relates to all Members of Stour Sailing Club as well as Guests, Users of SSC Premises and anyone who may be in the proximity of SSC CCTV Cameras.
1. Introduction
1.1 Stour Sailing Club uses CCTV for the purposes of the prevention and detection of crime and in order to recognise and identify individuals with a view to taking appropriate action where necessary.
1.2 This document sets out the accepted use and management of CCTV equipment and images to ensure that the SSC complies with the Data Protection Act 2018 and other relevant legislation. We process personal data in line with our Data Protection Policy.
1.3 SSC will also comply with the Guiding Principles of the Surveillance Camera Code of Practice as published by the Home Office and updated in 2021, which are included for reference at Appendix 2.
1.4 This policy and procedure applies to all SSC property locations in Quay Street Manningtree and the Waterside Facilities.
2. Policy position and purpose
2.1 CCTV has been installed in various locations on SSC properties and waterside facilities to assist in deterring crime, in the detection of crime and the identification and apprehension of Offenders in cooperation with Law Enforcement Agencies where requested, and as may be required for disciplinary or complaints investigations.
2.2 The existence of CCTV and positioning of cameras is intended to help deter any unauthorised access to SSC properties including the Clubhouse, the East and West Compounds and the waterside facilities known as the pontoons, and to help protect Club and Member’s property, deter incidents and enhance safety. And, in the event of an incident, help to identify individuals involved.
2.3 The purpose of this policy is to establish how any CCTV footage captured will be managed by SSC, and under what circumstances the footage may be retained and used.
February 2025
3. Responsibility for the management of the system
3.1 The Club House Manager has overall responsibility for the maintenance of the system. They will periodically check the equipment and arrange for the suppliers / contractor to carry our periodic maintenance checks.
3.2 The Club House Manager will ensure that images are deleted in accordance with the retention policy (auto deletion after 4 weeks’ storage). SSC will engage maintenance contractors who will also have access to the recorded images during the maintenance of the systems but will under no circumstances routinely view, disclose or retain copies of the recorded images.
3.3 The Club House Manager, the Compounds Manager and the Moorings Manager (jointly the SSC ‘Estates Team’) only will be trained in the operation of the CCTV system, and will be aware of the data protection compliance requirements in line with the Code of Practice.
4. Auditing the system’s operation and working practices
4.1 SSC Estates Team and Club officers are responsible for ensuring that this policy and its implementation is compliant with Data Protection Legislation, and will audit the system’s use on a periodic basis.
4.2 The Club House Manager and Club Officers are responsible for dealing with and responding to any requests for access to images.
5. Secure storage and retention of images
5.1 Images will be stored on the recording equipment which will be securely protected within the Club House premises. The Club House Manager and Club Officers have responsibility for ensuring that the equipment and the routinely recorded images have the necessary security.
5.2 Images are routinely retained for 4 weeks’ but may be retained longer in the event that they are required as part of an investigation. As the data recording equipment does not allow for longer storage any footage that is required to be retained for a longer period will be downloaded and kept secure.
6. Access to and disclosure of images
6.1 The Club House Manager and Club Officers are responsible for viewing images when investigating an incident or suspected incident.
7. Data Subject Rights
7.1 Recorded images, if sufficiently clear to allow for identification of individuals, are considered to be the personal data of the individuals (Data Subjects) whose images have been recorded by the CCTV system.
7.2 Data subjects have the right of access to personal data under the GDPR and DPA 2018. They also have other rights under the same provisions in certain limited circumstances, including the right to have their personal data erased, rectified, to restrict processing and to object to the processing of their personal data.
7.3 Data Subjects can exercise these rights by submitting a Subject Access Request to the Club in the manner indicated in the Data Protection and Privacy Policy by emailing info@stoursailingclub.co.uk
8. Third-Party Access
8.1 Third-party requests for access will usually only be considered in line with the GDPR and DPA 2018 in the following categories:
- Legal representative of the data subject
- Law enforcement agencies including the Police
- Disclosure required by law or made in connection with legal proceedings
- Officers of the Club responsible for disciplinary and complaint investigations, and related proceedings.
8.2 Stour Sailing Club will disclose recorded images to law enforcement agencies including the Police once in possession of a form certifying that the images are required for either the prevention or detection of crime; in the apprehension or prosecution of offenders, and that the investigation would be prejudiced by failure to disclose information. Where images are sought by other bodies/agencies with a statutory right to obtain information, evidence of that statutory authority will be sought before CCTV images are disclosed.
8.3 Every disclosure of CCTV images will be recorded by the Club with the following information recorded.
- The name of the relevant person/Police Officer receiving a copy of the recording
- Brief details of the images captured by the CCTV to be used in evidence or for the purposes permitted by this policy;
- The crime reference number, where relevant; and
- Date and time the images were provided to the third party.
9. Complaints Procedure
9.1 Any complaints relating to the CCTV system should be directed in writing to the Management Committee within 7 days of the incident giving rise to the complaint. The complaint will be dealt with in line with the Club’s Grievance/Complaints Policy.
9.2 Complaints in relation to the CCTV system should be directed in writing to the Management Committee as soon as possible and in any event no later than three months from the event giving rise to the complaint.
Appendix 1
Siting of cameras
Clubhouse
- 2 x CCTV cameras Covering Front Entrance door, Rear Fire Exit and stairs,
- 2 x CCTV camera pointed Left and Right viewing of the Public Hard and Club House frontage and slipway
Starting Hut
- 1 x CCTV camera pointed west covering East River Moorings
- 1 x CCTV camera pointed East covering Compound Area and in summer months’ monitors inside the Marquee.
West Compound Area
- 1 x CCTV camera pointed East on Dinghy Racks in West Compound
- 1 x CCTV camera pointed East covering and entry point
Pontoon and Quayside Area
- 1 x CCTV camera pointed West covering Pontoon Entry Gate
- 1 x CCTV camera pointed North covering entire length of pontoons and all Moorings directly in front of the Pontoon Area.
These CCTV systems are for the purposes of security and crime prevention/detection Nuisance and Antisocial Behaviour, Vandalism and Graffiti. The presence of CCTV cameras outside the SSC Club House Office are made clear to building users, and form part of the considerations in the Data Protection Impact Assessment.
Appendix 2
Home Office – Surveillance Camera Code of Practice (amended November 2021)
Guiding Principles
System operators should adopt the following 12 guiding principles:
- Use of a surveillance camera system must always be for a specified purpose which is in pursuit of a legitimate aim and necessary to meet an identified pressing need.
- The user of a surveillance camera system must take into account its effect on individuals and their privacy, with regular reviews to ensure its use remains justified.
- There must be as much transparency in the use of a surveillance camera system as possible, including a published contact point for access to information and complaints.
- There must be clear responsibility and accountability for all surveillance camera system activities including images and information collected, held and used.
- Clear rules, policies and procedures must be in place before a surveillance camera system is used, and these must be communicated to all who need to comply with them.
- No more images and information should be stored than that which is strictly required for the stated purpose of a surveillance camera system, and such images and information should be deleted once their purposes have been discharged.
- Access to retained images and information should be restricted and there must be clearly defined rules on who can gain access and for what purpose such access is granted; the disclosure of images and information should only take place when it is necessary for such a purpose or for law enforcement purposes.
- Surveillance camera system operators should consider any approved operational, technical and competency standards relevant to a system and its purpose and work to meet and maintain those standards.
- Surveillance camera system images and information should be subject to appropriate security measures to safeguard against unauthorised access and use.
- There should be effective review and audit mechanisms to ensure legal requirements, policies and standards are complied with in practice, and regular reports should be published.
- When the use of a surveillance camera system is in pursuit of a legitimate aim, and there is a pressing need for its use, it should then be used in the most effective way to support public safety and law enforcement with the aim of processing images and information of evidential value.
- Any information used to support a surveillance camera system which compares against a reference database for matching purposes should be accurate and kept up to date.