Southwold and District Freshwater Angling Preservation Society uses closed circuit television (CCTV) images to provide a safe and secure environment for members and visitors to the site.
This policy sets out the use and management of the CCTV equipment and images in compliance with the Data Protection Act 1998 and the CCTV Code of Practice.
The Society’s CCTV facility records images only. There is no audio recording i.e. conversations are not recorded on CCTV (but see the section on covert recording).
The purposes of the Group using CCTV systems include (but are not limited to):
To assist the committee and bailiffs ensure rules of the society are not being breached for example Site entry and Exit times.
Monitor wildlife on the complex.
3. Camera Locations
The camera is located at the main site entry gate.
All cameras (with the exception of any that may be temporarily set up for covert recording) are also clearly visible.
Appropriate signs are prominently displayed so that volunteers, members, and other visitors are aware they are entering an area covered by CCTV.
4. 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 may be recorded either in constant real-time (24 hours a day throughout the year), or only at certain times, as the needs of the society dictate.
As the recording system records digital images, any CCTV images that are held on the server are deleted and overwritten on a recycling basis and, in any event, are not held for more than two months.
Images that are shared with Law enforcement will be retained in line with that organisations retention policy.
5. Access to and disclosure of Images
Access to, and disclosure of, images recorded on CCTV is restricted. 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.
The images that are filmed are recorded centrally and held in a secure location. Access to recorded images is restricted to the operators of the CCTV system and to those committee members/bailiffs who are authorised to view them in accordance with the purposes of the system. Viewing of recorded images will take place in a restricted area to which other members will not have access when viewing is occurring. 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.
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).
A nominated Committee Member & chairman are the only persons who are 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.
6. Individuals’ access rights
Under the Data Protection Act 2018/GDPR, individuals have the right on request to receive a copy of the personal data that the Group 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 Chairman/Committee. 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 Group will respond promptly and in any case within 29 calendar days of receiving the request.
The Society will always check the identity of the person making the request before processing it.
The Society will first 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 Society 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.
The Society 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 Society’s use of CCTV. Any complaints or enquiries about the operation of the Society’s CCTV system should be addressed to them.
8. ICO Registration
The Society is exempt due to being not for profit organisation.
Barry Reid - Chairman
Policy last updated on 01/12/2023.