CCTV & VIDEO SURVEILLANCE POLICY

The Association is committed to ensuring that CCTV is operated responsibly, lawfully and proportionately, in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and applicable guidance issued by the Information Commissioner's Office (ICO). CCTV is operated to protect individuals, property and facilities while respecting the privacy and data protection rights of employees, volunteers, athletes, visitors, contractors and members of the public.

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Purposes of CCTV

CCTV is used for the following purposes:

Protecting the health, safety and security of employees, volunteers, athletes, visitors and members of the public. Preventing, detecting and investigating crime, theft, vandalism and antisocial behaviour. Protecting buildings, facilities, equipment and property. Monitoring and investigating accidents, incidents and health and safety concerns. Supporting safeguarding investigations where appropriate. Investigating serious breaches of site regulations or misconduct where lawful and proportionate. Providing evidence to the Police, courts, insurers and other authorised bodies where legally justified. CCTV will not be used for purposes incompatible with those for which recordings were originally collected unless permitted by law.

 

Lawful Basis for Processing

The Association generally relies upon Article 6(1)(f) of the UK GDPR (Legitimate Interests) for the operation of CCTV. These legitimate interests include protecting individuals, preventing crime, maintaining security and safeguarding facilities. Where necessary, the Association may also process CCTV footage to comply with a legal obligation under Article 6(1)(c). The Association does not rely upon consent for routine CCTV surveillance. The Association will ensure that CCTV processing is necessary and proportionate, taking account of individuals' rights and reasonable expectations of privacy. Where footage is processed as special category data or criminal offence data, any additional legal conditions and safeguards required by applicable legislation will be identified and applied.

 

CCTV Coverage and Signage

CCTV systems operate at The Pingles Stadium and other sites managed or controlled by the Association. Cameras may cover entrances, exits, communal areas, circulation routes, sports facilities, car parks and other areas where surveillance is justified for safety or security purposes. CCTV signage is displayed at entrances and relevant monitored areas to inform individuals that surveillance is taking place.

Cameras will not ordinarily be installed in toilets, changing rooms or other areas where individuals have a particularly high expectation of privacy. Camera positioning will be reviewed where necessary to minimise unnecessary recording of neighbouring properties or areas outside the Association's control.

 

CCTV Recording and Retention

The Association operates a seven-day CCTV retention period. Under normal operating conditions, recorded CCTV footage is automatically overwritten after seven days.

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Footage may be retained for longer where necessary for: Criminal investigations. Accidents or health and safety investigations. Safeguarding incidents. Insurance claims. Complaints or disciplinary investigations. Legal proceedings or other legitimate investigations.

Any footage retained beyond seven days will be kept only for as long as necessary and securely deleted when no longer required.

Individuals wishing to request CCTV footage are encouraged to contact the Association promptly because recordings may be automatically overwritten after seven days. Where the Association receives a valid request relating to identifiable footage, it will take reasonable steps to preserve relevant recordings while the request is assessed.

 

CCTV Access and Security

Access to live CCTV images and recorded footage is restricted to authorised directors and designated members of staff of Nuneaton Harriers Community Association Ltd. Access is provided only where required for legitimate management, safety, security or investigative purposes. The CCTV systems are not accessible remotely. Access to footage is undertaken through authorised equipment at the relevant premises. The Association does not provide routine CCTV system access to external organisations, including the local authority, sports clubs, contractors or security companies. Authorised individuals must not access, copy, download, share or disclose footage for personal or unauthorised purposes. Appropriate security measures will be maintained to protect recordings against unauthorised access, loss, alteration or disclosure.

 

Sharing CCTV Footage

CCTV footage may be shared with third parties where there is an appropriate lawful basis and disclosure is necessary and proportionate.

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This may include: Police and law enforcement agencies. Emergency services. Courts and legal representatives. Insurance providers and authorised claims investigators. Regulatory and statutory authorities. Other parties where disclosure is required or otherwise permitted by law. Each request will be considered individually.

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The Association may request identification, details of the incident and confirmation of the requesting organisation's authority before releasing footage. Only relevant footage will be disclosed, and appropriate steps will be taken to protect the privacy of other individuals.

The Association does not permit unrestricted access to CCTV recordings by third-party organisations.

 

Individual Data Protection Rights

Individuals captured by CCTV have rights under UK data protection legislation, subject to applicable exemptions and conditions.

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These may include: The right to be informed about the use of their personal data. The right to request access to footage containing their personal data. The right to request erasure or restriction in certain circumstances. The right to object to processing based on legitimate interests. The right to complain about the handling of their personal information. Individuals may submit a Subject Access Request (SAR) to the Association using the contact details provided in this Privacy Policy. Requests should ideally include the date, approximate time and location of the recording to help identify relevant footage. The Association may request reasonable proof of identity where necessary.

Requests will normally be responded to within one calendar month, subject to applicable statutory extensions and exemptions. Where recordings contain other identifiable individuals, appropriate measures may be taken to protect their privacy, including obscuring or redacting images.

 

Employees, Volunteers and Contractors

CCTV may capture employees, volunteers and contractors during their normal duties. The Association does not operate CCTV for the primary purpose of continuously monitoring individual staff performance. However, footage may be reviewed where necessary to investigate theft, serious misconduct, safeguarding concerns, accidents, security incidents or other legitimate matters. Any such use must be lawful, necessary, proportionate and consistent with the purposes of the CCTV system.

 

Children and Vulnerable Individuals

The Association recognises that children and vulnerable individuals regularly use its sports and community facilities. Additional care will be taken when handling CCTV footage involving children or vulnerable individuals. Recordings involving safeguarding concerns will be accessed and disclosed only where appropriate and in accordance with relevant legal and safeguarding requirements.

 

Audio Recording

The Association's CCTV systems record video images only. Audio recording is not enabled. Any future proposal to introduce audio recording would require a separate assessment of necessity, proportionality and applicable data protection requirements before implementation.

 

CCTV System Management

The Association is responsible for ensuring that its CCTV systems are operated appropriately and that personal information is protected. CCTV systems will be subject to appropriate access controls, security arrangements and maintenance. The Association will review its CCTV arrangements periodically, including camera coverage, retention periods, access permissions and the continuing necessity of surveillance.

Where required, a Data Protection Impact Assessment will be completed. Any suspected personal data breach involving CCTV footage will be investigated and reported to the ICO and affected individuals where legally required.

 

Complaints and Contact

Questions, complaints or requests concerning CCTV and personal information should be directed to:

Nuneaton Harriers Community Association Ltd
The Pingles Stadium
Avenue Road
Nuneaton
Warwickshire
CV11 4LX

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Website: www.thepinglesstadium.com

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Individuals may also complain to the Information Commissioner's Office:

www.ico.org.uk

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Policy Review

The Association will review its CCTV arrangements periodically and when significant changes occur to its surveillance systems, operating procedures or applicable legal requirements.

This CCTV section forms part of the Association's wider Privacy Policy and should be read alongside its other data protection information.