Princes Risborough Golf Club CCTV Policy

Introduction

Princes Risborough Golf Club (PRGC) is fully committed to the safety of its members, employees and visitors and uses CCTV to help maintain a safe and secure environment. Recorded images are personal data, which must be processed in accordance with data protection laws. We are committed to complying with our legal obligations and ensuring that any personal data is recognised and respected.

Purpose

This policy sets out Princes Risborough Golf Club’s approach to the use of CCTV and its effect on employees, members and visitors. In accordance with the Information Commissioner’s Office (ICO) requirements, PRGC is registered as a user of CCTV for the purposes defined in this policy. In line with the ICO’s requirements the use of CCTV is reviewed annually to ensure it can be justified. PRGC operates CCTV cameras around the premises under the guidelines of the Data Protection Act 2018 (DPA 2018) and the General Data Protection Regulations (GDPR) as they apply in the UK. The primary use of the CCTV cameras at the clubhouse and surrounding areas at the Club is for the purpose of detecting and preventing crime, protecting the property and facilities, identifying any health and safety issues, and for personal security of members, visitors and employees whilst at PRGC.

Responsibilities

Day to day responsibility for ensuring this policy is appropriately managed and controlled, in accordance and as defined by the ICO, is Gary Tubb. The following principles have been applied: CCTV has been installed only where it is considered necessary and proportionate. The Club has ensured that all cameras are set up in a way that ensures that there is minimal intrusion of privacy, and that any intrusion is fully justified. Signs are displayed prominently to inform employees, members and visitors that CCTV is in use. No images and information will be stored beyond those which are strictly required for the stated purpose of a surveillance camera system. Access to retained images and information will be restricted, with clearly defined rules on who can gain access. Surveillance images and information will be subject to appropriate security measures to safeguard against unauthorised access and use. Fair processing requirements will be observed at all times. Any decision for any future CCTV camera installations would be for Gary Tubb and privacy requirements will be considered.

Procedures

Live CCTV Footage, and recorded CCTV footage can only be viewed by: Club Management Staff The Police and our professional advisors (as required and under supervision of the Gary Tubb) Camera surveillance will be maintained at all times and footage to be continuously recorded and held on system memory for circa 30 days.

Use Of CCTV

As stated, the primary purpose of CCTV is to protect the property, members, visitors and employees of PRGC. However, we recognise that when CCTV is installed in a workplace, it is likely to capture pictures of members, visitors, employees and workers, even if they are not the main subject of surveillance. In accordance with the ICO’s CCTV Code of Practice, where footage is used in disciplinary proceedings, the footage will be retained, and the worker, employee, visitor or member will be permitted to see and respond to the images.

Requests For Access to CCTV Footage

Any requests for access to CCTV footage need to be relative to the purpose of the CCTV system - detecting and preventing crime, protecting the club’s property and facilities, health and safety requirements, and for personal security of members, visitors and employees whilst at The National Golf Centre. A record will be maintained of any requests made and whether the request has been approved or not. The Police, other enforcing agents, or outside bodies may request access to a recording. Any request will be considered initially by Gary Tubb. Employees, members and visitors whose images are recorded have a right (subject to some restrictions) to view those images of themselves and to be provided with a copy of the images within 30 days of their request, as long as they have not been automatically deleted. Any person making such a request should contact Gary Tubb at the address below providing the relevant time and date of the image, so that they may be easily identifiable. Complaints about the operation of the CCTV system should be addressed initially to Gary Tubb by email at gary.prgc@gmail.com.