Document Purpose
The purpose of this policy is to regulate the use of Closed Circuit Television (CCTV) and its associated technology in the monitoring of the internal and external environs of premises under the remit of the Douglas Lawn Tennis Club Committee.
Purpose of CCTV System
CCTV is installed internally & externally in our club for the purpose of enhancing the security of the club and its associated equipment as well as creating a mindfulness among the occupants, at any one time, that a surveillance security system is in operation to deter bullying/harassment, crime, vandalism and theft, as an aid to Health & Safety and to the discharge of the club’s duty of care within and/or in the external environs of the club at all times.
Scope of Policy
This policy applies to any staff, members and visitors to our club and relates directly to the location and use of CCTV, the monitoring, recording and subsequent use of such recorded material.
General Principles
Douglas Lawn Tennis Club has a statutory responsibility for the protection of its property, equipment and other plant as well as providing a sense of security to its employees, members and visitors to its premises. The Douglas Lawn Tennis Club owes a duty of care under the provisions of Safety, Health and Welfare at Work Act 2005 and associated legislation and utilises CCTV systems and their associated monitoring and recording equipment as an added mode of security and surveillance for the purpose of enhancing the quality of life of the facility by integrating the best practices governing the public and private surveillance of its premises.
The use of the CCTV system will be conducted in a professional, ethical and legal manner and any diversion of the use of CCTV security technologies for other purposes is prohibited by this policy e.g. CCTV will not be used for monitoring employee performance. Information obtained through the CCTV system may only be released when authorised by the Committee, following legal advice, should that be deemed necessary. Any requests for CCTV recordings/images will be fully recorded. Legal advice will be sought should there be a request for CCTV recordings/images from An Garda Síochána. If a law enforcement authority, such as An Garda Síochána, is seeking a recording for a specific investigation, An Garda Síochána may require a warrant and accordingly any such request made by An Garda Síochána should be requested in writing and Douglas Lawn Tennis Club will immediately seek legal advice.
CCTV monitoring of public areas for security purposes will be conducted in a manner consistent with all existing policies adopted by Douglas Lawn Tennis Club, including Child Protection, Equality & Diversity Policy, Dignity at Work Policy, Codes of Practice for dealing with complaints of Bullying & Harassment and Sexual Harassment and other relevant policies, including the provisions set down in equality and other educational and related legislation.
This policy prohibits monitoring based on the characteristics and classifications contained in equality and other related legislation e.g. race, gender, sexual orientation, national origin, disability etc.
All CCTV systems and associated equipment will be required to be compliant with this policy following its adoption by the Douglas Lawn Tennis Club Committee. Recognisable images captured by CCTV systems are personal data. They are therefore subject to the provisions of the Data Protection Acts 1988 and 2003.
Cameras are located in the following areas:-
- In clubhouse entrance hall
- In clubhouse function room
- On the light pole at the coach’s shed, monitoring the ball wall
- On the light pole at the coach’s shed, monitoring the lower car park
- On the light pole at the coach’s shed, monitoring the front of the clubhouse
- On court 1 light pole, monitoring courts 1,2 & 3
- On court 1 light pole, monitoring courts 4, 5 & 6
- On the clubhouse gable, monitoring the main car park
- On the southeast corner of the clubhouse, monitoring the clubhouse rear
DATA PROTECTION
All personal data recorded and stored by the CCTV system is governed by the Data Protection Acts, 1988 & 2003. Under the Data Protection Acts, a ‘Data Controller’ is the individual or the legal person who controls and is responsible for the keeping and use of personal information in manual files or in computerised form. The Data Controller is appointed by the Douglas Lawn Tennis Club committee and in their absence the Club President will assume the role of Data Controller. The personal data recorded and stored by the CCTV system will only be available to the Data Controller and will be used only for the purposes outlined in this document. The CCTV system shall not be used to monitor staff performance or conduct. Individuals whose images are recorded and stored by the CCTV system shall have the right to request and receive a copy of personal data processed by the system. Any requests for CCTV recordings/images will be fully recorded. Such requests shall be made in writing to the Data Controller and shall be complied with within a maximum of 40 days.
Personal data recorded by the CCTV system shall be retained for a maximum of 30 days. Thereafter, it will be deleted automatically. The recorded footage and the monitoring equipment shall be securely stored in the clubhouse office. Unauthorised access to that area is not permitted at any time. The area is locked when not occupied and key controlled. All CCTV systems and associated equipment will be required to be compliant with this policy following its adoption by the Committee.