Summary of Freedom Leisure’s CCTV Policy
1. CCTV Policy Statement
It is the objective of Freedom Leisure to ensure that where CCTV is installed, it is managed in an appropriate way adhering to all relevant Acts and Regulations. This policy sets out how Freedom Leisure manages CCTV in line with current legislation.
Wealden Leisure Ltd trading as Freedom Leisure has in place a CCTV surveillance system “the CCTV system” across many of its Sports, Athletic and Leisure Locations across the UK. This policy details the purpose, use and management of the CCTV system at Freedom Leisure UK locations and details the procedures to be followed in order to ensure that Freedom Leisure complies with relevant legislation and the current Information Commissioner’s Office Code of Practice.
Freedom Leisure will have due regard to the Data Protection Act 2018, and the General Data Protection Regulation (GDPR) 2018 and any subsequent data protection legislation, and to the Freedom of Information Act 2000, the Protection of Freedoms Act 2012 and the Human Rights Act 1998. Although not a relevant authority, Freedom Leisure will also have due regard to the Surveillance Camera Code of Practice, issued under the Protection of Freedoms Act 2012 and in particular the 12 guiding principles contained therein.
The CCTV system is owned or operated by Freedom leisure, 1-6 The Paddock, Carriers Way, East Hoathly, East Sussex, BN8 6AG and managed by Freedom Leisure and its appointed staff. Under the Data Protection Act 2018 Freedom Leisure is the ‘data controller’ for the images produced by the CCTV system. The CCTV system is operated in line with the requirements of the Data Protection Act and the Information Commissioner’s Guidance.
2. Purposes of the CCTV System
The principal purposes of the Freedom Leisure CCTV system are as follows:
The CCTV system will be used as a surveillance mechanism in order to identify incidents requiring a response. Any response should be proportionate to the incident being witnessed.
Freedom Leisure seeks to operate its CCTV system in a manner that is consistent with respect for the individual’s privacy.
3. Monitoring and Recording
Cameras are monitored at each Freedom Leisure site within a secure office area, which is staffed during opening hours.
Images are recorded locally onto DVD/DVR and other devices which are located securely at each site, these are viewable by authorised employees, and there will be a register at each site of authorised employees.
All images recorded by the CCTV System remain the property and copyright of Freedom Leisure.
The use of covert cameras will be restricted to rare occasions, when a series of criminal acts have taken place within a particular area that is not otherwise be fitted with CCTV. A request for the use of covert cameras will clearly state the purpose and reasons for use and the authority of the “Data Controller” will be sought before the installation of any covert cameras.
Covert recording will only take place if informing the individual(s) concerned would seriously prejudice the reason for making the recording and where there are reasonable grounds to suspect that illegal or unauthorised activity is taking place. All such monitoring will be fully documented and will only take place for a limited and reasonable period.
Body worn cameras may be used during normal duties on outdoor actives to protect staff. The downloading of images from such cameras will only be conducted by trained authorised staff and cameras will be cleansed following each day.
4. Applications for Disclosure of Images
Requests by individual data subjects for images relating to themselves “Subject Access Request” should be submitted in writing to the site manager in the first instance, with proof of identification, the site manager must inform the “Data Controller” of all requests and obtain their authorisation for the release of data.
In order to locate the images on Freedom Leisure CCTV system, sufficient detail must be provided by the data subject in order to allow the relevant images to be located and the data subject to be identified.
Where disclosure of CCTV images is necessary, details must be recorded that include:
5. Access to and Disclosure of Images to Third Parties
A request for images made by a third party should be made in writing to the “Data Controller”, which may then be delegated to the site manager.
In limited circumstances it may be appropriate to disclose images to a third party, such as when a disclosure is required by law, in relation to the prevention or detection of crime, or in other circumstances where an exemption applies under relevant legislation.
Such disclosures will be made at the discretion of the “Data Controller”, with reference to relevant legislation.
6. Complaints Procedure
Complaints concerning Freedom Leisure use of its CCTV system or the disclosure of CCTV images should be made in writing to the “Data Controller”
Head office, 1-6 The Paddock, Carriers Way, East Hoathly, East Sussex, BN8 6AG.