CCTV Privacy Policy

1.1 The Cherish Club has in place a CCTV surveillance system, “the system” within internal and external locations. Images are monitored and recorded centrally and will be used in strict accordance with this policy. The system is owned by The Cherish Club Ltd.

General Data Protection Regulations: CCTV digital images, if they show a recognisable person, are personal data and are covered by the General Data Protection Regulations. This Policy is associated with the The Cherish Club Ltd General Data Protection Policy, the provisions of which should be adhered to at all times.

3.1 The system has been installed by The Cherish Club Ltd with the primary purpose of reducing the threat of crime generally and general monitoring, protecting The Cherish Club’s premises and helping to ensure the safety of all The Cherish Club’s staff and visitors consistent with respect for the individuals’ privacy. These purposes will be achieved by monitoring the system to:

• Deter those having criminal intent
• Assist in the prevention and detection of crime
• Facilitate the identification, apprehension and prosecution of offenders in relation to crime and public order
• Facilitate the identification of any activities/event which might warrant disciplinary proceedings being taken against staff and assist in providing evidence to managers and/or to a member of staff against whom disciplinary or other action is, or is threatened to be taken.
• In the case of staff to provide management information relating to employee compliance with contracts of employment.

The system will not be used:

• To provide recorded images for the world-wide-web.
• To record sound other than in accordance with the policy on covert recording.
• For any automated decision taking

4.1 Images captured by the system will be recorded twenty-four hours a day throughout the whole year. Monitors may be present onsite. Recordings will be stored locally on a cloud drive located with the site communications equipment.

4.2 No unauthorised access to recordings will be permitted at any time. Access will be strictly limited to the Studio Manager, Co-founders, police officers and any other person with statutory powers of entry. A list of those members of staff authorised to access the recordings via the app is given at Appendix 2.

4.3 Staff, guests and visitors may be granted access on a case-by-case basis and only then on written authorisation from the DPO. In an emergency and where it is not reasonably practicable to secure prior authorisation, access may be granted to persons with a legitimate reason to access the recordings.

4.4 Before allowing access to recordings, staff will satisfy themselves of the identity of any visitor and that the visitor has appropriate authorisation. All individuals will be required to complete and sign the access’ log, located in the studios GDPR folder which shall include details of their name, their department or organisation they represent, the person who granted authorisation and the times of access, this will also include any visitors granted emergency access.

5.1 All staff working will be made aware of the CCTV images and recordings and associated policy. The Studio Manager will ensure that all staff are fully briefed and trained in respect of the functions, operational and administrative, arising from the use of CCTV.

6.1 Digital recordings are made using digital video recorders operating in time lapse mode. Incidents may be recorded in real time.

6.2 Images will normally be retained for 31 days from the date of recording, and then automatically over written and the Log updated accordingly.

7.1 All access to images will be recorded in an Access Log

7.2 Access to images will be restricted to those staff need to have access in accordance with the purposes of the system. A list of such staff is given at Appendix 2.

7.3 Access to images by third parties

7.3.1 Disclosure of recorded material will only be made to third parties in strict accordance with the purposes of the system and is limited to the following authorities:

• Law enforcement agencies where images recorded would assist in a criminal enquiry and/or the prevention of terrorism and disorder
• Prosecution agencies
• Relevant legal representatives
• The media where the assistance of the general public is required in the identification of a victim of crime or the identification of a perpetrator of a crime
• People whose images have been recorded and retained unless disclosure to the individual would prejudice criminal enquiries or criminal proceedings.
• Emergency services in connection with the investigation of an accident.

7.4 Access to images by a subject

CCTV digital images, if they show a recognisable person, are personal data and are covered by the General Data Protection Regulations. Anyone who believes that they have been filmed by CCTV is entitled to ask for a copy of the data, subject to exemptions contained in the Regulations. They do not have the right of instant access.

7.4.1 A person whose image has been recorded and retained and who wishes access to the data must apply in writing to the studio manager. Subject Access Requests can be made via email info@thecherishclub.co.uk . A response will be provided promptly and in any event within 1 month of receiving the request.

7.4.2 The General Data Protection Act gives the the studio manager the right to refuse a request for a copy of the data particularly where such access could prejudice the prevention or detection of crime or the apprehension or prosecution of offenders.

7.4.3 If it is decided that a data subject access request is to be refused, the reasons will be fully documented and the data subject informed in writing within 1 month, stating the reasons.