Introduction

This policy outlines the principles governing the use of Closed-Circuit Television (CCTV) systems by Hartley & District Social Club Ltd for the purpose of maintaining a safe and secure environment for employees, visitors, and assets, as well as deterring and investigating criminal activity. This policy also specifically addresses the remote viewing capabilities of the CCTV system via authorized mobile devices, with particular emphasis on their use in supporting lone workers.

Purpose of CCTV System

The CCTV system at Hartley & District Social Club is installed and operated for the following purposes:

• To deter crime and anti-social behavior.

• To monitor and record activity for the prevention, investigation, and detection of crime.

• To enhance the safety and security of lone workers by providing an additional layer of monitoring and immediate response capability.

• To ensure the general health and safety of all members, employees, contractors, guests.

• To provide evidence for internal disciplinary proceedings or external legal actions where appropriate and lawful.

• To protect organizational assets and property.

Scope

This policy applies to all members, employees, contractors, guests, and anyone else who may be recorded by or interact with the CCTV system operated by Hartley & District Social Club. It covers all CCTV cameras, recording equipment, monitoring stations, and authorized remote viewing devices.

Legal Basis and Compliance

Hartley & District Social Club operates its CCTV system in compliance with all relevant legislation, including but not limited to:

• The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and the UK Data Protection Act 2018.

• The Human Rights Act 1998.

• The Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999 (specifically regarding lone worker safety).

• The Protection of Freedoms Act 2012.

• As a data controller, Hartley & District Social Club is registered with the Information Commissioner's Office (ICO) under registration number: Z7864881

Responsibilities

• Club Bar Mangement (Steward/Ass Steward) is responsible for the overall management, operation, and maintenance of the CCTV system, ensuring compliance with this policy and data protection principles.

• Club Bar Mangement (Steward/Ass Steward) is responsible for integrating CCTV monitoring into comprehensive lone worker safety procedures.

• All employees are responsible for understanding and adhering to this policy.

• As per our Club Premises Certificate (24/02944/LACPC), all employees will be trained in the operation of the CCTV system on site to ensure the Police or authorised Council officer may immediately review the CCTV data footage at any time.

Camera Placement and Coverage

• CCTV cameras are strategically placed in visible locations to maximize their effectiveness for their stated purposes, including the safety of lone workers (i.g., the entrance, lobby, bar, snooker/pool rooms, and both external car parks. The system will be maintained and provided clear images, accurate dates and times the images were captured.

• Camera locations are regularly reviewed to ensure they remain appropriate and proportionate, avoiding areas where there is a reasonable expectation of privacy (e.g., toilets) unless exceptional circumstances dictate otherwise with clear legal justification and a documented Data Protection Impact Assessment (DPIA).

• Specific consideration is given to areas where lone working occurs, with camera placement designed to provide maximum safety coverage.

• Clear and prominent signage is displayed at the entrance to all CCTV-monitored areas, informing individuals that CCTV is in operation, its purpose, and providing contact details for further information.

Data Collection and Storage

• Data Minimisation: Only necessary and relevant footage will be collected.

• Image Quality: Footage will be of sufficient quality to serve its purpose, particularly for identification of safety or security incidents.

• Retention Period: Recorded CCTV footage will be stored for a period of 28 days from the date of recording, after which it will be securely and permanently deleted, unless required for an ongoing investigation, legal proceeding, or for health and safety purposes related to a specific incident involving a lone worker.

• Security: CCTV footage will be stored securely to prevent unauthorized access, alteration, or disclosure. This includes robust technical and organizational measures such as encryption, strong access controls, network segmentation, and secure physical storage.​

Access to and Disclosure of Footage

• Internal Access: Access to live and recorded CCTV footage is strictly limited to authorized personnel who require it for legitimate purposes related to their duties. This includes all members of employees (as per our Club Premises Certificate (24/02944/LACPC).

• Access for Lone Worker Monitoring: Designated club management specifically assigned to lone worker oversight will have controlled access to relevant live and recorded footage. This access is solely for the purpose of monitoring lone worker welfare, responding to alerts, or investigating safety incidents.

• External Disclosure: CCTV footage will only be disclosed to third parties under strict conditions, including: Law enforcement agencies (e.g., police & licensing officer) for the prevention or detection of crime, in response to a lawful request or warrant.

• Regulatory bodies (e.g., HSE, ICO), in response to a lawful request.

• Individuals who are the subject of the footage, upon a valid Subject Access Request (SAR), in accordance with data protection legislation, ensuring the privacy of other individuals captured in the footage is protected (e.g., by blurring or obscuring).

• Legal representatives in connection with legal proceedings.

• In cases of genuine and imminent emergency, where there is an immediate threat to life, serious injury, or property, and were obtaining formal consent or a warrant is not practical or possible.

• All requests for access or disclosure will be documented and reviewed by club management to ensure compliance with this policy and relevant legislation.

External Viewing on Mobile Devices for Lone Worker Safety

• Purpose: The provision of external viewing on mobile devices is specifically authorized to enhance real-time monitoring capabilities for lone workers, enabling prompt response to potential safety incidents and providing situational awareness to designated personnel. It is a critical component of our lone worker safety strategy.

• Authorization: Access to external viewing on mobile devices is strictly restricted to a limited number of explicitly authorised individuals who have direct responsibility for lone worker safety and incident response. These individuals will typically include: Club Steward/Ass Steward.

• Secure Access: Access to the CCTV system via mobile devices will be secured using robust, unique passwords that are changed regularly and meet complexity requirements.

• Multi-factor authentication (MFA) is mandatory for all mobile viewing access.

• Mobile devices used for viewing must be encrypted, password-protected, and kept physically secure.

• Users are strictly prohibited from sharing their access credentials or allowing unauthorized individuals to view footage.

• Usage Guidelines for Lone Worker Monitoring: Mobile viewing is for legitimate lone worker safety and security purposes only. Users must exercise extreme caution to ensure privacy and data security when viewing footage, especially in public places or where others may inadvertently view the screen.

• Live monitoring should primarily occur in a private, secure environment to prevent unauthorized viewing.

• Recording or capturing still images from the mobile viewing feed is strictly prohibited unless explicitly authorized for a legitimate investigative or emergency response purpose (e.g., documenting an incident for emergency services) and in strict compliance with data protection laws. Any such authorised captures must be immediately transferred to secure organizational storage and deleted from the mobile device.

• If a mobile device used for CCTV viewing is lost or stolen, it must be reported immediately to management so that access can be immediately revoked and an incident response initiated.

• Mobile viewing should complement, not replace, other established lone worker safety procedures (e.g. call checks)

• Monitoring and Audit: All access to mobile viewing, including login times, duration, and user activity, will be logged and regularly audited to ensure compliance with this policy. Any unauthorized access attempts or suspicious activity will be immediately investigated, and disciplinary action may be taken.

Data Protection Impact Assessment (DPIA)

A comprehensive DPIA has been conducted for the CCTV system, particularly considering the increased risks associated with lone worker monitoring via mobile devices. This DPIA identified and assessed privacy risks and established mitigation measures to ensure compliance with data protection principles. The DPIA is reviewed regularly.

Subject Access Requests (SARs)

Individuals have the right to request a copy of their personal data, including CCTV footage, under data protection legislation. All SARs must be submitted in writing to the bar management (Steward/Ass Steward).  Hartley & District Social Club Ltd will respond to SARs within the statutory timeframe, subject to verifying the identity of the requester and ensuring the privacy of other individuals captured in the footage.

Complaints and Breaches

Any concerns or complaints regarding the operation of the CCTV system, the use of mobile viewing for lone worker monitoring, or potential breaches of this policy should be reported immediately to bar management (Steward/Ass Steward). All complaints will be investigated promptly, and appropriate action will be taken. Serious breaches will be reported to the ICO where legally required.

Review of Policy

This CCTV Policy will be reviewed periodically, at least every 12 months, or whenever significant changes to legislation, technology, organizational practices, or lone working procedures, to ensure its continued effectiveness and compliance.

Policy Owner

This policy is owned by Hartley & District Social Club Ltd.

Contact Information

For any questions or concerns regarding this CCTV Policy, or to make a Subject Access Request, please contact:

info@hartleysocialclub.com

01474 704857

Hartley & District Social Club Ltd

The Club House, Ash Road

Hartley, Kent

DA3 8EH

 

Policy Approval:

Approved by: Hartley & District Social Club Ltd Committee

Signed: L.Brown

 

Position: Club Secretary

Date: 27th July 2025