RANBY VILLAGE HALL CLOSED CIRCUIT TELEVISION (CCTV) POLICY

1. Introduction

1.1. This document sets out the Ranby Village Hall’s policy on the use of Closed Circuit Television (CCTV).

1.2. The purpose of this policy is to ensure that CCTV is used responsibly, lawfully, and in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018).

1.3. This policy applies to all staff, contractors, volunteers, and visitors to the facility.

2. Purpose of CCTV

2.1. CCTV is installed to:
- Deter and prevent crime or vandalism
- Protect property
- Ensure the safety of staff, visitors, and contractors
- Assist in the management and security of the premises

2.2. The system may include fixed cameras, with audio recording.

2.3. The lawful basis for processing personal data via CCTV is legitimate interests, as permitted under UK GDPR Article 6(1)(f). A Legitimate Interests Assessment (LIA) has been conducted and is retained on file.

2.4. The facility has undertaken a Data Protection Impact Assessment (DPIA) to ensure that the rights and freedoms of individuals are protected.

3. System Operation

3.1. CCTV is monitored by authorised staff only.

3.2. Cameras are positioned to capture only images necessary for the purposes stated above.

3.3. Cameras are not placed in locations where individuals have a heightened expectation of privacy, such as toilets or changing rooms, unless legally justified.

3.4. Cameras cover external entrances/exits and shared indoor area, namely the main hall.

4. Signage

4.1. Clear, prominent CCTV warning signs are displayed at all entrances and in areas under surveillance.

4.2. Signs indicate the purpose of CCTV use, contact information, and where individuals can find further information about accessing footage.

5. Storage and Retention of Images

5.1. Recorded images are retained for a maximum of 28 days, unless required for an ongoing investigation or legal proceedings.

5.2. The retention period is reviewed periodically and justified based on operational and security needs.

5.3. Recorded images are stored securely, with access restricted to authorised personnel.

6. Access to CCTV Footage

6.1. Access is limited to any authorised staff that require it for legitimate purposes with agreement from the committee.

6.2. Individuals have the right to request access to footage relating to themselves under UK GDPR (Subject Access Request).

6.3. Requests must be submitted in writing to the committee and include sufficient details (date, time, location) to identify relevant footage.

6.4. No fee is charged for making a Subject Access Request.

6.5. Access may be refused where it would prejudice the rights of others, compromise security, or interfere with ongoing investigations.

7. Disclosure to Third Parties

7.1. CCTV footage will only be disclosed to third parties in the following circumstances:
- To law enforcement or regulatory authorities investigating a crime or suspected illegal activity
- To authorised personnel for legitimate operational purposes

7.2. Requests for disclosure must be submitted in writing and approved by the committee.

8. Complaints

8.1. Complaints about the operation of the CCTV system should be directed to the committee within 14 days.

8.2. Any complaints will be investigated promptly in accordance with the facility’s complaints procedure.

9. Review and Updates

9.1. This policy is reviewed at least annually or whenever there is a change in legislation or operational requirements.

9.2. Any amendments are approved by the facility’s committee.

10. References

- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018
- ICO Guidance: CCTV and Video Surveillance: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/cctv-and-video-surveillance/