CIU Legal Consultant Allyn Walton gives a brief overview on what clubs need to be aware of when it comes to the use of CCTV on their premises, including the six key rules governing the use of cameras and footage
There are many guidelines on the internet which go into minute detail about use of CCTV. Feel free to use them if you like BUT maybe you might just want to read these six rules (with some helpful examples) and that could do the trick? Here are the Rules:
Use of CCTV must always be for a specified purpose
CCTV use must respect an individual’s privacy
There must be clear responsibility, accountability and transparency
Images should not be stored any longer than is strictly required
Access to retained images should be restricted and subject to proper security
Clear rules, policies and procedures must be in place
Rule 1 CCTV is very useful when it comes to: crime prevention/detection internally involving members of staff and externally (e.g. the car park); enhancing the safety and security of your members and even access control BUT use it for nothing else unless its lawful and reasonable. Simple really, but please make sure you DON’T go beyond these reasons otherwise you might get in trouble, especially in places like toilets, even if there is a legitimate reason (i.e. to prevent vandalism and drug abuse).
Rule 2 Even if someone is just passing by walking their dog the images on your club’s CCTV are their private data. Signs must go up to warn people which will have been provided by your installer. Split screen displays which show everything and are very useful for an overview, MUST NOT be visible to the membership or non-designated staff members. So ideally put that in a separate room and keep the door locked or if you need access (due to a lone worker on the bar) then make sure it is hidden or angled away from the public.
Rule 3 Notice boards should tell members (and visitors for that matter) who’s in charge of CCTV. That person must have a full understanding of the legal and technical aspects and if necessary, have training to do the job properly. They should know that non-compliance can have consequences for themselves and the club.
Rule 4 This is perhaps the most important rule. Keep images only as long as you are expected to, that is, no longer than the purpose that is required.
Rule 5 No-one other than a designated person should have access to the CCTV images. This includes Smartphone access, which should only be to a small number of committee members. Under no circumstances allow CCTV images to be posted on Social Media or even shown in the club on those mobile screens. They might be funny to you but can lead to fines, prosecutions and even dismissal from employment.
Rule 6 Make sure that your policies and procedures, which will have been provided by your installer, are available to your members on request.
Disclaimer I hate these, but because this is a complex area it can’t be covered properly in a short article like this. Contact for further advice on CCTV and GDPR is available from the Information Commissioner’s Office - www.ico.org.uk

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