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CCTV Policy


Leah Evans
Owner of CRPD
July 2022
Chrome Roses Pole Dance


1. Chrome Roses Pole Dance “CRPD” have in place a CCTV surveillance system “the CCTV system” across its 2 studios in Cardiff & Newport. This policy details the purpose, use and management of the CCTV system and details the procedures to be followed in order to ensure that CRPD complies with relevant legislation and the current Information Commissioner’s Office CCTV Code of Practice.

2. CRPD will have due regard to the Data Protection Act 2018, the General Data Protection Regulation (GDPR) 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, CRPD 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.

3. This policy and the procedures therein detailed, applies to all of CRPD’s CCTV systems and any other system capturing images of identifiable individuals for the purpose of viewing and or recording the activities of such individuals. CCTV images are monitored and recorded in strict accordance with this policy.


CCTV System overview

  1. The CCTV system is owned by Chrome Roses Pole Dance and managed by the CRPD and its appointed agents. Under current data protection legislation CRPD is the ‘data controller’ for the images produced by the CCTV system.  

  2. The Business Owner is responsible for the overall management and operation of the CCTV system, including activities relating to installations, recording, reviewing, monitoring and ensuring compliance with this policy.

  3. Signs are placed at all studio entrances in order to inform staff, students, visitors and members of the public that CCTV is in operation.

  4. The Business Owner is responsible for ensuring that adequate signage is erected in compliance with the ICO CCTV Code of Practice.

  5. Cameras are sited to ensure that they cover CRPD premises as far as is possible. focus on entrances and communal areas. Where cameras overlook residential areas, privacy screens will be fitted.

  6. The CCTV system is operational and is capable of being monitored for 24 hours a day, every day of the year.

  7. The CCTV system is subject to a Data Protection Impact Assessment.


Purposes of the CCTV system

  1. The principal purposes of CRPD CCTV system are as follows

- for the prevention, reduction, detection and investigation of crime and other incidents;

- to ensure the safety of staff, students and visitors;

- to assist in the investigation of suspected breaches of CRPD regulations by staff or students.

2. The CCTV system will be used to observe the studios and areas under surveillance in order to identify incidents requiring a response. Any response should be proportionate to the incident being witnessed.

3. CRPD seeks to operate its CCTV system in a manner that is consistent with respect for the individual’s privacy.


Monitoring and Recording

  1.  Images are recorded centrally on servers located securely in the CRPD Studios and are viewable by the business owner only. Additional staff may be authorised by the Business Owner to monitor cameras sited within their own areas of responsibility on a view only basis.

  2. The cameras installed provide images that are of suitable quality for the specified purposes for which they are installed and all cameras are checked daily to ensure that the images remain fit for purpose and that the date and time stamp recorded on the images is accurate.

  3. All images recorded by the CCTV System remain the property and copyright of CRPD.



Compliance with Data Protection Legislation

  1. In its administration of its CCTV system, CRPD complies with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. Due regard is given to the data protection principles embodied in GDPR. These principles require that personal data shall be:

a) processed lawfully, fairly and in a transparent manner;

b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;

c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

d) accurate and, where necessary, kept up to date;

e) kept in a form which permits identification of the data subjects for no longer than is necessary for the purposes for which the personal data are processed;

f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

2. CRPD ensures it is responsible for, and able to demonstrate compliance with GDPR


Applications for Disclosure of Images

Applications by individual data subjects

  1.  Requests by individual data subjects for images relating to themselves “Subject Access Request” should be submitted in writing to CRPD together with proof of identification.

  2. In order to locate the images on the CRPD 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.

  3. Where CRPD is unable to comply with a Subject Access Request without disclosing the personal data of another individual who is identified or identifiable from that information, it is not obliged to comply with the request unless satisfied that the individual has provided their express consent to the disclosure, or if it is reasonable, having regard to the circumstances, to comply without the consent of the individual.


Access to and disclosure of images to third parties

  1. A request for images made by a third party should be made in writing to CRPD.

  2. 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.

  3. such disclosures will be made at the discretion of the Business Owner, with reference to relevant legislation.

  4. Where a suspicion of misconduct arises and at the formal request of the Investigating Officer, the Business Owner may provide access to CCTV images for use in staff disciplinary cases.

  5. A record of any disclosure made under this policy will be held on the CCTV management system, itemising the date, time, camera, requestor, authoriser and reason for the disclosure.


Retention of images

  1. Unless required for evidential purposes, the investigation of an offence or as required by law, CCTV images will be retained for no longer than 30 days from the date of recording. Images will be automatically overwritten after this point.

  2. Where an image is required to be held in excess of the retention period referred to in 7.1, the Business Owner will be responsible for authorising such a request.

  3. Images held in excess of their retention period will be reviewed on a 12 monthly basis and any not required for evidential purposes will be deleted.

  4. Access to retained CCTV images is restricted to the Business Owner and other persons as required and as authorised by the Business Owner.


Monitoring Compliance

  1. All staff involved in the operation of CRPD CCTV System will be made aware of this policy and will only be authorised to use the CCTV System in a way that is consistent with the purposes and procedures contained therein.

  2. All staff with responsibility for accessing, recording, disclosing or otherwise processing CCTV images will be required to undertake data protection training.


Policy Review

  1. CRPD usage of CCTV and the content of this policy shall be reviewed annually by the Business Owner with reference to the relevant legislation or guidance in effect at the time. Further reviews will take place as required.

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