The Flex Unit Gym Ltd. CCTV Policy and Procedures

1. Introduction

The Flex Unit Gym Ltd. ("the Gym") is committed to ensuring the safety and security of all members, staff, and visitors. This policy outlines the operational guidelines for the use of Closed-Circuit Television (CCTV) on the Gym’s private property in compliance with UK and Scottish legislation, including the Data Protection Act 2018 and the General Data Protection Regulation (GDPR).

2. Purpose of CCTV

The primary purposes of CCTV at the Gym are to:

Enhance the safety and security of members, staff, and visitors.

Prevent and detect crime and anti-social behavior.

Assist in managing the Gym effectively and efficiently.

Protect the Gym’s property and assets.

3. Legal Basis

The use of CCTV is guided by the following legislation and regulations:

Data Protection Act 2018

General Data Protection Regulation (GDPR)

Human Rights Act 1998

Protection of Freedoms Act 2012

Information Commissioner's Office (ICO) Code of Practice

4. Scope

This policy applies to all CCTV systems operated by or on behalf of The Flex Unit Gym Ltd. and to all Gym locations where CCTV systems are installed.

5. Responsibilities

Data Controller: The Gym is the Data Controller and is responsible for ensuring compliance with relevant legislation.

Data Protection Officer (DPO): The DPO oversees the implementation of this policy, conducts periodic reviews, and addresses any data protection issues.

CCTV Operators: Individuals authorized to operate the CCTV system, ensuring it is used appropriately and lawfully.

6. CCTV System Management

Installation: CCTV cameras are installed in areas where there is a legitimate need for surveillance, such as entrances, exits, gym floors, and parking areas. Cameras will not be placed in private areas such as changing rooms or bathrooms.

Signage: Clear and prominent signs will be displayed to inform individuals that CCTV is in operation.

Monitoring and Recording: CCTV footage will be monitored and recorded continuously. Access to live feeds and recorded footage will be restricted to authorized personnel only.

Retention: Recorded footage will be retained for a maximum of 30 days, unless required for an ongoing investigation or legal proceeding.

7. Data Subject Rights

Individuals have the following rights regarding their personal data captured by CCTV:

Access: Individuals have the right to request access to their personal data.

Rectification: Individuals can request the correction of inaccurate personal data.

Erasure: Individuals can request the deletion of their personal data in certain circumstances.

Restriction: Individuals can request the restriction of processing of their personal data in certain circumstances.

Objection: Individuals can object to the processing of their personal data based on legitimate interests.

Requests can be made in writing to the DPO.

8. Data Security

Appropriate technical and organizational measures will be implemented to ensure the security of CCTV data, including:

Encryption of recorded footage.

Secure storage of recorded data.

Controlled access to CCTV systems and footage.

9. Sharing of Images

CCTV footage and images may be shared under the following conditions:

Protection of the Business: Footage may be shared with relevant third parties to protect the business, its property, and assets. This includes sharing with legal advisors, insurance companies, and security consultants.

Unsolicited Procedures on Business Grounds: Footage may be shared to address unsolicited procedures or incidents on business grounds, including but not limited to addressing breaches of terms of service, handling insurance claims, and responding to legal requests.

Law Enforcement: CCTV footage may be disclosed to law enforcement agencies where such disclosure is necessary for the prevention or detection of crime, or where required by law.

10. Complaints and Breaches

Any complaints regarding the use of CCTV or breaches of this policy should be reported to the DPO. All breaches will be investigated, and appropriate action will be taken.

11. Review and Updates

This policy will be reviewed annually or as required to ensure compliance with applicable laws and regulations. Any updates will be communicated to relevant stakeholders.

Contact Information

This policy ensures that the Gym’s use of CCTV is compliant with legal requirements, respects the privacy rights of individuals, and contributes to a safe and secure environment for all users while allowing for the sharing of images to protect the business and manage incidents effectively.