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Blairgowrie, Rattray & District Angling Association

CCTV (Closed Circuit Television) Policy    

1. General Information 

1A.  The installation of CCTV surveillance has been completed to deter and reduce vandalism, fly tipping, theft, littering and anti-social behaviour in and around the area of Whiteloch Farm, Farmhouse & the Angling Facilities.
1B. The CCTV system is a standalone fixed system with 9 cameras recording video images
1C.  Registration with the ico, (Information Commissioner’s Office) in accordance with legal requirements has been carried out and complies with the GDPR / Data Protection Act 2018. This policy will be revisited annually and updated when required to comply with any new legislation introduced. The reference number for registration is ZB283006.
1D.  Farm CCTV operators comply with
ico, Code of Practice and are aware of their responsibilities in compliance with GDPR regulations.

1E. Each person having access to the system will use it in a responsible manner without disclosing images to unauthorised persons.

 2.  Justification for Installation 

2A. The camera system has been installed for the following reasons:
 To protect the assets, buildings and properties including their contents in the immediate area 24 hours per day. 
 To improve the safety and security of all persons using the paths, as well as anglers and other authorised visitors vehicles, their possessions & contents.

 To support the Police in an effort to detect and deter criminal activities and to assist in apprehending, identifying and prosecuting offenders.

   The CCTV images recorded will only be used for the prevention, reduction and identification of those committing crimes whilst present on the locations noted above. 
   The camera system will help provide a safe and secure environment for members of the public, farm visitors, residents, anglers and farm workers.

 3.  Camera Locations & coverage.

 3A. Whiteloch Farm Buildings, Whiteloch Farmhouse, Whiteloch Pier Area, Fingask Boathouse (Inside & Out), Fingask Pier, Car Parks, Paths and Roads in close proximity. 
3B. The images recorded are from 9 cameras sited to record activities in and around the above locations. 
3C. The privacy expectations of persons present will not be compromised as images will only be viewed where justified if an incident occurs at locations as per description in item 2.A  .

 4. Covert Surveillance.

4A.The system has no cameras which will be used to engage in covert surveillance.

 5. Public Notification  

5A. The CCTV GDPR Policy will be available to view by the general public on the Angling Association website   on Facebook Angling Association site,  (Members only) and by request to Whiteloch Farm.
5B.  Signage is clearly located in areas where cameras are operating with contact details on larger signs (4).
5C. The cameras in use are all clearly visible by persons present in the areas under observation.

 6. Images Retention and Storage  

6A. The CCTV images are stored for a period of 30 days and are then automatically deleted from the system.
6B. If images are requested by the Police they will then be supplied as a section of recorded images with date / time verification. These images may be held where Police request identification of issue in association with investigation or prosecution.
6C. Images recorded are transmitted by cable or WIFI to remote recording units (2) which are both securely located. Access to these units and the images stored therein is securely restricted to 3 persons.
6D.  Each person represents the interests of the Farm, Angling Association or Farmhouse but collectively all 3 can access images if or when there is a justifiable reason to do so.
6E. The viewing of images will normally be instigated by the reporting or discovery of an incident
which has occurred and may have been recorded by the cameras present. The vast majority of images recorded will not be viewed at all and will be deleted at the end of a 30 day period unless there is valid reason to keep them. Images that are viewed will not be released to other persons unless they qualify as per following qualifying descriptions contained in notes 7 & 8.

7. Access.

 7A.  At certain times images may be viewed where identification of persons, vehicles, times etc. are justified to achieve the objectives of CCTV installation as listed in 2.0 . At these times the observers of images will have their access and comments logged and their authority to view images verified.
7B. On receipt of a disclosure request then details of the disclosure must be recorded and records kept.
Information required includes, but is not limited to, the following. 
     Date, time, data subject of request.·       
     Name of person who is making request.·       
     Organisation they represent.·
     Verified authority to make request.·      
   Reason why request was made (may not always be required).·       
     Method of providing data e.g. by recorded video disc, by observation of recorded data. 
7C. Where relevant on request the recorded images may be accessed or viewed by;·
The Police or their authorised agents where a crime or suspected crime is being investigated on the request of the operators of CCTV or has been reported by a data subject.· 
The Police where investigating a crime or suspected crime that has been reported to them as taking place at this location.·      
Where a complaint of illegal or anti-social behaviour is being investigated by the Police as occurring within the area covered by the CCTV coverage.·    
  The HSE (Health and Safety Executive) where children are involved.·    
  Police or CCTV operators to assist in recognition and identification of juveniles so that unacceptable behaviour can be reported to their parents, or guardians. ·   
 Data subjects and their legal representatives pursuant to a legitimate SAR (Subject Access Request).·   
 Where individuals or their legal representatives request access subject to a court order.·   
  Insurance company where they are in pursuit of evidence to substantiate a claim where damage has occurred to insured property at this location.

8. ( SAR ) Subject Access Requests   (Recorded images of yourself)

 8A. The Data Protection Act gives individuals the right to request access of CCTV footage  which relates to themselves but not to others unless approved by legitimate bodies as covered in section 7A to 7C.
 8B. Whiteloch Farm operators of CCTV will respond to these requests within 30 days of receipt of request.Required information will include location, date, time of presence, subject data / description and name of person making request. Provided information will be recorded.
 8C. Access to view requested images may be denied where they might prejudice an authorised active investigation or the legal rights of third parties.
 8D. Where data is supplied in the form of either a still picture, a series of pictures, a video or disc format then details of other parties may be obscured if not relevant to request. At time of release of this data then details of authorised viewing body, reason for request and name of person making request will be recorded.
 8E. Where 3rd parties are present their images may be obscured prior to release in any form.  
 8F. Where a request to view data images recorded concerns other persons present to prove criminal activity, vandalism, anti-social behaviour etc. then the incident may require to be reported to the Police before images are permitted to be accessed.

 9. Complaints Procedure.

In first instance complaints should be directed to Whiteloch Farm. PH10 6QN.
All complaints will be investigated and discussed, if resolution of the complaint is not achieved to the complainer’s satisfaction then they are encouraged to contact the
ico, (Information Commissioner’s Office) to discuss the matter as required.

Helpline Number 03031231113  Website

10.  Review.

10.A The policy will be reviewed ;

·        On an annual basis.

·        Where there have been changes to updated legislation .

·        If there is requirement to review through changes to system or its controllers.

·        After an investigation or a SAR has been conducted to test the capability and suitability of the system and its requirements.

·        Where a complaint has been made whether upheld or not. 


Policy Creation date  February 2022,. Name… For P. Lock (BRDAA Sec.) Changes N.

Policy Review dates………………………………. Name………………………………………………………. Changes Y / N.





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