CCTV Policy

Introduction

Aspire Gyms uses CCTV for the purposes of the prevention and detection of crime and in order to recognise and identify individuals with a view to taking appropriate action where necessary.

This policy sets out the accepted use and management of CCTV equipment and images to ensure that the Aspire Gyms comply with the Data Protection Act 2018 and other relevant legislation. We process personal data in line with our Privacy Policy.

This policy and procedure applies to all Aspire Gyms sites.

Responsibility for the management of the system

The Management Team has overall responsibility for the maintenance of the system. They will periodically check the equipment and arrange for the suppliers to carry our periodic maintenance checks.

The Management Team will ensure that images are deleted in accordance with the retention policy, see below. Members of the Management Team will have access to the recorded images during the maintenance of the systems but will under no circumstances routinely view, disclose or retain copies of the recorded images.

Members of the Management Team will be trained in the operation of the CCTV system, and will be aware of the data protection compliance requirements in line with the Code of Practice.

Auditing the system’s operation and working practices

The Management Team is responsible for ensuring that this policy and its implementation is compliant with Data Protection Legislation, and will audit the system’s use on a periodic basis.

The Management Team is responsible for dealing with and responding to any requests for access to images made by CCTV Policy, V2.0 August 2023 Page 4 of 6 individuals under the Data Protection Act 2018. Any requests received by Aspire Gyms for access to images must be forwarded to the Management Team to be progressed using existing procedures.

Access to and disclosure of images

The Management Team is responsible for viewing images when investigating an incident or suspected incident.

Images may also be accessed by the relevant Manager if necessary as part of a disciplinary investigation. Images may then be disclosed as part of the evidence assembled by the Investigating Manager in the event of a disciplinary hearing.

Secure storage and retention of images

Images will be stored on the recording equipment which will be securely protected. The Management Team have responsibility for ensuring that the equipment and the routinely recorded images have the necessary security. Images are routinely retained for 14 days, but may be retained longer in the event that they are required as part of an investigation.

Where images have been retained for an investigation the Management Team will take responsibility for the secure storage of those images.

Siting of cameras

Aspire Gym Hale

1 x CCTV camera pointing at the entrance doors
1 x CCTV camera pointing at the reception area
1 x CCTV camera covering the gym floor

It should be noted that Aspire Gyms are based at sites where building landlords may operate their own external CCTV systems for the purposes of security and crime prevention/detection.