Video Surveillance Policy
This Video Surveillance Policy is to control the management, operation and use of the Closed-Circuit Television System, and all other surveillance systems under the control of, and owned by Ayr United Football Club, Somerset Park, Tryfield Place, Ayr.
This Policy is in accordance with the relevant legislation including the Data Protection Act 1998, the Human Rights Act 1998, and the Freedom of Information Act 2000.
The Policy will be subject to periodic review to ensure it continues to reflect the public interest.
Reference made to “The Club”, means Ayr United Football Club, reference made to “DPA” means the Data Protection Act.
(1) use of video surveillance outlined
(2) checklist for users of limited video surveillance systems monitoring (football club)
(3) systems procedures
(4) chain of custody – video record transfer
(5) video surveillance access form
- USE OF VIDEO SURVEILLANCE OUTLINED
Why do we need Video surveillance?
Ayr United Football Club requires video surveillance at Somerset Park to deter and detect crime, also to monitor individual/crowd dynamics during match day and identify troublespots.
It is also used to monitor staff and volunteers in and around the stadium, for the purpose of ensuring compliance with Health and Safety regulations, Company Policies and Staff Handbook.
What do we use the images for?
Video images captured are used to assist the Club in the detection of troublemakers and also assist with the detection of crime, images would be passed to Police Scotland on their request.
Who is legally responsible for DPA?
The legal responsibility for compliance with the DPA, is that of the data controller, Tracy McTrusty, General Manager Ayr United Football Club.
Why do we use video surveillance?
We use video surveillance at the Club, as outlined above, to deter and detect crime, and monitor individual/crowd dynamics.
To monitor correct practice of personnel within and around the stadium to minimise risk, theft or malpractice.
CCTV is the most effective means of doing this.
What are the problems it is meant to address?
The system has been installed with the aim of monitoring the area for the purposes of deterring crime, malpractice and detecting troublemakers or potential individual/crowd problems, both in and around Somerset Park.
How does video surveillance benefit us?
As outlined the surveillance system will assist the Club in the identifying and dealing with crowd/individuals and crime problems, should they arise.
Is the video surveillance system capable of delivering these benefits?
Yes, the system of cameras that have been chosen and installed by the Club, are pupose-made for the needs identified by the Club.
Can less privacy-intrusive solutions, such as improved lighting, achieve the same oblectives?
No, improved lighting helps up to a point, however the use of video surveillance is required to meet the needs of the Club in this respect.
Do you need images of identifiable individuals, or could the scheme use other images not capable of identifying the individual?
Yes, we need images of identifiable individuals in relation to the detection of crime, be it during match day or at any other time as the system operates 24/7. This is a requirement of the Scottish FA and SPFL.
What future demands may arise for wider use of images and how will you address these?
There may be a request in the future made from members of the public to access the video surveillance regarding an incident they were perhaps involved in, the potential of this happening is deemed to be very low by the Club, and it is more likely that the Police will request video footage as part of ongoing enquiries. If a request is made this will be accessed and there are video surveillance request forms available at the Club.
What are the views of those who will be under surveillance?
All staff are aware of the presence of the cameras, and there is sufficent and appropriate signage displayed at key areas of the stadium, to date no complaints have been received with regards the use of video surveillance.
2. CHECKLIST FOR USERS OF LIMITED VIDEO SURVEILLANCE SYSTEMS MONITORING BUSINESS PREMISES
We, Ayr United Football Club, have considered the need for using video surveillance, and have decided that there is a justifiable need for a system to be maintained which will assist in protecting the business premises known as Somerset Park, Tryfield Place, Ayr.
We conduct an annual review of our use of video surveillance.
Notification has been submitted to the Information Commissioner and the next renewal date recorded
There is a named individual who is responsible for the operation of the system (Roy Provan, Safety and Stadium Manager)
A system has been chosen which produces clear images which the law enforcement (usually Police Scotland) can use to investigate crime and these can easily be taken from the system when required.
Cameras have been sited so that they provide clear images.
Cameras have been positioned to avoid capturing the images of persons not visiting the premises.
There are visible signs showing that video surveillance is in operation.
Where it is not obvious who is responsible for the system contact details are displayed on the signs.
Images from this video surveillance system are securely stored, where only a limited number of authorised persons may have access to them, Roy Provan, Safety and Stadium Manager and Tracy McTrusty, General Manager.
The recorded images will only be retained long enough for any incident to come to light (e.g. for a theft to be noticed, a vandalism to be noticed) and the incident to be investigated.
Except for the Police, images will not be provided to third parties. The Club knows how to respond to individuals making requests for copies of their own images. If unsure the data controller knows to seek advice from the Information Comissioner as soon as such a request is made.
Regular checks are carried out to ensure that the system is working properly and produces high quality images.
- SYSTEM PROCEDURES
The following procedures are created by Ayr United Football Club to outline the way in which we use the video surveillance system in practice.
Terms to be aware of prior to reading the procedures:
“We” refers to Ayr United Football Club system administrators.
“Our” refers to Ayr United Football Club owned and operated systems.
“Other” refers to persons whose permission has not been given to release their images.
Our video surveillance system is in operation 24/7. Should an incident occur, of which we are aware or made aware, we may retrospectively interrogate the system to determine if we hold any footage relevant to that occurrence. Where we hold information/footage relevant to the occurrence and it is of a criminal/liable nature we would inform the relevant authority (e.g. Police Scotland).
This decision would be made by the system administrators, Roy Provan and Tracy McTrusty
The system administrators are also the system operators and as such are both aware of these Club procedures.
Where a third party requests access to our video surveillance, they would be asked to complete a Video Surveillance Access Request Form and submit a fee of £10 by cheque, along with proof of their identification which will be verified by an adminstrator.
The request would then be assessed.
If the retention period has expired or if the work involved in acquiring the relevant images is deemed arduous then no further action will be taken and the fee of £10 will be returned.
We will where possible attempt to satisfy any reasonable requests as far as is practicable.
When referring to arduous work, we mean, for example: when the “time of video capture” frame is too long and too many man hours would be required to locate the relevant images.
Alternatively where the “Approximate location” is too vague thus increasing the man hours to search too many camera views, rendering the exercise impracticable.
Where the requested images show additional person(s) or vehicle(s) a decision will be made based on the possibility of identification. Where it is possible to identify the “other” person/s or vehicle/s a decision will be made by the operator to, prevent release of the images or, obscure the identify of the “other” person/s or vehicle/s, including any distinguishing features or clothing.
- CHAIN OF CUSTODY – VIDEO RECORD OF TRANSFER
When a decision is made to release the requested video surveillance, in every circumstance a Chain of Custody – Video Record Transfer Note will be completed, with the following information,
Date of video incident, details of incident, incident number, prepared by, released by, name of person uplifting, rank and station, date and time of collection,reason for request,person uplifting if different from person requesting.
Each incident will have been allocated an individual incident number, at the time of request. In most cases this will be a release to Police Scotland. In the unlikely event of this not being the case the same form will be completed with as much information, regarding the person collecting the video record as possible.
The completed and signed form will be stored on file, held at the Club.
- VIDEO SURVEILLANCE REQUEST FORM
These request forms should contain: name of person requesting, date of incident, approximate time of incident, details of the incident, details of identification re the individual concerned and reason for request.
Completed forms will also be held on file at the Club.
This is a living document and will be reviewed on a regular basis to ensure continued compliance with data protection laws.
Roy Provan, Safety and Stadium Manager, Ayr United Football Club
Reviewed September 2015 RP
Reviewed April 2016, minor changes made (names, job titles etc.) RP
Reviewed August 2017, no alterations required RP
Reviewed and edited to include staff monitoring and name changes – November 2019 – Tracy McTrusty