Hull City

CCTV Policy

The Super Stadium Management Company uses closed circuit television (CCTV) to provide a safe and secure environment to ensure the safety of our staff, customers, and suppliers and to protect all the companies’ properties.

We aim to set out how we manage the use of CCTV, the equipment and the images produced in compliance with GDPR and the CCTV code of practice.

SMC CCTV fixed systems record images only, there is no audio recording.

1. Purpose of CCTV

The overall purpose of CCTV is to help reduce the fear of crime for SMC staff and Visitors / Tennant and Contractors and to protect the SMC premises from criminal activities.

To assist in the prevention and detection of crime against both persons and property.

To assist in the identification, apprehension and prosecution of offenders.

To assist in the security of all property belonging to the SMC and to employees and visitors of the related premises.

To ensure compliance with HSE rules and company procedures.

To assist with the identification of unauthorised or unsafe working practices that result in disciplinary proceedings being instigated against employees, third party operatives and contractors.

2. Location of cameras

Cameras are located at strategic points in and around the Stadium and the SMC associated premises to include the Hull City Training Facility principally the entrance and exit points.

SMC have positioned cameras so that they only cover communal or public areas that focus on the company’s business premises and they are sited to ensure clear images are provided.

Cameras may be temporarily set up covertly in certain high risk situations at the discretion of the Safety operations team or the Facilities Manager.

Appropriate signs are prominently displayed so all staff, visitors are aware they are entering a fully operational CCTV area.

Maintenance checks of the equipment are undertaken on a regular basis to ensure it is working properly and is producing high quality images.

3. Recording and retention of images

CCTV images are recorded on a 24hour basis, or only certain times as the business dictates.

Images produced by the CCTV equipment are intended to be as clear as possible so that they are effective for the purposes set out above.

As the recording system records both analogue and digital images, any CCTV images that are held on the hard drive of a PC or server are deleted and overwritten on a recycling basis and are not held for more than 28 days, Images are not stored on, or transferred on to, removable media such as CDs unless the image is requested by the SMC management team for the purpose of investigating an incident, disturbance or damage to intellectual properties under the control of the SMC, or where a law enforcement agency is investigating a crime as images may need to be retained for a longer period. SMC will erase or destroy the storage once the purpose of the recording is no longer relevant.  In normal circumstances, this will be a period of 28 days…

4. Access to and disclosure of images

Access to the recorded images should be restricted to an authorised member of staff. All accessing or viewing of recorded images should only occur within a restricted area and other employees will not be allowed to have access to that area or the images when a viewing is taking place.

The images that are filmed are held in a secure location with restricted access. Images that have been authorised for removal for viewing purposes will be documented in accordance with this policy.

Disclosure of images to other third parties will only be made in accordance with this policy and limited to:

The police and other law enforcement agencies to assist in the prevention or detection of a crime that may lead to prosecution of an offender or identify a witness.

Prosecution agencies such as the Crown Prosecution Service.

The SMC management team or authorised representatives involved in an internal disciplinary process or a legal action against a third party under disputes or bringing the SMC, Hull City or it’s associated companies into disrepute.

All requests for disclosure and access to images will be documented, including the date of the disclosure, to whom the images have been provided and the reasons why they are required. Disclosure may be declined by the SMC management team, all reasons and will be recorded.

5. Individuals’ access rights

Under GDPR, individuals have the right on request to receive a copy of the personal data that the Company holds about them, including CCTV images if they are recognisable from the image.

If you wish to access any CCTV images relating to you, you must make a written request to the Data Compliance Officer by email to [email protected] or by post: Data Compliance Officer, KCOM Stadium, West Park, Hull, HU3 6HU. Your request must include the date and approximate time when the images were recorded and the location of the particular CCTV camera, so that the images can be easily located and your identity can be established as the person in the images.  The Company will respond within 40 calendar days of receiving the request.

The Company will always check the identity of the person or employee making the request before processing it.

The DCO will first determine whether disclosure of your images will reveal third party information as you have no right to access CCTV images relating to other people.  In this case, the images of third parties may need to be obscured if it would otherwise involve an unfair intrusion into their privacy.

If the Company is unable to comply with your request because access could prejudice the prevention or detection of crime or the apprehension or prosecution of offenders, you will be advised accordingly. All the above actions will be documented in accordance with our policies and procedures.

6. Covert recording to include body worn cameras, ANPR and the use of Drone recording.

The Company will only undertake covert recording in accordance with our policies and procedures underwritten by the SMC senior management team. We operate covert recording for the safety of our employees, contractors, visitors or potential damage or disruption to the intellectual property owned or managed by the SMC, where there is good cause to suspect that criminal activity or equivalent malpractice is taking, or is about to take place. Announcements will be made that covert recording is taking place at the time of the incident, however we reserve the right to inform the individuals concerned that the recording is taking place if it would seriously prejudice its prevention or detection.

Covert monitoring may include both video and audio recording.

Covert monitoring will only take place for a limited and reasonable amount of time consistent with the objective of assisting in the prevention and detection of particular suspected criminal activity or equivalent malpractice.  Once the specific investigation has been completed, covert monitoring will cease.

Information obtained through covert monitoring will only be used for the prevention or detection of criminal activity or equivalent malpractice and will be retained as per this policy. All other information collected in the course of covert monitoring will be deleted or destroyed unless it reveals information which the Company cannot reasonably be expected to ignore.

Covert monitoring definitions:

Body Worn Videos (BWV) is an overt method by which staff may obtain and secure evidence for the purpose or preventing or detecting criminal activity only and is for the safety of our operatives should they encounter aggressive or criminal behaviour.

Automatic number plate recognition (ANPR) is a technology for automatically reading vehicle number plates and is used to help detect, deter and disrupt criminality including tackling organised crime groups and terrorists. SMC will notify if ANPR is being used in areas other than the management of staff parking. It will operate within this policy for storage and retention and will not be used for any other activates other than the purpose it’s installed for.

Drone photography is the capture of still images and video by a remotely-operated or autonomous unmanned aerial vehicle (UAV), also known as an unmanned aircraft system (UAS).

The use of Drone Photography is strictly prohibited within the stadium, its boundaries and any other properties managed or owned by the SMC and its subsidiary companies. All requests to use a Drone will be subject to SMC senior management team approval and will be in accordance with the aviation laws governed by the CAA.

7. Staff training

Training will ensure that all employees handling images or recordings are trained and given Guidance in the requirements of the law and impact of GDPR with regards to the CCTV systems.

Staff will be fully briefed and trained in respect of all functions, both operational and administrative relating to CCTV control operation.

8. Implementation

The Data Compliance Officers are responsible for the implementation of and compliance of policies and procedures. The SMC senior management team are responsible for the operation of the CCTV system and will conduct regular reviews on the use of CCTV, BWV, ANPR and Drone recording on the properties it owns or manages in respect of its use through regular reviews, audit and records kept on all activates.