CCTV/IP Camera Security Policy

Last Updated: 21/12/22

Purpose

The purpose of this document is to outline the CCTV and IP Security Camera Policy at The Avenue Lawn Tennis Squash and Fitness Club. (The Club).

Background

The club has CCTV cameras installed and is registered with the Information Commissioners Office (ICO). This subscription is paid to the ICO on an annual basis. The data storage (hard drive) for the legacy CCTV is located in the club office, which is locked and alarmed when not staffed. Recently three IP Cameras have been installed which cover the three squash courts. The camera covering Court 3 also covers the corridor and door which lead to the gym, function room and tennis courts. The data that is stored on a MicroSD inside each camera is accessed from an iOS application.

Policy

The squash courts are monitored by three IP Cameras for security and court protection. There is one camera per squash court.

The footage will be accessed only in the event of a breach in security or the damage of a court. This will be from a single, club owned mobile phone that is held securely under lock and key in the club office.

The mobile phone will also be protected by a complex password, which will be stored in a sealed envelope in the club safe. The sealed envelope will only be opened on club premises, and only when two Management Committee members are present to review footage. Both Management Committee members will sign the sealed envelope upon opening, evidencing the access.
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The device will only be accessed for the purpose of reviewing footage for security, damage to the squash courts or for periodic software updates and patches.

Footage that is to be reviewed on the legacy CCTV will follow a similar procedure to the IP Cameras. Two Management Committee members will need to sign a record of access, and the footage will only be reviewed onsite, on the office computers.

There are five legacy CCTV cameras at The Club, covering the front gate by the office, the bar and lounge area, the front door and corridor, the car park, and the area outside the gym and hard-court access.

Data Retention Period

1. Each IP Camera has a 128GB MicroSD card installed, which will store a maximum of nine days of
   footage. Each IP Camera is set to record 24 hours a day on a continuous loop, overwriting the oldest
   data first.
2. The legacy CCTV has a hard drive of 150GB size and stores footage for approx 30 days.

Camera Access

1. Three IP Cameras – Access to the club via fob would be required to gain building access. The Cameras
   are mounted at height behind a cage that is secured to the walls by 3 x screws.
2. Five legacy CCTV cameras that are connected to a hard drive located in the office. Access to footage
   on these cameras would be via the Office computer using the password that is stored securely on Password Safe on that device, access to which is limited to Sarah Grady and Justine Brown. The office is locked and alarmed when not occupied. These cameras are situated in the bar, inside the front door, outside the office facing the gate, at the end of the balcony by the gym and the last one covering the car park.

Data Encryption

1. IP Cameras – there is no data encryption on the MicroSD Cards. Access to the MicroSD cards would be
   facilitated by removing the protective cage and taking the camera off the wall. Note that the Micro SD Card would need a reader and a working knowledge of the directory structure to access the data, aligned to the fact that a suitable video or streaming software would be required for access.
2. Legacy CCTV cameras – there is no data encryption, however the system used to access the footage stored on the CCTV hard drive is located in the office, which is controlled by key access and is alarmed. The password for the CCTV access is known by The Club data controller Justine Brown.

Image Quality

1. IP Cameras – all videos are stored at 1080p resolution.
2. Legacy CCTV cameras – all videos are stored in PAL format at 720p resolution.

Approval

This CCTV/IP camera Policy has been approved by:

The Management Committee Date: 07.02.2023

Welfare Officer: Julia Baker Date: 28.02.2023

Welfare Officer: Victoria White Date: 05.03.2023

Review

This policy will be reviewed every two years, or earlier if there is a change in national legislation and/or guidance.