CCTV Policy

This policy explains how Renowned Martial Arts (the “Academy”) uses closed-circuit television (CCTV) at our premises. It covers why we use CCTV, where our cameras are, how footage is stored and protected, who can see it, how long we keep it, and what your rights are.

This policy applies to everyone who enters our premises, including students, trial participants, parents and guardians, visitors, coaches, staff, and contractors.

We operate our CCTV system in line with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and guidance published by the Information Commissioner’s Office (ICO).

This policy should be read alongside our Privacy Policy, which sets out how we handle all personal data, including CCTV footage. Both documents are available on our policies page.

your Operating Company, as listed in Schedule A, trading as Renowned Martial Arts, is the data controller for CCTV footage recorded at our premises. This means we decide why and how the CCTV system is used and are responsible for making sure it complies with data protection law.

The day-to-day operation of the CCTV system is managed by [GAP: cctv system operator name], [GAP: cctv system operator role].

If you have any questions about our CCTV system or this policy, please contact us at admin@renownedmartialarts.uk.

We use CCTV for the following purposes:

1. To help keep everyone on our premises safe
2. To protect our property and equipment from theft, damage, or vandalism
3. To deter antisocial or criminal behaviour
4. To help us investigate incidents, accidents, or complaints
5. To support law enforcement if we are asked to provide footage in connection with a crime

Our lawful basis for using CCTV is legitimate interest under Article 6(1)(f) of UK GDPR. We have a genuine and reasonable need to protect our premises, our property, and the people inside the building. We believe this interest is not outweighed by the privacy rights of the people recorded, because we limit cameras to appropriate areas, we display clear signs, and we keep footage for a short period only.

We do not use CCTV to monitor the performance of coaches or staff, to record private conversations, or for any purpose other than those listed above.

The table below shows where our cameras are located and what each one covers.

Cameras are never placed in changing rooms, toilets, showers, or any other area where people have a reasonable expectation of privacy.

We position our cameras so that they record only the areas they need to. Where possible, we avoid recording public footpaths, neighbouring properties, or other areas outside the boundary of our premises.

Our CCTV system records video footage.

[GAP: audio recording statement]

Footage is recorded to [GAP: cctv storage method].

Where footage is stored using a cloud-based service, the provider acts as a data processor on our behalf. We have confirmed that the provider stores data within the UK or within a country that the UK government recognises as having adequate data protection standards. If you would like more information about this, please contact us at admin@renownedmartialarts.uk.

The system is password-protected. Only the people listed in section 7 can log in to view live footage or play back recordings.

The system can also be accessed remotely through a secure app or web portal. Remote access is password-protected and limited to the same authorised people listed in section 7.

Access to live and recorded CCTV footage is limited to the following people:

1. [GAP: authorised personnel list items]

Nobody outside this list may view footage unless one of the sharing circumstances described in section 9 applies.

Routine CCTV footage is automatically overwritten after [GAP: cctv retention period]. This means that, unless we take steps to preserve a specific recording, footage is not kept beyond this period.

We may keep footage for longer than the standard retention period if it is relevant to:

1. An ongoing investigation into an incident, accident, or complaint at the Academy
2. A request from the police or another law enforcement body
3. A legal claim or dispute, whether actual or reasonably expected
4. A subject access request that we are in the process of responding to

Where footage is kept for any of these reasons, it will be stored securely and deleted as soon as it is no longer needed for that purpose.

We do not make CCTV footage available to the public and we do not share it on social media. We will only share footage with a third party in the following circumstances:

1. Where we are required to do so by law, for example in response to a court order
2. Where the police or another law enforcement body requests footage in connection with the investigation or prevention of a crime
3. Where it is necessary to support legal proceedings, whether brought by us or against us
4. Where a person whose image has been recorded makes a valid subject access request for footage of themselves (see section 11)
5. Where we reasonably believe that sharing footage is necessary to protect someone’s safety

Before sharing footage with any third party, we will make sure there is a proper legal basis for doing so. Where footage also contains images of other people, we will take reasonable steps to protect their privacy, for example by blurring or obscuring their faces where it is practical to do so. In some cases, such as close-contact training footage, it may not be possible to separate one person’s image from another’s. Where this applies, we will consider carefully whether sharing the footage is still justified and proportionate before doing so.

If your image has been captured by our CCTV system, you have the same data protection rights under UK GDPR as you do for any other personal data we hold. These rights are set out in full in our Privacy Policy. In summary, they include:

1. The right to be informed about how we use CCTV. This policy fulfils that right.
2. The right of access. You can ask for a copy of any footage in which you appear. See section 11 for how to do this.
3. The right to erasure. In certain circumstances, you can ask us to delete footage of you. This right does not apply where we need the footage for a legal obligation or to handle a legal claim.
4. The right to object. You can object to the use of CCTV on the basis that our legitimate interest does not outweigh your rights. We will consider your objection and respond to you.

To exercise any of these rights, please contact us at admin@renownedmartialarts.uk.

You have the right to request a copy of any CCTV footage in which you appear. This is called a Subject Access Request (SAR). Our Privacy Policy explains the general SAR process. The steps below explain what we need from you to locate and provide CCTV footage specifically.

To request footage, please follow these steps:

1. Send your request by email to admin@renownedmartialarts.uk.
2. Tell us the date and approximate time you were on our premises.
3. Describe where on the premises you were and what you were wearing, so we can identify you in the footage.
4. We may ask you to provide a recent photograph of yourself to help us confirm which person in the footage is you.
5. We will respond within one calendar month of receiving your request. If the request is complex, we may take up to three months, but we will let you know within the first month if this applies.

Where the footage you have requested also shows other people, we will take reasonable steps to protect their privacy before providing it to you. This may mean blurring or obscuring other faces, or providing still images rather than video, depending on what is practical.

In some cases, it may not be possible to separate your image from another person’s in a meaningful way. For example, footage of close-contact training such as sparring or grappling may show two or more people in a way that cannot be redacted without making the footage unusable. Where this applies, we may withhold that specific portion of the footage in order to protect the other person’s rights. We will always explain our reasons if we are unable to provide any part of what you have asked for.

Because footage is automatically overwritten after [GAP: cctv retention period], we can only provide footage that still exists at the time we process your request. If you think you may need footage, please submit your request as soon as possible.

We display a clear sign at the entrance to our premises so that everyone is aware CCTV is in use before they are recorded. Where cameras cover a specific area that is not visible from the entrance, we may place additional signs so that people are informed before entering that area. Because our cameras also record audio, our signs make this clear so that people know audio recording is in operation before they enter.

Our signs include the name of the Academy, a statement that CCTV is in operation, and details of how to contact us if you want to find out more or exercise your rights. This is in line with ICO guidance on CCTV signage.

If you have a concern about how we use CCTV, please contact us first at admin@renownedmartialarts.uk. We will do our best to resolve your concern quickly and fairly.

If you are not satisfied with our response, or if you believe we have not handled your data lawfully, you have the right to complain to the Information Commissioner’s Office (ICO). You can contact them online at ico.org.uk/make-a-complaint, by phone on 0303 123 1113, or by post at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

We would always prefer to hear from you directly before you contact the ICO, so please give us the chance to put things right first.

We may update this policy from time to time. When we do, we will update the version number and effective date at the top of this page.

If we make a significant change to how we use CCTV, we will let students know by email or by placing a notice at the Academy before the change takes effect.