We are committed to ensuring that your privacy is protected and we will never release your personal details to any third party without your express consent. When you complete an application to join the club certain personal information is collected from you (for example: your name, email address, gender, golf handicap, type of membership sought). You can be assured that it will only be used in accordance with this privacy statement.
What do we collect
We may collect the following information:
Name and Surname
Date of Birth
Bank Details (if applicable)
What we do with the information we gather
We require this information to administer your membership and to provide the products and services you have requested from us and provide you with a better service for the following reasons:
Internal record keeping.
Sending subscription notices to you.
Recording financial transaction to your subscription account.
Contacting you with relevant club correspondence.
Maintaining a record of any competitions you play in.
Maintaining a record of your handicap and related GUI Number.
Providing you with a Members Card for gaining access to the club facilities.
Confirm your handicap to other Golf Clubs if they request confirmation of your handicap for any competitions you have entered with them. Bandon Golf Club will retain your personal information in our Club Membership Database for the duration of your membership. We take your privacy seriously and all such information is held on secure servers within the Republic of Ireland. Bandon Golf Club complies with all applicable Data Protection Regulations. We may change/update this policy as is necessary and will notify you accordingly. This policy is effective from 29/5/2018.If you have any queries regarding your data you may contact the Data Control Officer at 023/8841111.
Under General Data Protection Regulations you have the right to contact the Data Commissioner’s Office if you are unhappy with the way your data is being processed.
The Club Data Protection Officer is the Honorary Club Secretary (Patrick Kehoe)
1.0 Introduction Bandon Golf Club, as a data controller, processes the personal data of individuals through its use of Closed Circuit Television (CCTV) on its premises at Castlebernard, Bandon, Co. Cork. Recognisable images captured by CCTV systems are personal data and are therefore subject to the provisions of the General Data Protection Regulation (GDPR) and the Data Protection Acts 1988-2018 [hereafter referred to as “data protection legislation”].
2.0 Purpose of Policy The purpose of this policy is to regulate the use of CCTV in the monitoring of both the internal and external environs of Bandon Golf Club. The aim is to ensure that CCTV is used transparently and proportionately in accordance with data protection legislation, the Club’s Data Protection Policy and guidance provided by the Data Protection Commission.
3.0 Scope This policy relates directly to the location and use of CCTV and the monitoring, recording and subsequent use of such recorded material. It applies to staff, members and visitors to Bandon Golf Club.
4.0 Proportionality The Club at all times will operate its CCTV system for the purposes outlined herein in a proportionate, measured and reasonable manner.
5.0 Ownership of the CCTV System Bandon Golf Club is the data controller and all recorded material is the property of Bandon Golf Club.
6.0 Purposes of CCTV CCTV surveillance is employed for the following purposes:
6.1 Security: To assist in providing for the security of members, staff and visitors; to periodically monitor and protect Bandon Golf Club buildings and facilities; to assist in the prevention and detection of crime; and to prevent the loss or damage to the property of members, visitors or employees.
6.2 Risk Management: To assist in providing for the safety of members, staff and visitors; to assist in the resolution of incidents involving workplace hazards, injuries or near misses; to assist in the processing of allegations/claims against Bandon Golf Club.
6.3 To assist Bandon Golf Club where its grievance or disciplinary procedures have been invoked. CCTV surveillance will not be used to monitor individuals to gather evidence to invoke a procedure.
6.4 To enable Bandon Golf Club to respond to legitimate requests from third parties for CCTV footage of incidents e.g. for legal proceedings or insurance investigations.
7.0 Lawful Basis The lawful basis permitting the processing of images of individuals for the above purposes is Article 6(1)(f) of the GDPR i.e. the processing is necessary for the legitimate interests pursued by Bandon Golf Club and its members, visitors and staff.
8.0 Signage Signage is displayed at prominent locations throughout the Golf Club so that members, staff and visitors are aware that CCTV cameras are in use
9.0 Installation and Maintenance of the CCTV System CCTV systems are installed and maintained by a PSA licensed CCTV company contracted by Bandon Golf Club. The CCTV company operates under the instruction of Bandon Golf Club and provides Bandon Golf Club with assistance in pixelating images of 3rd parties when an approved access request is received. In so doing, the CCTV company is considered to be a data processor. Data protection legislation places a number of obligations on data processors, including having appropriate security measures in place to prevent unauthorised access to data or unauthorised alteration, disclosure or destruction of data. The Golf Club will put in place contracts with CCTV companies, clearly setting out the responsibilities and liabilities of both parties.
10.0 Management, Storage & Retention of CCTV Footage The systems are managed by the following data controller: Bandon Golf Club – Honorary Secretary (firstname.lastname@example.org) Recordings are stored on a computer hard-drive accessed only by authorised personnel. Viewing is restricted to authorised personnel. Camera monitors are located in areas where they are kept out of view of staff, students and visitors. In accordance with data protection legislation, CCTV footage is retained for no longer than is necessary. All recordings are retained for a maximum of 30 calendar days. After this time, they are safely deleted. When used in conjunction with an investigation or as evidence, recordings may be retained by request specifically in that context until the issue is resolved. After this period, images are safely deleted. Camera operators shall act with utmost probity at all times and be mindful of exercising prejudices which may lead to complaints of the system being used for purposes other than those for which it is intended. Footage shall not be copied (e.g. by using a mobile phone).
11.0 Procedure for Handling Access Requests. Disclosure of images from the CCTV system is controlled and consistent with the purposes for which the system exists. All requests to access CCTV footage are channelled through the data controller. All access to images is logged.
11.1 Subject Access Requests Individuals have the right to access their personal data including their image in CCTV recordings. Requests shall be made in writing to the data controller, either by email or using a ‘CCTV REQUESTS - Subject Access Request Form’ (see below). Bandon Golf Club aims to respond promptly and at the latest within one month of receiving a valid request. Downloading of footage is carried out by the data controller. Recorded material is handled with care and in a confidential manner to ensure complete regard for individual privacy. Footage is downloaded onto a DVD or memory stick; a copy is given to the requester and a copy is retained by Bandon Golf Club in a secure location. Where CCTV images reveal other individuals, their faces are pixilated so that they are not recognisable. The footage in question is retained until the purpose for which it was downloaded has ended, at which point the footage is safely and permanently deleted. Concerns regarding access to one’s own personal data in CCTV footage can be raised with the Honorary Secretary of Bandon Golf Club email@example.com. Individuals also have the right to submit a complaint to the Data Protection Commission.
11.2 Third-Party Access
11.2.1 Access Requests by An Garda Síochána Access requests by An Garda Síochána shall be processed where such processing is necessary and proportionate for preventing and detecting criminal offences. Requests are approved by the Golf Club data controller. Verbal requests are sufficient to allow for the viewing of the footage. However, verbal requests for copies of footage must be followed up with a formal written request using Bandon Golf Club’s ‘CCTV REQUESTS – Third Party Request Form’ (see below). A log is maintained of all requests by An Garda Síochána.*
11.2.2 Other Third-Party Access Disclosure of information to other third parties is made in strict accordance with the purposes of the system and is limited to the following authorities: - Data Controller.* - Legal or insurance representatives of data subjects (with written consent of data subjects)** - Bandon Golf Club’s insurers/assessors** - In exceptional cases, to others to assist in the identification of a victim, witness or perpetrator in relation to a criminal incident** - CCTV companies for service/repair and to pixelate images***
* Access is logged ** Requests must be made in writing on a ‘CCTV REQUESTS - Third Party Access Request Form’ (see below). A decision to refuse such a request by the CCTV administrator may be appealed to the Data Protection Officer and further to the President (or nominee) on procedural grounds only. *** Access is documented
12.0 Procedure for Requesting Installation of Additional CCTV Cameras Requests for the installation of additional cameras on Golf Club premises shall be made in writing (by email) by a member of the Club to the data controller. The applicant will be required to substantiate why the privacy rights of individuals must cede, in a proportionate way, to achieve a legitimate objective. Approval by the Management Committee, will depend on a proven need, taking into account whether better solutions exist and the benefits to be gained from any additional camera(s).
13.0 Procedure for Removal of CCTV Cameras Where requested by a member and where evidence shows that a CCTV camera location is no longer justified, the camera shall be removed at the request of the data controller and placed in storage until required.
14.0 Compliance with this Policy All employees who are responsible for implementing, managing, operating or using the CCTV system must do so only as authorised and in accordance with this Policy.
15.0 Supporting Documents This policy should be read in conjunction with other Club policies, including: - Bandon Golf Club Data Protection Policy The above list is not exhaustive and other policies may apply.