CCTV Body Worn Camera Policy

20th October 2021

1. INTRODUCTION

1.1 We make every effort to ensure the building is a safe and enjoyable environment for our visitors – and equally, those who have advised us they wish to self-exclude, we do our best to respect and uphold these wishes.
1.2 To facilitate these efforts, we have employed the use of CCTV and body-worn cameras in the building.

2. CCTV

2.1 CCTV is in place in all areas of the building for the prevention and detection of crime and to assist with the arbitration and settlement of gaming disputes. In the entrances and gaming areas, we also use audio recording.
2.2 Recordings are stored on-site and automatically deleted after 31 days, unless required as part of an investigation or dispute.

3. BODY-WORN CAMERAS

3.1 Our security staff are equipped with body-worn cameras 24-hours a day as part of our Westminster Council licencing conditions.
3.2 These cameras make audio and visual recordings when activated by the wearer – they do not record continuously. Your image will only be captured if you are involved in an altercation or disturbance on the premises, or in the public areas immediately outside our entrances.
3.3 Footage is downloaded at the end of a shift and stored securely on site. It is automatically deleted after 31 days unless required as part of an investigation or dispute. Footage can only be viewed using specialist software.

4. LAWFUL BASIS OF PROCESSING

4.1 Hippodrome Casino has identified the following lawful bases for these processing activities:
a. CCTV – Processing is necessary for compliance with our legal obligations – to ensure a safe playing environment and one which complies with our Gambling Commission obligations – GDPR Article 6 (1)(c).
b. Body-worn cameras – Processing is necessary for compliance with our legal obligations to ensure a safe environment for all visitors – GDPR Article 6(1)(c).

5. DATA INFORMATION

5.1 Data Roles:
a. CCTV / Body-worn cameras – The Data Controller is Hippodrome Casino Ltd, Cranbourn Street, Leicester Square, WC2H 7JH, whom have control of; the collection source, use purposes, legal basis, retention, locations of storage and the security of personal data within this system and other systems or parties in delivery of the service.
5.2 Data Sharing:
a. CCTV / Body-worn cameras – Personal data is only shared with other establishments (such as the authorities) in the event of the footage being required as part of an investigation into criminal or anti-social activity. Hippodrome Casino will be a joint controller of this.
5.3 Data Collection / Retention:
a. CCTV / Body-worn cameras – If you image is collected by our CCTV / body-worn cameras, it will be stored on our secure systems for a period of 31 days, unless being used as part of an investigation.

6. PRIVACY CONCERNS

6.1 Should you wish to exercise your privacy rights or have concerns over any elements of these processing activities, please contact the Hippodrome Privacy Office and we will be happy to help – [email protected]

If you are based in the EU/EEA, you can still contact us directly, alternatively feel free to contact us via our GDPR EU/EEA Representative, DataRep, which can be reached at:

• [email protected] – be sure to quote “Hippodrome Casino” in the subject line, otherwise we will not know what your request relates to, and it may take significantly longer to administer your email.
• Online webform at www.datarep.com/datarequest
• At the postal address of your country of origin – the full list of which can be accessed here.

Right to complain – you have the right to complain at any time to the Information Commissioners’ Office (ICO) regarding data protection issues that pertain to processing activities of the Hippodrome Casino – https://ico.org.uk