CCTV Notice
About us
Tottenham Hotspur Ltd is a company registered in England and Wales and is part of a group of companies and organisations centred around our football club.
In this CCTV Notice, we use the term “Tottenham Hotspur” (and “we”, “us” and “our”) to refer to our group of companies and organisations including Tottenham Hotspur Ltd, Tottenham Hotspur Football & Athletic Co. Ltd, Tottenham Hotspur Women Football Club Limited, Tottenham Hotspur Stadium Limited, and Tottenham Hotspur Foundation.
About this CCTV notice
We use fixed and domed cameras (“CCTV Cameras”) designed to capture and record images of individuals and property and to view and record individuals on and around our premises. This maintains a safe environment for our staff and visitors, and assists us to monitor and forecast capacity in and around the Tottenham Hotspur Stadium.
This CCTV Notice sets out the accepted use of the CCTV Cameras, equipment and images to ensure compliance with relevant data protection and privacy laws and regulations.
We reserve the right to change this CCTV Notice at any time, and any such changes will be made available to staff, visitors and customers by reviewing the most up-to-date version of this CCTV Notice.
The purpose of this CCTV Notice is to:
- outline why and how we will use CCTV Cameras, and how we will process data recorded by CCTV Cameras;
- ensure that the legal rights of individuals, relating to their personal data, are recognised and respected;
- assist staff in complying with their own legal obligations when working with personal data. In certain circumstances, misuse of information generated by CCTV Cameras or other surveillance systems could constitute a criminal offence; and
- explain how to make a subject access request in respect of personal data created by CCTV Cameras.
Who does this notice apply to?
This CCTV Notice applies to all our staff, officers, consultants, self-employed contractors, casual workers, agency workers, volunteers and interns. It also applies to anyone visiting our premises or using our vehicles.
Reasons for the use of CCTV cameras
We currently use CCTV Cameras in and around the Tottenham Hotspur Stadium (including for example the Tottenham Experience, Paxton House, and Warmington House), the Hotspur Way Training Centre, the Lodge, the Retail and Merchandise Warehouse, Lilywhite House, and Percy House as outlined below. We believe that such use is necessary for legitimate business purposes, including:
- to prevent and deter crime and protect buildings and assets from damage, disruption, vandalism and other crime;
- for the personal safety of staff, visitors and other members of the public;
- to support law enforcement bodies in the prevention, detection and prosecution of crime;
- to assist in day-to-day management, including ensuring the health and safety of staff and visitors;
- to assist in the effective resolution of disputes which arise in the course of disciplinary or grievance proceedings;
- to assist in the defence of any civil litigation, including employment tribunal proceedings;
- to assist in the handling of complaints or requests for information made by staff, visitors, and other member of the public when visiting or being present in and around the Tottenham Hotspur premises listed above;
- to collect data which assists us to monitor and forecast capacity in and around the Tottenham Hotspur Stadium.
We currently do not use CCTV Cameras:
- to record sound unless in accordance with any recording as considered below;
- for any automated decision making; or
- to monitor any private or confidential areas of the Tottenham Hotspur Stadium.
Monitoring
CCTV Cameras monitor the following locations:
- Tottenham Hotspur Stadium;
- Tottenham Experience;
- Paxton House;
- Warmington House;
- Hotspur Way Training Centre;
- The Lodge;
- Retail and Merchandise Warehouse; and
- Lilywhite House; and
- Percy House.
Camera locations are chosen to minimise viewing of spaces not relevant to the legitimate purpose of the monitoring. As far as practically possible, CCTV Cameras will not focus on private or confidential locations.
The location of some CCTV Cameras may not be entirely apparent and obvious, for example where the presence of a traditional CCTV Camera would have an adverse effect on the aesthetic and appearance of such area. These CCTV Cameras are contained within a limited number of areas in and around the Tottenham Hotspur Stadium.
Some of the CCTV Cameras deployed may have the ability to record sound, however the Club is unable to replay any sounds which may have been recorded by the CCTV Cameras.
CCTV Cameras may record 24 hours a day, every day of the year, but only a small number of these are able to be actively monitored by the Club's authorised personnel at any given time. For example, on a matchday at the Tottenham Hotspur Stadium, authorised personnel actively monitor the CCTV Cameras in and around the Tottenham Hotspur Stadium and its surrounding areas.
Our staff using surveillance systems will be given appropriate training to ensure they understand and observe the legal requirements related to the processing of relevant data.
How we will operate any CCTV cameras
Where CCTV Cameras are placed in the workplace, we will ensure that signs are displayed within areas of the surveillance zone to alert individuals that their image may be recorded. The signs will contain details of the organisation operating the system, the purpose for using the surveillance system and who to contact for further information, where these things are not obvious to those being monitored.
We will ensure that live feeds from cameras and recorded images are only viewed by approved members of staff whose role requires them to have access to such data. Recorded images will only be viewed in designated, secure offices.
Use of data gathered by CCTV cameras
In order to ensure that the rights of individuals recorded by the CCTV Cameras are protected, we will ensure that data gathered from CCTV Cameras is stored in a way that maintains its integrity and security. This may include encrypting the data, where it is possible to do so, and securing the data in password controlled locations which only authorised personnel have access to.
Given the large amount of data generated by surveillance systems, we may store video footage using a cloud computing system. We will take all reasonable steps to ensure that any cloud service provider maintains the security of our information, in accordance with industry standards.
We may engage data processors to process data on our behalf. We will ensure reasonable contractual safeguards are in place to protect the security and integrity of the data.
Retention and erasure of data gathered by CCTV cameras
Data recorded by the CCTV Cameras will be stored in our system on our premises. Data from CCTV Cameras will not be retained indefinitely but will either be permanently deleted or overwritten, once there is no reason to retain the recorded information. Exactly how long images will be retained for will vary according to the purpose for which they are being recorded and the quality of the recording being captured. In the majority of cases, recorded images will be kept for between 25 to 30 days (inclusive) and will be overwritten on a recycling basis once the drive is full. In the event that any data is to be held for longer than 30 days this shall be authorised by the Data Protection Officer and the reason for this shall be recorded.
At the end of their useful life, all images stored in whatever format will be erased permanently and securely. Any still photographs and hard copy prints will be disposed of as confidential waste.
Use of additional surveillance systems
Prior to introducing any new surveillance system, including placing a new CCTV Camera in any workplace location, we will carefully consider if they are appropriate by carrying out a data protection impact assessment (“DPIA”).
A DPIA is intended to assist us in deciding whether new surveillance cameras are necessary and proportionate in the circumstances and whether they should be used at all or whether any limitations should be placed on their use.
Any DPIA will consider the nature of the problem that we are seeking to address at that time and whether the surveillance camera is likely to be an effective solution, or whether a better solution exists. In particular, we will consider the effect a surveillance camera will have on individuals and therefore whether its use is a proportionate response to the problem identified.
Currently, there are no CCTV Cameras placed in areas where there is an expectation of privacy (for example, in changing rooms). We shall not place any CCTV Cameras in areas where there is an expectation of privacy, unless, in very exceptional circumstances, it is judged by us to be necessary to deal with very serious concerns, and only to the extent that it does not cause unjustified harm to an individual's rights and freedoms under data protection and privacy laws and regulations.
How we may share CCTV cameras' images
Access to and disclosure of images recorded on CCTV Cameras will be restricted and carefully controlled. This will ensure the rights of individuals are protected, and also ensure that the images can be used as evidence if required. Images may only be disclosed in accordance with the purposed for which they were originally collected as set out above.
Disclosures to third parties will only be made in accordance with the purpose(s) for which the system if used and will be limited to:
- police and other law enforcement agencies, where the images recorded could assist in a specific criminal enquiry and/or the prevention of terrorism and/or public disorder;
- prosecution agencies (such as the Crown Prosecution Service);
- relevant legal representatives of people whose images have been recorded and retained (unless disclosure to the individual would prejudice criminal enquiries or criminal proceedings);
- individuals who have been caught on our CCTV Cameras in accordance with a request made such as one described below;
- in exceptional cases, for others (such as insurers) to assist in identification of a victim, witness or perpetrator in relation to a criminal incident;
- staff involved with our disciplinary processes; and
- staff within the Club's Legal, Risk and Compliance Team.
We will maintain a record of all disclosures of CCTV Camera footage.
No images from our CCTV Cameras will ever be posted online or disclosed to the media by us.
Requests for CCTV camera footage
Data subjects may make a request for disclosure of their personal information and this may include CCTV Camera images. In order to request any such images which we may hold, we recommend contacting our DPO via email on: personaldata@tottenhamhotspur.com
In order for us to locate relevant footage in a timely and efficient manner, we recommend that any requests for copies of recorded CCTV Camera images include the: (i) full name of the data subject; (ii) approximate date and time of the recording; (iii) approximate location where the footage was captured; (iv) if necessary, information identifying the data subject (such as a physical description of the data subject, including (without limitation) what the data subject was wearing); and (v) information describing the purpose of the data subject's visit to the area of the Club's premises being monitored by CCTV Cameras.
When you contact us to request your personal information held in the CCTV Camera images, we may ask you for some information so that we can confirm your identity and ensure that we action your request against properly. This will usually be any information which will assist in identifying you on the CCTV Camera image, including (without limitation) physical description, description of clothes worn, seat number, etc. We do not store this information – we just use it to confirm your identity.
We maintain a record of all the requests that we receive. If you do make a request, this record will capture your name and a differential piece of data such as your email address or CRN. We keep this record to evidence our compliance with Data Protection Legislation and as a record of our activities in case we are challenged.
In accordance with Data Protection Legislation, we reserve the right to obscure images of third parties when disclosing CCTV Camera data, where we consider it necessary to do so.
Requests to prevent processing
We recognise that, in rare circumstances, individuals may have a legal right to request erasure of personal data concerning them or to restrict the processing of their personal data. In order to exercise any of the following rights please contact the DPO using the details below in the "Getting in Touch" section or email on personaldata@tottenhamhotspur.com.
Getting in touch
We have a dedicated Data Protection Officer (“DPO”) who you can contact if you have questions or any complaints in relation to this CCTV Notice:
Data Protection Officer
Tottenham Hotspur Stadium
Lilywhite House
782 High Road
London
N17 0BX
Alternatively email: personaldata@tottenhamhotspurstadium.com.
Your Rights – Complaining to the ICO
Please note, you are also able to make a complaint to the Information Commissioner’s Office (“ICO”), the UK regulator for data protection issues, if you think your data protection rights have been breached in any way by us. You can do this by contacting the ICO by calling: 0303 123 1113, or alternatively visiting: https://ico.org.uk/make-a-complaint/. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to this notice
As Tottenham Hotspur changes, this CCTV Notice is expected to change as well. We reserve the right to amend this CCTV Notice at any time, for any reason, without notice to you, other than the posting of the amended CCTV Notice on our websites. We may email periodic reminders of this CCTV Notice and will email relevant data subjects to notify them of any material changes. You should check our website frequently to see the current CCTV Notice that is in effect and any changes that may have been made to it.
Updated April 2025
