Pace-of-play analysis on a golf course: what the club needs to know

A golf club that puts camera sensors on its course is processing personal data, even when the images are blurred. That brings in the GDPR and, in Sweden, the Camera Surveillance Act. This article sums up what the club needs to do and how TeeGuard is built to make it easier. It is not legal advice.

Is a permit needed?

Normally not. A private organisation such as a golf club does not need a permit from the Swedish Authority for Privacy Protection (IMY) to use cameras. The club does need to show that the monitoring is lawful under the GDPR, and that is where the work lies.

The balancing test

The club is the data controller and will usually rely on legitimate interest. It then has to weigh its own interest, such as keeping pace of play and spotting queues, against players' interest in not being monitored. IMY says privacy weighs heavily where people spend their leisure time, sports facilities included. It also lists things that reduce the intrusion, such as viewing in real time only and using low-resolution images.

The questions that decide the test are much the same for every club:

• What the sensor sees: only playing areas, or also places where people are in private.
• What is kept: video, still images or only numbers.
• How long it is kept.
• Whether people can be recognised in the images.
• Who has access to what is kept.

The impact assessment

A data protection impact assessment (DPIA) is usually required when at least two of the regulator's criteria apply. Systematic monitoring is one of them, and the use of new technology such as AI analysis is another. Plan on doing one. It describes the processing, the risks and the safeguards, and it should be finished before the sensors go live.

Signage

Anyone walking onto the course should be able to see that it is monitored before they come into view. The sign should state the purpose, who the controller is and how to reach them, the data protection officer if the club has one, people's rights and where the full information can be found, for example through a link or QR code. The full information can sit in a second layer, such as the club's website. Put signs at eye level at the entrances and by the first tee.

The processor agreement

When a supplier processes the data on the club's behalf, there must be a written data processing agreement under Article 28 of the GDPR. It sets out what the supplier may do with the data, where it is stored, for how long and which sub-processors are used.

How TeeGuard is built

• The system looks for people, never for faces, and has no facial recognition.
• An encrypted video stream is sent to TeeGuard's service in the region, where the head of every person detected is blurred in memory before anything is stored in the cloud.
• No video is recorded. The video stream is analysed in memory and never stored, and no image is stored during a network outage.
• What is kept is the count, the time, clothing colour, a rough height band and one blurred image per event.
• The blurred image is deleted within 24 hours and metadata after 30 days unless agreed otherwise.
• The database and the images are stored in the EU, and each club sees only its own data.

We share our own legitimate interest assessment and our description of the safeguards, so the club has something to start from in its own assessment.