Table of Contents
| Introduction |
| Physical Security and Visual Deterrence |
| Data Collection Sources, Data Storage, Retention and Safeguards and Data Uses |
| POENB Member Rights and Responsibilities |
Introduction
This Security and Data Policy outlines POENB’s physical security and deterrence, data collection sources, data privacy and surveillance policies and practices.
Specifically, it describes how POENB collects, uses, stores, and protects information in compliance with New York State laws, including the SHIELD Act (S.5575-A/A.5688) for data security and one-party consent rules for audio recordings (Penal Law § 250).
The Security and Data Policy also uses defined terms and references other POENB Rule and Policies.
The first letter of a key term is CAPITALIZED throughout this document. These Key Terms and Definitions are listed in alphabetical order and are included in a separate document.
In addition to the Security and Data Policies and Key Terms and Definitions, POENB has five other Rules and Policies. All seven documents are posted on the POENB website (www.eatonsneck.org).
Members and other interested parties should consult and carefully read the Security and Data Policies, Key Terms and Definitions and other POENB Rules and Policies documents to have a comprehensive understanding of POENB’s management practices.
By joining POENB, entering the Beach Properties, and (if applicable) driving their vehicle through the Security Gate, Members (and their Guests) consent to this Policy.
The Board may modify, update or rescind POENB’s Rules and Policies to adapt to new legal requirements, strategic goals and/or operational needs. Typically, the Board evaluates the POENB Rules and Policies on an annual basis. However, in selected cases, POENB may need to modify the Rules and Policies during a given year to properly manage the Beach Properties for the benefit and safety of the Members. Changes to these Rules and Policies are permitted based on a simple majority vote by the Board of Directors.
The Board will communicate to Members material changes to the Rules and Policies during the Member Meetings and/or via emails or announcements on social media.
The Appendix ofthis Security and Data Policy contains a Version Control Table that identifies the name, version, and “as of” date of the document as well as the Member who made the changes and the Board Member who is responsible for ensuring the accuracy, completeness, currency, and reasonableness of the Security and Data Policy as well as its intellectual consistency with related POENB Rules and Policies.
POENB disclaims all liability for personal injury, property damage, or loss arising from use of Association properties, except those caused by the Association’s gross negligence. All users (Members, Member Household, Member Guests, Beach Party/Event Attendees, Resident Non-Member Property Owners, Authorized Vendors and Party / Event Vendors) assume all risks associated with beach activities and agree to indemnify and hold harmless the Property Owners of Eaton’s Neck Beach Inc. (POENB), its Board, and Members from claims related to their use, guests, or events.
Questions? Contact info@eatonsneck.org
Physical Security and Visual Deterrence
To physically secure POENB, Inc.’s two owned beaches (Price’s Bend and Valley Grove), deter potential intruders and mitigate the risk of property damage, POENB has:
- Placed highly visible security signs around the beach properties. These signs state that the beaches are private property and are for Members only. At Price’s Bend, additional signs note that the private property is under video surveillance for community safety, and/or that the area is protected by security cameras.
- Erected a split rail fence all Price’s Bend
- Planted hedges/shrubs along the perimeter of both beaches.
- Installed a motion detecting light near the driveway entrance to Price’s Bend
- Installed latching gates at selected entrances to the beach.
- Installed security cameras.
- Installed a security gate with a barrier arm l- that opens via a Clicker, and
- Consciously maintained selected parts of the beach properties in a “natural state” to allow native, thorny and dense salt water tolerant vegetation to create an effective barrier to foot traffic
POENB will continue to assess the effectiveness of these visual and physical deterrents and adapt the approaches taken to changing threats and evolving technologies.
Data Collection Sources, Data Storage, Retention and Safeguards, and Data Uses
With respect to data collection, storage, retention, safeguards, and uses, POENB tries to strike the right balance between:
- It’s need to operate efficiently and generate timely, accurate and complete POENB management and financial reports with
- It’s commitment to collect, protect and store only necessary, high-quality data about its Members.
This section identifies the key data sources that POENB collects about its Members and other individuals, how it stores, retains and safeguards that data, and how the data is used.
Membership Applications
Data Collected
POENB allows eligible POENB Area Residents to apply for membership both online (via its website) and using a paper form. The data requested from both sources are identical. Eligible POENB Area Residents are asked to provide their name, street address and contact details (email, telephone number).
The Membership Application also asks an Eligible POENB Area Resident if they would like a watercraft storage spot, a Security Gate Clicker, if they’d like to make a general/discretionary donation or a specific donation (4th of July or other objective), whether they want to “opt out” having their name published in the Changing Tides as a Member, and whether they are interested in getting involved in POENB activities (committees, etc..)
The information collected on the Membership Application has not materially changed in 60+ years. POENB has never asked for, nor does it plan to ask for any Personally Identifiable Information (“PII”). PII includes information such as SSN, passport numbers, driver’s license numbers, date of birth, criminal records, fingerprints, medical history, religion or ethnicity.
The Membership Application also asks an Eligible POENB Area Resident to select their preferred payment method. Options include writing a paper check or using an electronic payment method (debit or credit card, Venmo or PayPal).
Data Storage and Safeguards
Membership data collected is stored on the POENB Treasurer’s and Membership Chair’s Personal Computer (PC). The data is available, with limited access, to authorized Board members.
Since its founding in 1960, Members have written checks to POENB without incident. POENB’s Treasurer uses a combination of physical security, banking technology and legal protection to safeguard checks received from Members. The Treasurer also deposits all checks received quickly into one of POENB’s Chase bank accounts.
If a member chooses to pay their membership fees online, the Member enters his/her credit card or electronic payment method via PayPal. PayPal is a global online payment system that lets individuals and businesses send and receive and manage money securely. It acts as an intermediary to keep financial details private from sellers during purchases.
PayPal does not share a buyer’s (Member) full financial information credit card or bank account numbers with the seller (POENB). The Seller, (POENB) only receives necessary transaction details including the buyer’s (Member’s) name, email address, shipping (home) address and phone number.
Data Uses
Data collected from the Membership Applications is refreshed annually since the Membership Term is one year. POENB uses the data to communicate with Members (direct or blast emails, phone calls) and to conduct selected statistical analysis (number of standard vs. special members, location of members by street address, tenure of membership, new members, owners / full members vs. renters/ limited members, number of members requesting watercraft storage spots and type of watercraft stored, member assigned watercraft spot location, general payment method (on line vs. paper check), application method (on line vs paper form). Actual versus budgeted comparisons regarding (1) number and type of members and (2) donations received, etc.
Website Brower Information
POENB’s maintains a dedicated website www.eatonsneck.org for its Members and the general public. Many organizations track user activities on their website including (1) how long the user stays on the site, (2) which pages they view, and (3) their navigation paths (the sequence of pages a user visits to improve the user’s experience. POENB does not collect or analyze a user’s browsing behavior on its website.
Email Correspondence
Data Collected
POENB Board has a dedicated email – info@eatonsneck.org.
The Board receives approximately 20 emails per month from Members, Resident Non-Members, government officials, and business/corporations on a variety of topics.
Every month, POENB’s Recording Secretary (Board Member) prepares a log of all emails received. This log contains (1) the sender’s name, (2) sender’s email address, (3) subject matter, (4) date and time received, (5) a brief summary of message, and (6) the date the message was sent by the Corresponding Secretary to the responsible Board member for follow-up action – as required.
Data Storage
The emails received are stored in POENB’s email box for a period of three years and then deleted.
Data Uses
Email data helps POENB’s Board (1) understand, categorize and analyze Member questions and needs, (2) ensure all Member queries and comments are addressed promptly, (3) prioritize needed action, and (4) report the number and type correspondence received to membership at POENB’s monthly meeting in the Meeting Minutes.
Video Surveillance
Data Collected
POENB continuously records video footage from three security cameras installed at Price’s Bend.
- One camera faces Price’s Bend parking lot
- One camera faces the Price’s Bend beach, and
- One camera is pointed at vehicles who uses their “Clicker” to drive through the Security Gate to enter the Price’s Bend parking lot
This data is recorded for security purposes. The cameras do not capture data inside vehicles or private areas.
Data Storage
Video/audio footage is retained for 30 days (or up to 90 days for active investigations), then automatically deleted.
Data Uses
Video from the camera pointed at vehicles who use their Clicker to drive through the Security Gate is used to:
- Enforce Gate Rules (e.g., detect tailgating or unauthorized access)
- Maintain and troubleshoot the gate system, and
- Investigate reported incidents, violations, or emergencies.
Price’s Bend Security Gate Entry/Exit Logs
Data Collected
Each time a Member uses his/her optional (not a condition of membership) access device (Clicker) to raise the Security Gate at Price’s Bend, POENB is provided with a date and time stamp of the entry or exit and the Clicker ID used.
The Clicker ID is linked to the member’s name, addresses, and contact information, included in the membership database. The date, time and Clicker ID information is collected automatically via the gate system.
POENB’s security gate system is not configured to read license tags (has no license tag reader capabilities) and, therefore, cannot and does not collect license tag information.
Data Storage and Data Safeguards
Data is not sold, shared with third parties (except law enforcement with a subpoena), or used for marketing.
All data collected is stored securely on encrypted servers with access limited to authorized Board Members and administrative maintenance personnel.
Entry logs are retained for one year for compliance and enforcement, then anonymized or deleted.
POENB maintains reasonable safeguards against breaches, including regular audits, as required by the NY SHIELD Act. In the event of a data breach, affected members will be notified without unreasonable delay.
Data Uses
POENB (Security Officers and authorized Board members) uses this information to verify access, monitor usage and generate aggregate reporting (e.g., usage trends – average daily beach usage, busiest dates and times during the Beach Season) without identifying individuals.
Price’s Bend Security Gate Audio Recordings
Via the security camera at the parking lot entrance to Price’s Bend, POENB can capture audio from conversations in the immediate Security Gate vicinity (e.g., for incident verification). However, audio is not actively monitored in real-time and is disabled unless needed for security events.
POENB Member Rights and Responsibilities
Access and Correction: Members may request a copy of their personal data (e.g., membership application data input int. Members should send any corrections to info@eatonsneck.org. Requests will be fulfilled within 30 days.
Deletion: Members may request deletion of non-essential data (e.g., old logs), subject to legal retention requirements.
Opt-Out: Video/audio applies to all individuals in the gate area; no individual opt-out is available for security reasons. However, Members can request review of specific footage.
Members may report concerns or file complaints with the New York Attorney General’s Office if needed.
Members must not tamper with cameras or data collection equipment—violations may result in fines per the Gate Rules.
