The Colleys
GDPR CCTV Privacy
Policy
Revision 1.2 –
16/08/2022
Data Controller:
Timothy J Colley
Contact: cctv@timcolley.co.uk
1. General
1.1 We use closed circuit television (CCTV) images for the
prevention, identification, and reduction of crime and to monitor our buildings
to provide a safe and secure environment for ourselves, neighbours
and visitors, and to prevent the loss or damage to property.
1.2 CCTV surveillance at the location is intended for the
purposes of:
·
protecting buildings
and assets, at all hours.
·
reducing the
incidence of crime and anti-social behaviour (including theft and vandalism).
·
supporting the
Police in a bid to deter and detect crime.
·
assisting in
identifying, apprehending, and prosecuting offenders.
1.3 The system comprises of 2 fixed cameras at Blue Gardens:
one at the front of the property, one at the back.
1.4 The CCTV system is owned and operated solely by us.
The CCTV is a standalone system and operated by the school.
1.5 The CCTV system is not monitored.
1.6 The CCTV system is NOT registered with the Information
Commissioner, all reasonable expectations regarding the General Data Protection
Act have been adhered to.
1.7 All authorised operators and employees with access to
images are aware of the procedures that need to be followed when accessing the
recorded images. All operators are aware of their responsibilities under the
CCTV Code of Practice. All relevant persons are aware of restrictions in
relation to access to, and disclosure of, recorded images.
1.8 We comply with Information Commissioner’s Office (ICO)
CCTV Code of Practice to ensure it is used responsibly and safeguards both
trust and confidence in its continued use.
1.9
The use of the
CCTV system will be conducted in a professional, ethical, and legal manner and
any diversion of the use of CCTV security technologies for any other purpose
than listed in this document is prohibited by this policy.
2.1 The use of CCTV to control the
perimeter of our buildings for security purposes has been deemed to be
justified. The system is intended to
capture images of intruders or of individuals damaging property or removing
goods without authorisation or of antisocial behaviour.
2.2 CCTV systems will not be used to monitor
normal, day-to-day activity.
2.3 In other areas, namely the rear of
the property, potential damage to property and persons have been identified
that require mitigation.
3.1 Cameras will be sited so they only
capture images relevant to the purposes for which they are installed, and care
will be taken to ensure that reasonable privacy expectations are not
violated. Any inconsequential capture of
areas that are of concern to third parties will be or have been previously
discussed or agreed upon.
3.2 We will ensure that the location of
equipment is carefully considered to ensure that images captured comply with
the Data Protection Act. We will make every effort to position cameras so that
their coverage is restricted to our own premises, which may include outdoor
areas.
3.3 Cameras placed to record external
areas are positioned in such a way as to prevent or minimise recording of
passers-by or of another person's private property, unless previously agreed
with that other person.
3.4 CCTV Video Monitoring and Recording
of Public Areas may take place for the following purposes:
·
Protection of buildings and property: The building’s perimeter, entrances
and exits, special storage areas, outdoor locations (withing the boundaries of
the property).
·
Criminal Investigations (carried out by police)
Robbery, burglary,
and theft surveillance
·
Covert Surveillance
We will
not engage in covert surveillance.
4.1 A copy of this CCTV Policy will be
provided on request to visitors and will be made available on our website.
4.2 The location of CCTV cameras will
also be indicated, and adequate signage will be placed at each location in
which a CCTV camera(s) is sited to indicate that CCTV is in operation.
4.3 Adequate signage will also be
prominently displayed at the entrance to the property. Signage shall include the name and contact
details of the data controller as well as the URL this document.
4.4 Appropriate locations for signage
will include:
·
At
entrances to premises i.e., external doors.
·
At
or close to each internal camera.
5.1 The images captured by the CCTV system will be
retained for a maximum of 14 days, except where the image identifies an issue
and is retained specifically in the context of an investigation/prosecution of
that issue.
5.2 The images/recordings will be stored
in a secure environment with a log of access kept.
5.3 Access will be restricted to
authorised personnel. Supervising the access and maintenance of the CCTV System
is the responsibility of the data controller.
5.4 In certain circumstances, the recordings may
also be viewed by other individuals to achieve the objectives set out
above. When CCTV recordings are being
viewed, access will be limited to authorised individuals on a need-to-know
basis.
5.5 Files/Drives/DVDs will be stored in a secure environment. Access will be restricted to authorised
personnel. Similar measures will be
employed when using server storage, with automatic logs of access to the images
created.
6.1 Recorded footage and the monitoring
equipment will be securely stored in a restricted area. Unauthorised access to that area will not be
permitted at any time. The area will be
locked when not occupied by authorised personnel. A log of access to footage will be
maintained.
6.2 Access to the CCTV system and stored
images will be restricted to authorised personnel only.
6.3 A record of the date of any
disclosure request along with details of who the information has been provided
to (the name of the person and the organisation they represent), why they
required it and how the request was dealt with will be made and kept, in case
of challenge.
6.4 Data will be provided to those
requests authorised in a permanent format where possible. If this is not
possible the data subject will be offered the opportunity to view the
footage.
6.5 In relevant circumstances, CCTV
footage may be accessed:
·
By
the police where we are required by law to make a report regarding the
commission of a suspected crime; or
·
Following
a request by the police when a crime or suspected crime has taken place and/or
when it is suspected that illegal/anti-social behaviour is taking place on our
property, or
·
To
data subjects (or their legal representatives), pursuant to a Subject Access
Request or
·
To
individuals (or their legal representatives) subject to a court order.
·
To
our insurance company where the insurance company requires the same to pursue a
claim for damage done to the insured property.
·
Subject
Access Requests (SAR)
·
Individuals
have the right to request access to CCTV footage relating to themselves under
the Data Protection Act.
6.6 Individuals submitting requests for
access will be asked to provide sufficient information to enable the footage
relating to them to be identified. For example, date, time, and location.
6.7 We will respond to requests within 30
calendar days of receiving the request, however, please note that for technical
reasons, our recording capacity is limited to 14 days. If making a request for
access after this point, data cannot be retrieved as the data is already
overwritten.
6.8 We reserve the right to refuse access
to CCTV footage where this would prejudice the legal rights of other
individuals or jeopardise an on-going investigation.
6.9 A record of the date of the
disclosure along with details of who the information has been provided to (the
name of the person and the organisation they represent) and why they required
it will be made.
6.10
In
giving a person a copy of their data, we provide a still/series of still
pictures, a DVD or a disk with relevant images. However, other images of other individuals
will be obscured before the data is released.
6.11
Where
footage contains images relating to 3rd parties, we will take
appropriate steps to mask and protect the identities of those individuals.
7.1
Complaints
and enquiries about the operation of CCTV within the boundaries of our property
and public areas captured should be directed to the data controller in the
first instance.
8.1
The
data controller will:
·
Ensure
that the use of CCTV systems is implemented in accordance with the policy set
down in this document.
·
Oversee
and co-ordinate the use of CCTV monitoring for safety and security purposes
within our property.
·
Ensure
that all existing CCTV monitoring systems will be evaluated for compliance with
this policy.
·
Ensure
that the CCTV monitoring at our property is consistent with the highest
standards and protections.
·
Review
camera locations and be responsible for the release of any information or
recorded CCTV materials stored in compliance with this policy.
·
Maintain
a record of access (e.g., an access log) to or the release of tapes or any
material recorded or stored in the system.
·
Ensure
that the perimeter of view from fixed location cameras conforms to this policy
both internally and externally.
·
Consider
feedback and/or complaints regarding possible invasion of privacy or
confidentiality due to the location of a particular CCTV camera or associated
equipment.
·
Ensure
that all areas being monitored are not in breach of an enhanced expectation of
the privacy of individuals and be mindful that no such infringement is likely
to take place.
·
Ensure
that external cameras are non-intrusive in terms of their positions and views
of neighbouring residential housing and comply with the principle of
“Reasonable Expectation of Privacy”.
·
Ensure
that monitoring footage is stored in a secure place with access by authorised
personnel only.
·
Ensure
that images recorded on tapes/DVDs/digital recordings are stored for a period
not longer than 14 days and are then erased
unless required as part of a criminal investigation or court proceedings
(criminal or civil).
·
Ensure
that camera control is solely to monitor suspicious behaviour, criminal damage
etc. and not to monitor individual characteristics.
·
Ensure
that camera control is not infringing an individual’s reasonable expectation of
privacy in public areas.