CCTV. Bishop Otter Campus and Bognor Regis Campus. Procedures in accordance with the Data Protection Act 1998.
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1 CCTV Bishop Otter Campus and Bognor Regis Campus Procedures in accordance with the Data Protection Act Estate Management hold the rights to the University of Chichester CCTV Procedures. 1
2 CCTV PROCEDURES Date of Issue 11/11/2012 Next Review Date 11/11/2014 Version 1 Last Review Date Author Director Responsible Peter Tierney Approved By John Kingdon Date Approved 10/11/2012 Links with other documents CCTV policy Issue Status Date Reason for Change Authorised V1 Procedures Oringal Policy M.Callow 2
3 CONTENTS 1.0 Introduction 1.1 Accountability 1.2 The Data Protection Act CCTV Code of Practice 2.0 Scope 3.0 Policy 3.1 Initial Assessment Procedures 3.2 Camera Locations 3.3 Access image(s) 3.4 Access to images by individuals 3.5 Viewing of cameras 3.6 Training Management of access and viewing of cameras Recorded Material 6.0 Interaction with other policy and procedures 7.0 Responsibilities 6.1 Facilities Manager Soft FM responsibility 6.2 Responsibility through the Director of Estate Management 8.0 Documentation 9.0 Review Appendix A Internal CCTV signs Appendix B External CCTV signs 3
4 1.0 INTRODUCTION These procedures must be followed to comply with the Data Protection Act 1998 in connection with CCTV (closed circuit television) surveillance systems managed by The University of Chichester. 2.0 SCOPE 1.1 account has been taken of the following: - The Data Protection Act 1998; The CCTV Code of Practice; The Human Rights Act 1998; The Regulation of Investigatory Powers Act 2000; 1.2 The Data Protection Act 1998 came into force on the 1st March This data protection legislation provides for legally enforceable standards to the collection and processing of images relating to individuals. 1.3 CCTV Code of Practice which sets out the measures to be complied with the Data Protection Act This Procedure will cover all Staff, Students, visitors, contractors etc., of the University of Chichester and all other persons whose image(s) may be captured by the system. 3.0 Procedure 3.1 Initial Assessment Procedures The Director of Estate Management has the legal responsibility for the University systems. However the UoC Facilities Manager Soft FM has responsibility for the day-to-day compliance with the requirements of the CCTV Code of Practice and these procedures The purpose of the UoC CCTV is for the: Prevention or detection of crime or disorder; Apprehension and prosecution of offenders (including use of images as evidence in criminal proceedings); Interest of Staff, Student Health and Safety; Protection of staff, student health; Protection of UoC property and assets. 4
5 3.2 Camera Locations and Signage All cameras are located in prominent positions within the view of staff, students and visitors. All CCTV surveillance is automatically recorded and any breach of these procedures will be detected via controlled access to the system and auditing of the system Signs have been erected on all entrance points to the UoC premises at appropriate locations throughout the campuses to ensure staff, students, visitors etc, are aware they are entering a CCTV covered area All buildings that are monitored by CCTV will have signage indicating this for the prevention of crime and to warn people of their presence. Please see appendix A for an internal CCTV sign external signs are shown in Appendix B Use of Covert CCTV surveillance if required should be requested through the Facilities Manager Soft FM. If the request is refused then alternatives can be discussed If the use of body worn mini-cameras is undertaken by campus security it will be clearly identified on their uniform that CCTV cameras are being worn and are in use. All members of security that use devices whilst dealing with incidents will state to individuals that they are being recorded 3.3 Access of image/s It is important that access to, and disclosure of, the images recorded by CCTV and similar surveillance equipment is restricted and carefully controlled. This will ensure that the rights of individuals are preserved; In addition such controls will ensure that the continuity of evidence remains intact should the images be required for evidential purposes e.g. a Police enquiry or an investigation being under taken as part of the UoC disciplinary procedure Access to the medium on which the images are displayed and recorded is restricted to UoC staff and third parties authorised by the Facilities Manager Soft FM, Deputy Director of Estate Management or Director of Estate Management Access and disclosure to images is permitted to investigating teams/police. Under these conditions the CCTV images/footage record book must be completed. 5
6 3.4 Access to images by individuals 3.5 Authorised Staff Section 7 of the 1998 Data Protection Act gives any individual the right to request access to CCTV images Individuals who request access to images must be issued an access request form. Upon receipt of the completed form, the Facilities Manager Soft FM or Deputy Director of Estate Management or Director of Estate Management determine whether disclosure is appropriate and whether there is a duty of care to protect the images of any third parties. If the duty of care cannot be discharged then the request can be refused A decision will be given in writing to the individual who made the request to access images within 21 days of receipt of the enquiry. If the request is refused these reasons will be explained to the individual Access to the CCTV system will only be for authorised University staff and contractors. Whether staff and contractors are operators or managers, they will meet the highest standards of probity Authorised staff and contractors involved in the operation of the CCTV system are required to adhere to the UoC policy regarding the operation of CCTV The following tables demonstrates the level of delegation for the staff as nominated to access the CCTV system Delegation Title Department Level 1 Director of Estate Management EM System Deputy Director Estate EM Administration and Management Facilities Manager Soft FM EM authorisation to Facilities Manager Hard FM EM view/retrieve Projects, Standards and IT /copy footage Security Manager. Level 2 Authorisation to view Footage Blayde frontline security officers Non-authorised personnel will not be permitted access to the CCTV at any time 6
7 3.6 Training All members of staff that have access to view the cameras will have training provided in the use of this function All members of staff and security contractors that use mobile cameras will have training provided in there correct use. 4.0 Management of access and viewing of cameras 4.1 The UoC does not have a control room for the purpose of operating the CCTV system 4.2 Authorised staff and contractors are only to view footage at work stations in situations that would not enable public view. Authorised staff should also ensure that unauthorised staff does not have access to footage being reviewed 4.3 Access to the CCTV system is for authorised staff and contractors only. 5.0 Recorded Material 5.1 Images, which are not required for the purpose(s) for which the equipment is being used, should not be retained for longer than is necessary. While images are retained, it is essential that their integrity be maintained, whether it is to ensure their evidential value or to protect the rights of people whose images may have been recorded. It is, therefore, important that access to and security of the images is controlled in accordance with the requirements of the Data Protection Act All images that are digitally recorded from fixed camera locations are stored securely within the systems hard drives. The system is automatically cleared after 30 days. Located within the UoC are sub monitors that display images of public areas; however they are enclosed in secure areas and are only accessible to UoC staff. All images recorded by mobile cameras will be stored on data storage devices for 28 days before being erased 5.3 Where the images are required for evidential purposes in legal or UoC disciplinary proceedings, a CD-R disc recording is made and placed in a sealed envelope signed and dated and held by the facilities Manager Soft FM a duplicate copy will be provided to investigating teams/police. Viewing of images within the Operations room, located in A204 University House, is controlled by the Facilities Manager Soft FM or a person nominated to act on his/her behalf 7
8 5.4 All materials recorded from body worn mini CCTV cameras will be manually wiped every seven days by the security contractors. The hard drive will be removed from the camera and wiped by their head of security. This process will be overseen by the Facilities Manager Soft FM and will be logged and checked. The cameras will be stored in a safe with only access by authorised persons, that being the Facilities Manager Soft FM and the senior partner of the Security contractor 6.0 INTERACTION WITH OTHER POLICY AND PROCEDURES This procedure should be read in conjunction with the UoC Security Plan when drafted, CCTV Code of practice and CCTV policy 7.0 RESPONSIBILITIES 6.1 Facilities Manager Soft FM is responsible for the implementation of this procedure, monitoring its effectiveness and ensuring the Policy is available on the UoC Portia. He/she is also personally accountable for ensuring that the policy and Code of Practice are adhered to and monitored. 6.2 The UoC discharges this responsibility through the Director of Estate Management to whom the UoC Facilities Manager Soft FM is accountable. 8.0 DOCUMENTATION Copies of all documentation and records relating to the CCTV system will be held within the Estate Management Department and will be kept under restricted confidentiality, for a period of 3 years. 9.0 REVIEW This policy will be reviewed by Estate Management every two years, or earlier in the light of changing circumstances. 8
9 Appendix A Internal CCTV sign 9
10 Appendix B External CCTV Sign 10
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