NOT PROTECTIVELY MARKED The Ride CCTV Policy Page 1 of 7
Contents 1. Introduction 2. Objectives of the CCTV System 3. Statement of Intent 4. Operation of the System 5. CCTV System 6. Monitoring Procedures 7. Video Download Procedures 8. Breaches of the Policy 9. Assessment of the Scheme and CCTV Usage Policy 10. Complaints 11. Access by the Data Subject 12. Public Information 13. System Maintenance and Monitoring Title Subject Version Date Author Protective Marking Classification Description Next review date The Ride CCTV Policy CCTV 1.0 19/04/2016 Damian Worrell OFFICIAL 19/04/2017 Page 2 of 7
1. Introduction 1.1. The Ride is fully committed to the safety of its residents, staff and visitors and to this extent has invested in the security of the buildings and facilities. The purpose of this Policy is to regulate the management, operation and use of the closed circuit television (CCTV) system at The Ride. 1.2. Common CCTV systems are based around digital technology and therefore need to be treated as information that will be processed under the Data Protection Act 1998, Human Rights Act 1988 and Protection of Freedom Act 2012 this also complies with 2013 CCTV code of Practice, the Regulation of Investigatory Powers Act & the Private Security Industry Act 2001.The persons ultimately responsible for data protection within the London Borough of Hounslow (the Council) is the Information Governance Team. 1.3. The system comprises a number of fixed dome cameras these are located externally at the front rear and side around The Ride site. All cameras maybe monitored and are only available for use by approved members of staff. 1.4. The CCTV system is owned by the Council and will be subject to review on an annual basis. This shall be conducted by management at The Ride. 2. Objectives of the CCTV system are:- 2.1. To protect the Council s buildings and its assets to ensure they are kept free from intrusion, vandalism, damage or disruption. 2.2. To increase the personal safety of resident, staff and reduce the fear of physical abuse, intimidation and crime. 2.3. To support the police in a bid to deter and detect crime. 2.4. To assist in identifying, apprehending and prosecuting offenders on The Ride site. 2.5. To protect members of the public and private property. 2.6. To assist in the usage and management of The Ride building on a day to day basis 3. Statement of Intent 3.1. The Ride will comply with the Data Protection Act 1998, whether it be information, recordings and downloads which relate to the CCTV system. 3.2. Cameras will be used to monitor activities outside of The Ride building i.e. the car park side allies and front garden to identify criminal activity actually occurring, Page 3 of 7
anticipated, or perceived, and for the purpose of securing the safety and wellbeing of the occupants within The Ride, together with its visitors. 3.3. Staff have been instructed to ensure that static cameras will not focus on private homes, gardens and other areas of private property. 3.4. Unless an immediate response to events is required, staff must not direct cameras at an individual, their property or a specific group of individuals, without an authorisation from the Executive Principal being obtained. 3.5. Materials or knowledge secured as a result of CCTV system will not be used for any commercial purpose. Downloads will never be released to the media for purposes of entertainment. 3.6. The planning and design of the existing CCTV system has endeavoured to ensure that the CCTV system will give maximum effectiveness and efficiency but it is not possible to guarantee that the CCTV system will cover or detect every single incident taking place in the areas of coverage. 3.7. Warning signs, as required by the Code of Practice of the Information Commissioner have been placed at all access routes to areas covered by the Academy CCTV. 4. Operation of the System 4.1. The system will be administered and managed by The Ride s Data Protection officer, in accordance with the principles and objectives expressed in this Policy. 4.2. The day-to-day management will be the responsibility of The Ride s Manager. 4.3. The CCTV system will be operated 24 hours each day, every day of the year, the external cameras are monitored from 7:30am to 1:00am and will continually record for 24 hrs. This is for the safety of the children we care for. 4.4. Recordings are electronically wiped from the system every 30 days. Unless vital information has been recorded that can assist future police/council investigations. In this event all relevant recorded data shall be transferred to a USB stick and held until deemed necessary or requested by previously suggested authorities. 4.5. This is in line with the Council s Corporate Retention Schedule, Record s Management Policy and Data Disposal Procedure. 5. CCTV System 5.1. Access to the CCTV will be limited to the members of staff approved by the Management. Page 4 of 7
5.2. Unless an immediate response to events is required, staff must not direct cameras at an individual or a specific group of individuals. 5.3. The CCTV system may generate a certain amount of concern from members of the public. Any concern expressed by a member of the public should be referred to the manager, Sue Stansfield. If permission is granted by the line Manager Bob Spencer, the member of the public can be accompanied through the Policy. 5.4. Other administrative functions will include maintaining hard disc space, filing and maintaining occurrence and system maintenance logs by the ICT Manager / Site Manager. 5.5. In the event of an emergency which requires an immediate contact with an emergency service to be contacted by a member of staff, the emergency procedures identified in the Health and Safety Policy will be adhered too. 6. Monitoring Procedures 6.1. Camera surveillance is to be maintained at all times strictly for monitoring purposes only. 6.2. A monitor has been installed for the purpose of monitoring live feeds and will be continuously displayed. 6.3. Staff are to monitor cameras in the first instant, to protect the welfare and safeguard residents, to observe possible criminal activity, to acknowledge staff/contractors have/not attended the site. 7. Video Download Procedures 7.1. Recordings may be viewed by the police and authorised personnel for the prevention and detection of crime. Permission to do this will be given by the homes Manager once a crime reference number is provided. The Customer Relations Team will be notified immediately of such requests. 7.2. A record will be maintained of the release of downloads to the police or other authorised applicants. The recordings will be put on an encrypted disc and/or sent via secure email for example GCSX. A register will be available for this purpose and will be kept by the Assistant Manager. 7.3. Viewing of downloads by the police must be recorded in writing and in the register. Requests by the police should be sent to the Data Protection mailbox (dataprotection@hounslow.gov.uk). These requests can only be actioned under section 29 of the Data Protection Act 1998. 7.4. Should a download be required as evidence, a copy may be released to the police under the procedures described in the above paragraphs of this Policy. Page 5 of 7
Downloads will only be released to the police on the clear understanding that the encrypted disc/usb remains the property of The Ride, and both the encrypted disc/usb and information contained on it are to be treated in accordance with this Policy. The Ride also retains the right to refuse permission for the police to pass to any other person the encrypted disc or any part of the information contained thereon. 7.5. Applications received from outside bodies (e.g. solicitors) to view or release downloads will be referred to the Data Protection team (dataprotection@hounslow.gov.uk). In these circumstances downloads will normally be released where satisfactory documentary evidence is produced showing that they are required for legal proceedings, 8. Breaches of the Policy (including breaches of security) 8.1. Any breach of this Policy by staff will be initially investigated by the Manager, Sue Standfield, and HR will be notified to take the appropriate disciplinary actions. 8.2. The Information Governance and Information Security team will be immediately notified of any data or security breaches. 8.3. Any serious breach of the Policy will be immediately investigated and an independent investigation carried out to make recommendations on how to remedy the breach. 9. Assessment of the Scheme and CCTV Usage Policy Performance monitoring, including random operating checks, may be carried out by authorised personnel. 10. Complaints Complaints about The Ride s CCTV system should be addressed to the Manager, Sue Standfield 7-9 The Ride Brentford TW8 9LB in the first instance. Otherwise, the Complaints Team who are based at The Civic Centre Lampton Road Hounslow TW3 4DN. 11. Access by the Data Subject 11.1. The Data Protection Act provides data subjects (individuals to whom "personal data" relate) with a right to view data held about themselves, including those obtained by CCTV. 11.2. Such requests should be made in writing to the Data Protection team. Data subjects will be advised to visit the London Borough of Hounslow s website for further information. Page 6 of 7
12. Public Information Copies of this Policy will only be available to the public, by making a Freedom of Information request to the FOI team (foi@hounslow.gov.uk). A copy of this Policy will be located on the Gateway for information purposes to members of staff. 13. System Maintenance and Monitoring 13.1. The system will be maintained in accordance with the Data Protection Act 1998. 13.2. The system will only be maintained and monitored by companies which carry the relevant accreditation from the Security Systems and Alarm Inspection Body (SSAIB) or National Security Inspection (NSI). Page 7 of 7