C.C.T.V

C.C.T.V. Policy

Introduction:

1st Wimborne Minster Scout Group has installed a closed circuit television (CCTV) system to provide a safe and secure environment for the young people, adult volunteers, members, visitors, clients, contractors, suppliers and to protect the group’s property.

This document sets out the accepted use and management of the CCTV System and images to ensure that the group complies with the General Data Protection Regulation (GDPR), the Data Protection Act (DPA) 2018 and the Surveillance Camera Code of Practice.

This CCTV policy has been produced using guidance available from the Information Commissioner’s Office and the Surveillance Camera Commissioner.

Within this document we consider the purpose and aims of our CCTV system, provide details of the operation of the system, the considerations given to the privacy of individuals, the security of retained data and how we will handle subject access requests.

Purpose and Aims of the CCTV System:

The purposes of the Group using CCTV systems include:

  • To deter crime
  • To assist in the prevention or detection of crime or equivalent malpractice.
  • To assist in the identification, apprehension and prosecution of offenders.
  • To monitor and maintain the security of the Group’s premises, grounds and equipment.
  • To ensure that health and safety rules and procedures are being complied with.
  • To assist with the identification of unauthorised actions or unsafe working practices that might result in disciplinary proceedings being instituted against volunteers and to assist in providing relevant evidence.
  • To promote productivity and efficiency.
  • CCTV Images will NOT be used in any media.
  • There is no use of automated recognition (ANPR).

The need for a CCTV solution arises due to:

The site is left unoccupied for extended periods of time.  During such times there have been incidents of unexplained damage or attempted break-in’s.  CCTV provides a deterrent solution, can provide evidence to determine the identity of the person(s) committing the offence and effect prosecution.

The remote location of the premises is often dark, particularly when leaders are arriving or leaving the HQ unaccompanied, resulting in the consideration of personal safety issues.  Floodlights and Video recording are only activated by significant motion and/or heat detection within close proximity to the device(s).

CCTV may also be used to monitor our volunteers safety when carrying out their activities and duties. For these reasons the information processed may include visual images, personal appearance and behaviours. This information may be about volunteers, members, visitors, offenders and suspected offenders, members of the public entering or in the immediate vicinity of the area under surveillance.

Location of cameras:

All CCTV Floodlight Cameras are clearly visible and located at key access points and other areas of concern around the Group’s premises; principally at the entrance doors (including garage) and areas where there have been previous incidents of unexplained damage or attempted break-in’s.

The cameras are positioned to cover communal or public areas on the Charity’s premises and they have been sited so that they provide clear images.  No camera focuses, or will focus, on the surrounding private residential gardens and buildings, toilets, shower facilities or changing rooms.

Appropriate signs are prominently displayed so that volunteers, members, other visitors and members of the public are aware they are entering an area where CCTV installation is in use.

Recording and retention of images:

The CCTV surveillance system is owned by the 1st Wimborne Minster Scout Group. Authority for use of CCTV and responsibility for CCTV use rests with the Executive Committee of the Group (the Data Controllers or DCO). The Group Scout Leader (GSL), Chairman and other nominated individuals are responsible for the day-to-day operation of the system (Data Processors) and ensuring compliance with this policy.

The CCTV system runs 24 hours a day, 7 days a week with remote monitoring application provided by Ring.com which captures and stores images and audio.  Videos are securely stored on a server within the monitoring application for 30 days, after which they are automatically destroyed.

Image recording is not continuous and is only started if there is a predefined amount of motion within a predefined region in view of each camera.  These settings have been adjusted to minimise the capture of images of other authorized users of the surrounding area (such as those using the public rights of way adjacent to the premises).

The CCTV images are not actively monitored and are normally reviewed post incident, however notification settings can be used to alert the nominated individuals of activity as well as stream Live View.

Access to and disclosure of images:

Access to, and disclosure of, images recorded on CCTV is restricted.  This ensures that the rights of individuals are retained. 

Access to recorded images is restricted to the operators of the CCTV system and to those line managers who are authorised to view them in accordance with the purposes of the system.  Viewing of recorded images is normally after an incident has occurred or when a concern has been raised.

Disclosure of images to other third parties will only be made other than in accordance with relevant law enforcement or a valid Subject Access Request (SAR) has been made and will be limited to:

  • The police and other law enforcement agencies where the images recorded could assist in the prevention or detection of a crime.
  • The police and other law enforcement agencies where the images recorded could assist or the identification and prosecution of an offender.
  • The police and other law enforcement agencies where the images recorded could assist the identification of a victim or witness.
  • Prosecution agencies, such as the Crown Prosecution Service.
  • Relevant legal representatives.
  • Line managers involved with disciplinary and performance management processes.
  • Individuals whose images have been recorded and retained (unless disclosure would prejudice the prevention or detection of crime or the apprehension or prosecution of offenders).

The Group Scout Leader or Group Executive Committee are the only person(s) who are permitted to authorise disclosure of images to external third parties such as law enforcement agencies.

Under the DPA, individuals have the right to receive a copy CCTV recordings, if they are recognisable from the image.  Such requests must be made in writing to the Group’s Executive Committee and include:

  • The date and time the images were recorded
  • Information to identify the individual, if necessary
  • The location of the CCTV camera
  • Proof of Identity.

The Group will always check the identity of the person making the request before processing it and will respond within 30 days from the date of receiving the request.  If disclosure of your images will reveal third party information, the images of third parties may need to be obscured to protect their privacy.

If the Group is unable to comply with your request because access could prejudice the prevention or detection of crime or the apprehension or prosecution of offenders, you will be advised accordingly.

All requests for disclosure and access to images will be documented, including the date of the disclosure, to whom the images have been provided and the reasons why they are required.  If disclosure is denied, the reason will be recorded.

Covert recording:

Covert monitoring may include both video and audio recording.

Covert monitoring will only take place for a limited and reasonable amount of time consistent with the objective of assisting in the prevention and detection of particular suspected criminal activity, or, equivalent malpractice. Once the specific investigation has been completed, covert monitoring will cease.

Information obtained through covert monitoring will only be used for the prevention or detection of criminal activity, or, equivalent malpractice.  All other information collected in the course of covert monitoring will be deleted or destroyed unless it reveals information which the Group cannot reasonably be expected to ignore.

Staff training:

The Group will ensure that all volunteers handling CCTV images or recordings are trained in the operation and administration of the CCTV system and on the impact of the Data Protection Act 2018 with regard to that system.

Implementation:

The Group Executive Committee is responsible for the implementation of this policy along with ensuring policy compliance and the operation of the CCTV system.  This policy and the need for CCTV will be reviewed regularly although it is not anticipated that the need for a CCTV system to be in place will change..  Any complaints or enquiries about the operation of the Group’s CCTV system should be addressed to them.

NB: From 25 May 2018, people who use CCTV for domestic purposes, ie to monitor their property, even if it films beyond the boundaries of their property will be exempt from paying a fee under data protection law.