SPECIALIST MATHEMATICS AND SCIENCE ACADEMY Whole School Policy. CCTV Policy

Transcription

1 SPECIALIST MATHEMATICS AND SCIENCE ACADEMY Whole School Policy Date reviewed: January 2016 Date approved: (FGB) January 2016 Next review: September Introduction CCTV Policy a. The purpose of this Policy is to regulate the management, operation and use of the closed circuit television (CCTV) system at Christ s College Finchley, hereafter referred to as the School'. b. The CCTV system is owned by the school. c. The system comprises of a number of cameras located in and around the school premises. All cameras are overt in nature. The use of covert cameras is strictly prohibited. d. CCTV cameras are located in learning spaces within the school as well as communal areas, walk-ways, main entrances and exits. e. All cameras are monitored by designated senior staff together with those directly involved in the security of the school site. f. The school will follow Data Protection Act guidelines. g. Operation of the School CCTV Policy will be reviewed bi-annually by the School Governing Body and will include consultation, as appropriate, with interested parties. CCTV Policy 2016 GAD/mac/so (Judicium) Page 1

2 2. Objectives of the CCTV Scheme a. To protect the School buildings and their assets; b. To increase personal safety of staff, students and visitors and reduce the fear of crime; c. To support the Police in the protection and prevention of crime; d. To assist in identifying, apprehending and disciplining offenders; e. To protect members of the public and private property; f. To reflect on behavioural instances of pupils; and g. Facilitate the identification of any activities/event which might warrant disciplinary proceedings being taken against staff or students and assist in providing evidence to managers and/or to a member of staff or student against whom disciplinary or other action is, or is threatened to be taken. 3. Statement of Intent a. The CCTV scheme will be registered with the Information Commissioner s Office (ICO) under the terms of the Data Protection Act 1998 and will seek to comply with the requirements of both the Data Protection Act and the Commissioner's Code of Practice. b. The School will treat the system and all information, documents and recordings obtained and used as data which are protected by the Act. c. Cameras will be used to monitor activities within all perimeter areas of the building to protect for arson, all classrooms and communal walk ways to identify criminal activity actually occurring, anticipated, or perceived, and for the purpose of securing the safety and wellbeing of the School, together with the wellbeing of school personnel, pupils and its visitors. d. Staff have been instructed to ensure cameras are not able to focus on private homes, gardens and other areas of private property. e. It is important for staff to understand that whilst on the premises, they may be recorded from time to time on surveillance video-tape and that they have consented to this. As this policy details, there are however strict security controls over this recorded data and under normal circumstances no such data will be retained for longer than 30 days. Any questions about data held in this way should be addressed to the Headteacher in the first instance. f. Staff must not direct cameras at an individual, their property or a specific group of individuals, unless it is required within the stated approved reasons set out in the Regulation of Investigatory Powers Act. Any direct surveillance carried out will also only be proportionate to the purpose it is designed to achieve. g. Materials or knowledge secured as a result of CCTV will not be used for any commercial purpose. Data from CCTV footage will only be released to the media for use in the investigation of a specific crime and with the written authority of the Police. Data from CCTV footage will never be released to the media for purposes of entertainment. h. The planning and design has endeavoured to ensure that the CCTV scheme will give maximum CCTV Policy 2016 GAD/mac/so (Judicium) Page 2

3 effectiveness and efficiency but it is not possible to guarantee that the system will cover or detect every single incident taking place in the areas of coverage. i. 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 school CCTV. 4. Operation of the CCTV System a. The system will be administered and managed by Facilities & Business Manager, under the direction of the Headteacher / Deputy Headteacher in accordance with the principles and objectives expressed in this Policy. The day-to-day management will be the responsibility of Facilities and Business Manager. b. The CCTV system will be operated 24 hours per day, 365 days per year. c. CCTV signs are located in all areas that are covered by CCTV internally and externally. Signs are place on the gates to notify all entrants to the School of the CCTV system. 5. Operational Control a. The Facilities and Business Manager will check and confirm the efficiency of the system and in particular that the equipment is properly recording and that cameras are functional. b. The System Administrator will ensure that all staff involved with the operation of the CCTV system are properly trained and fully understand their roles and responsibilities in respect of data protection legislation e.g. i. the user s security policy (procedures to have access to recorded images); ii. the user s disclosure policy; iii. rights of individuals in relation to their recorded images. c. Access to the viewing monitors and recorded data will be strictly limited to designated senior and administrative staff together with those directly involved in the security of the school, including the Police. d. Staff, visitors and others entering areas with CCTV viewing monitors will be subject to particular arrangement as outlined below. e. Authorised staff must satisfy themselves over the identity of any other visitors and the purpose of their visit. f. The system may generate a certain amount of interest. It is vital that operations are managed with the minimum of disruption. g. If an emergency arises out of hours, permission must be obtained from the Headteacher to view or process data from CCTV footage. h. Other operational functions will include maintaining data and hard disc space, filing and maintaining occurrence and system maintenance logs. CCTV Policy 2016 GAD/mac/so (Judicium) Page 3

4 i. Incidents involving the Emergency Services must be notified to the Headteacher or Deputy. 6. Monitoring Procedures a. Camera surveillance may be maintained at all times; b. The CCTV footage will only be accessed to identify a specific event; c. The CCTV system will not be used to monitor live events unless authorised by the Headteacher; d. Pictures will be continuously recorded or when activated by movement; e. Covert surveillance activities of law enforcement agencies are not covered here because they are governed by the Regulation of Investigatory Powers Act (RIPA) Data Copy Procedures a. In order to maintain and preserve the evidential integrity of data removed from the hard drive used to record events from the CCTV system, and the facility to use them in any future proceedings; the following procedures for their use and retention must be strictly adhered to: i. Before use, each item onto which data will be copied must be cleaned of any previous recording. ii. Each item of data must be identified by a unique reference number. iii. The person making the recording shall register the details of the copied data including, start date and time, duration, cameras used, justification for copy and unique reference number. The individuals appearing in the footage must not be labelled on the details. iv. Any data removed from the hard drive will be stored in a locked cabinet within the facilities office. v. Any data required for evidential purposes must be sealed, witnessed, signed by the controller, dated and stored in a separate, secure data store. If data is not copied for the Police before it is sealed, a copy may be made at a later date providing that it is then resealed, witnessed, signed by the controller, dated and returned to the evidence material store. vi. Recorded data removed from the system must not be retained for longer than necessary. Specifically, data will be destroyed on completion of any investigation resulting in no further action. b. Data may be viewed by the Police for the prevention and detection of crime, authorised officers of the Police for supervisory purposes, authorised demonstration and training. c. Footage must never be sent to an individual outside the School for any purpose without written permission from the Headteacher. d. A record will be maintained of the release of data to the Police or other authorised applicants. A register will be made available for this purpose. e. Viewing of data by the Police must be recorded in writing and in a log book. f. The School also retains the right to refuse permission for the Police to pass to any other person the disk or any part of the information contained. CCTV Policy 2016 GAD/mac/so (Judicium) Page 4

5 g. Should data be required as evidence, a copy may be released to the Police under the procedures described above. h. The School retains the right to refuse permission for the Police to pass to any other person the data or any part of the information contained thereon unless required for criminal investigation reasons. i. Evidential data will be released to Police on signature. The school will not store evidential data on behalf of Police. j. Applications received from outside bodies (e.g. solicitors) to view or release data will be referred to the Headteacher. In these circumstances data will normally be released where satisfactory documentary evidence is produced showing that they are required for legal proceedings, a subject access request, or in response to a Court Order. 8. Record Keeping/Incident Logs a. The School will maintain comprehensive records relating to the management of the system and incidents. Model documents from the installers/providers of CCTV system may be utilised for this purpose. 9. Retention of Data a. There are no specific statutory guidelines about the length of time data images should be retained. Consequently, the period of retention will be determined locally, will be documented and understood by those operating the system and will be for the minimum period necessary to meet the objectives of the CCTV scheme. A period of 30 days is considered adequate unless determined otherwise (see 9.b below) b. Where CCTV data is required to assist in the prosecution of a criminal offence, data will need to be retained until collected by the Police. c. Measures to permanently delete data should be clearly understood by persons that operate the system. These may be achieved by means of regular rotation of video tape(s) to ensure old data is overwritten or adjusting the image quality on disc based systems to ensure data is overwritten after a set period. d. Systematic checks should be carried out to ensure the deletion regime is strictly followed. 10. Breaches of the Policy (including breaches of security) a) Any breach of the Policy by School staff will be initially investigated by a Deputy Headteacher in the first instance in order to determine the appropriate disciplinary action. Any serious breach of this policy will be immediately investigated and an independent investigation carried out to make recommendations on how to appropriately deal with the breach. CCTV Policy 2016 GAD/mac/so (Judicium) Page 5

6 11. Assessment of the CCTV System a) An annual assessment will be undertaken by the Facilities & Business Manager or Headteacher to evaluate the effectiveness of the CCTV system. b) The outcome of the assessment will be reported to a meeting of the school Governors who will determine if the system is achieving the objectives of the scheme, or if the system requires modification. 12. Complaints a. Any complaints about the School's CCTV system should firstly be made, in writing, to the Headteacher. 13. Access by the Data Subject a. The Data Protection Act provides Data Subjects (individuals to whom "personal data" relate) with a right to data held about themselves, including those obtained by CCTV. b. Requests for Data Subject Access for the school must be in writing and addressed to the Headteacher. Sufficient information must be given to confirm the identity of the individual and to locate the event on stored data. c. Data will not be released to individuals if their request falls under one of the exemptions defined by the Data Protection Act. 14. Public Information a. Copies of this Policy will be available to the public on the school s website. CCTV Policy 2016 GAD/mac/so (Judicium) Page 6