CCTV Policy

Approved by Trust Board on 10 December 2020

Applicable from 11 December 2020

Review Date: December 2024 

This document represents a Trust-wide which is approved by the Trust Board for use in the Trust’s academies.

It is the responsibility of individual academies to insert information into the document so that it is relevant to local circumstances and practice, whilst not removing the key principles contained within it, prior to the policy being noted by Local Governing Bodies.

If any changes to this policy are proposed at a local level, these must be referred to the Trust’s JCNC through the Head of HR. When Trust colleagues are working on Co-op Group premises (for example, 1 Angel Square), Co-op policies will apply. 

Co-operative Academies Trust Policy on the use of CCTV

Closed Circuit Television CCTV Policy Document for Co-op Academy Swinton

1. Introduction

The purpose of this document is to regulate the management, operation and use of CCTV systems in our academy.

1.1        Co-op Academy Swinton uses closed circuit television (CCTV) images to reduce crime and monitor the academy buildings in order to provide a safe and secure environment for pupils, staff and visitors, to prevent the loss or damage to property and to assist in the investigation of accidents, incidents and near misses.

1.2        The system comprises of 95 fixed cameras and 2 dome cameras.

1.3        The system does not have sound recording capability.

1.4        The CCTV system is owned and operated by Co-op Academy Swinton and is maintained by Elite digital. The deployment of which is determined by the academy’s leadership team, in line with this policy which has been agreed with trade union representatives.

1.5        The CCTV is monitored centrally from the Behaviour office in the main body of the school located on the IT corridor. Authorisation to view CCTV footage must be obtained from the Principal or Vice Principals and can only be viewed by SLG, PPCs, Year Team and Behaviour Mentors. CCTV footage must be viewed in pairs unless otherwise authorised by the Principal.

1.6        The introduction of, or changes to, CCTV monitoring will be shared with local trade union representatives, staff and the academy community.

1.7        The academy’s CCTV Scheme is registered with the Information Commissioner under the terms of the Data Protection Act 1998. The use of CCTV, and the associated images and any sound recordings, is covered by the Data Protection Act 1998. This policy outlines the academy’s use of CCTV and how it complies with the Act.

1.8        All authorised operators and employees approved to access images are aware of the procedures that need to be followed when accessing the recorded images and sound. All operators are trained by the academy’s data controller in their responsibilities as part of the requirements of this policy document, the academy’s safeguarding policies and procedures, e-safety information and the Data Protection Act. All employees are aware of the restrictions in relation to storage of, access to, and disclosure of, recorded images and sound. Failure to adhere to these requirements could lead to disciplinary action.

2. Statement of Intent

2.1        The academy complies with the 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. The checklist of operation (appendix 1) is adapted from this document. Further information is available at:
https://ico.org.uk/media/for-organisations/documents/1542/cctv-code-of-practic e.pdf

2.2        CCTV warning signs will be clearly and prominently placed at all external entrances to the academy, including main staff/pupil and visitor entrances and academy gates, as coverage includes outdoor areas. Signs will contain details of the purpose for using CCTV (see appendix 2). In areas where CCTV is used, the academy will ensure that there are prominent signs placed at both the entrance of the CCTV zone and within the controlled area.

2.3        The planning and design of the system has endeavoured to minimise any invasion of privacy and ensure that the Scheme will give maximum effectiveness and efficiency, but it is not possible to guarantee that the system will fully meet this brief or detect every single incident taking place in the areas of coverage.

2.4        CCTV data will not be used in any aspect of performance management, unless with the written consent of the employee concerned.

3. Siting the Cameras 

3.1        Cameras will be sited so they only capture images relevant to the purposes for which they are installed (described above) and care will be taken to ensure that reasonable privacy expectations are not violated. The academy will ensure that the location of equipment is carefully considered to ensure that images captured comply with the Data Protection Act, cameras will be regularly checked to ensure they have not been moved or tampered with in any way.

3.2        The academy will make every effort to position cameras so that their coverage is restricted to the academy’s premises, which may include outdoor areas.

3.3        CCTV will not be used in classrooms, with the exception of the agreed use of equipment designed to provide professional development opportunities, which will only be used with the permission of all involved (see IRIS Protocol at appendix 3 for more detail).

3.4        Members of staff upon request will have access to details of where CCTV cameras are situated, with the exception of cameras placed for the purpose of covert monitoring (see section 4).

3.5        Only suitably competent contractors with the relevant knowledge and experience will be employed to install and maintain the equipment.

4. Covert Monitoring 

4.1        Covert monitoring should not normally be considered, and should only be used in exceptional circumstances, for example:

i) Where there is good cause to suspect that a criminal activity or equivalent malpractice which may constitute gross misconduct;

ii) Where notifying the individuals about the monitoring would seriously prejudice the reason for making the recording.

4.2        In these circumstances written authorisation must be obtained from the Director of the Trust or Chair of the Trust Board before allowing such an operation to take place. Unless the Director of the Trust is instructed otherwise (e.g. in a police investigation), members of the JCNC will be informed confidentially about any plans for covert monitoring.

4.3        Covert monitoring must cease following completion of an investigation.

4.4        Cameras sited for the purpose of covert monitoring will not be used in areas which are reasonably expected to be private, for example toilets or changing areas.

5. Storage and Retention of CCTV images 

5.1        Recorded data will not be retained for longer than is necessary to meet the purposes of recording them, and will be deleted/erased appropriately and in line with approved procedures for the academy as documented in appendix 1. While retained, the integrity of the recordings will be maintained to ensure their evidential value and to protect the rights of the people whose images have been recorded.

5.2        All retained data will be stored securely. Access will be limited to named operators/staff only (see appendix 1) whose access is authorised by the Principal.

6. Access to CCTV images 

6.1        Access to recorded images will be restricted to those staff authorised to view them, and will not be made more widely available.

6.2        A list of staff authorised to view Images from this CCTV system will be held by the academy.

6.3        A log will be maintained of when CCTV footage is accessed and reviewed (name of reviewer, date & reason).

7. Subject Access Requests (SAR)

7.1        Individuals have the right to request access to CCTV footage, relating to themselves, under the Data Protection Act.

7.2        All requests must be made in writing to the Principal / Headteacher. Individuals submitting requests for access will have to provide sufficient information to enable the footage relating to them to be identified and isolated. For example, date, time and location.

7.3        The academy will respond to requests within 40 calendar days of receiving the written request and fee.

7.4        At the Trust’s discretion, a fee of £10 may be charged per Subject Access Request.

7.5        The academy reserves the right to refuse access to CCTV footage where this would prejudice the legal rights of other individuals or jeopardise an ongoing investigation. Where images of other individuals are on the CCTV footage their permission will be sought before access is allowed.

8. Access to and Disclosure of Images to Third Parties 

8.1        There will be no disclosure of recorded data to third parties other than to authorised personnel such as the Police and service providers to the academy where these would reasonably need access to the data (e.g. investigators).

8.2        Requests should be made in writing to the Principal.

8.3        The data may be used within the Trust’s discipline and grievance procedures as required, and will be subject to the usual confidentiality requirements of those procedures.

9. Complaints 

9.1 Complaints and enquiries about the operation of CCTV within the academy should be directed to the Principal in the first instance.

9.2        Failure of authorised operators/staff to comply with the requirements of this policy will lead to disciplinary action under the Trust’s disciplinary procedure.

10. Further Information & Guidance 

Further information and guidance on CCTV and its use is available from the following sources:

• Data Protection Code of Practice for surveillance cameras and personal information 2015 (published by the Information Commissioners Office www.ico.org.uk ): https://ico.org.uk/media/for-organisations/documents/1542/cctv-code-of-pra ctice.pdf 
• The Government’s Surveillance Camera Code of Practice 2013: https://www.gov.uk/government/publications/surveillance-camera-code-of-practice  
• Guidance on conducting a privacy impact assessment: https://ico.org.uk/media/for-organisations/documents/1595/pia-code-of-prac tice.pdf 
• Regulation of Investigatory Powers Act (RIPA) 2000
• Data Protection Act 1998
• Freedom of Information Act 2000
• Protection of Freedoms Act 2012
• Crown Prosecution Service – www.cps.gov.uk 

11. Review 

This policy will be reviewed every 3 years, or sooner if required due to changes in legislation or statutory guidance.

Appendix 1 – Checklist of Operation

The Academy’s CCTV system and the images produced by it are controlled in line with our policy, our data controller will notify the Information Commissioner about the CCTV system and its purpose (which is a legal requirement of the Data Protection Act 1998).

The Academy has considered the need for using CCTV and has decided it is required for the prevention and detection of crime and for protecting the safety of users of the site. It will not be used for other purposes. We conduct an annual review of our use of CCTV.

Appendix 2 – CCTV Signage

It is a requirement of the Data Protection Act 1998 to notify people entering a CCTV protected area that the area is monitored by CCTV and that pictures are recorded.

The Academy is to ensure that this requirement is fulfilled.

The CCTV sign should include the following:

• That the area is covered by CCTV surveillance and pictures are recorded • The purpose of using CCTV
• The name of the school
• The contact telephone number or email address of the systems operators for enquiries (this will either be the school or if monitored externally the details of the provider)
• Your signage must include a pictorial image identical to the one shown below 
  

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Appendix 3 – Map of CCTV Locations