CCTV Policy
Emily Watson
Building Manager
South East Dance
The Dance Space
Contents
1. Introduction
2. CCTV system overview
3. Purposes of the CCTV system
4. Monitoring and recording
5. Compliance with Data Protection legislation
6. Applications for disclosure of images
7. Retention of images
8. Complaints Procedure
9. Monitoring compliance
10. Policy Review
1. Introduction
The Dance Space building has in place a CCTV surveillance system “the CCTV system” internally and externally. This policy details the purpose, use and management of the CCTV system at The Dance Space and details the procedures to be followed in order to ensure that South East Dance complies with relevant legislation and the current Information Commissioner’s Office CCTV Code of Practice. South East Dance will have due regard to the Data Protection Act 2018, the General Data Protection Regulation (GDPR) and any subsequent data protection legislation, and to the Freedom of Information Act 2000, the Protection of Freedoms Act 2012 and the Human Rights Act 1998.
This policy is based upon guidance issued by the Information Commissioner’s Office. CCTV images are monitored and recorded in strict accordance with this policy.
2. CCTV System overview
The CCTV system is owned by South East Dance Ltd and managed by South East Dance Ltd and its appointed agents. Under current data protection legislation, South East Dance Ltd is the ‘data controller’ for the images produced by the CCTV system. South East Dance Ltd are registered with the Information Commissioner’s Office and the registration number is ZB100049.
The CCTV system operates to meet the requirements of the Data Protection Act and the Information Commissioner’s guidance. The Building Manager is responsible for the overall management and operation of the CCTV system, including activities relating to installations, recording, reviewing, monitoring and ensuring compliance with this policy.
A total of 16 CCTV Cameras are placed at North, South, East and West elevation of the external building, as well as intermittently at entrances and exits and in communal corridors and circulation spaces internally.
Signs are placed adjacent to external cameras, in order to inform staff, students, visitors and members of the public that CCTV is in operation. The signage indicates that the system is managed by South East Dance. The Building Manager is responsible for ensuring that adequate signage is erected in compliance with the ICO CCTV Code of Practice. Cameras are sited to ensure visibility of vulnerable public facing areas.
Cameras are not sited to focus on private residential areas or sensitive personal spaces internally. The CCTV system is operational and is capable of being monitored for 24 hours a day, every day of the year.
The CCTV system is subject to a Data Protection Impact Assessment. Any proposed new CCTV installation is subject to a Data Protection Impact Assessment. Any new CCTV Camera installation is subject to a privacy assessment.
3. Purposes of the CCTV system
The principal purposes of the installed CCTV system at The Dance Building are as follows: - for the prevention, reduction, detection and investigation of crime and other incidents; - to ensure the safety of staff, participants and visitors, to assist in the investigation of vandalism, trespass or break in or other undesirable activity outside of occupied hours.
The CCTV system will be used in a manner that is consistent with respect for the individual’s privacy. The CCTV system will not be live monitored and will be located in a locked surveillance room for footage retrieval only when required. There will not be a CCTV monitoring point located in any public reception area or office space. The CCTV System will not be used to record sound, or to provide recorded images for the internet.
4. Monitoring and Recording
Cameras are monitored in the Security Control Room, which is a secure area, locked with access only permitted by the Building Manager or Executive Director.
Images are recorded centrally into built in data storage, located securely in the Surveillance Room. Images are only viewable via a monitor with passcode, managed by the South East Dance Building Manager.
The cameras installed provide images that are of suitable quality for the specified purposes for which they are installed and all cameras are checked daily to ensure that the images remain fit for purpose and that the date and time stamp recorded on the images is accurate.
All images recorded by the CCTV System remain the property and copyright of South East Dance Ltd. There will be no monitoring of staff activities, unless there are exceptional circumstances, e.g. if a serious suspicion of misconduct arises. In the unlikely event of this occurring, any monitoring will be carried out in accordance with Part 3 of the Information Commissioner’s Employment Practices Code.
5. Compliance with Data Protection Legislation in its administration of its CCTV system
South East Dance Ltd complies with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. Due regard is given to the data protection principles embodied in GDPR. These principles require that personal data shall be: a) processed lawfully, fairly and in a transparent manner; b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed; d) accurate and, where necessary, kept up to date; e) kept in a form which permits identification of the data subjects for no longer than is necessary for the purposes for which the personal data are processed; f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
6. Applications for disclosure of images
Requests by individual data subjects for images relating to themselves “Subject Access Request” should be submitted in writing to South East Dance Ltd Building Manager, together with proof of identification.
In order to locate the images on the CCTV system, sufficient detail must be provided by the data subject in order to allow the relevant images to be located and the data subject to be identified.
Where South East Dance Ltd is unable to comply with a Subject Access Request without disclosing the personal data of another individual who is identified or identifiable from that information, it is not obliged to comply with the request unless satisfied that the individual has provided their express consent to the disclosure, or if it is reasonable, having regard to the circumstances, to comply without the consent of the individual.
A request for images made by a third party should be made in writing to the Building Manager at South East Dance. In limited circumstances it may be appropriate to disclose images to a third party, such as when a disclosure is required by law, in relation to the prevention or detection of crime or in other circumstances where an exemption applies under relevant legislation. Such disclosures will be made at the discretion of the Building Manager, with reference to relevant legislation and where necessary, following advice from South East Dance Executive Director and Board of Trustees. A record of any disclosure made under this policy will be held on the CCTV management system, itemising the date, time, camera, requestor, authoriser and reason for the disclosure.
7. Retention of images
Unless required for evidential purposes, the investigation of an offence or as required by law, CCTV images will be retained for no longer than 30 days from the date of recording. Images will be automatically overwritten after this point. Access to retained CCTV images is restricted to the Building Manager and other persons as required and as authorised by the Building Manager.
8. Complaints Procedure
Complaints received in relation to the use of the CCTV system or retention of images or footage should be made to the Building Manager in writing, who will investigate and then follow the correct procedures, taking advice from the Executive Director and the Board of Trustees.
9. Monitoring Compliance
All staff employed by South East Dance as well as Leasehold office tenants will be made aware of this policy. All staff with responsibility for accessing, recording, disclosing or otherwise processing CCTV images will be required to undertake data protection training.
10. Policy review
South East Dance Ltd usage of CCTV and the content of this policy shall be reviewed annually by the Building Manager with reference to the relevant legislation or guidance in effect at the time. Further reviews will take place as required.