1.1 The purpose of this Policy is to regulate the management, operation and use of the closed circuit television (CCTV) system at Trinity School, hereafter referred to as ‘the school'.
1.2 The system comprises a number of fixed and dome cameras located around the school site. All cameras are monitored by selected senior and administrative staff together with those directly involved in the security of the school site.
1.3 This Code follows Data Protection Act guidelines.
1.4 The Code of Practice will be subject to review bi-annually to include consultation as appropriate with interested parties.
1.5 The CCTV system is owned by the school.
2. Objectives of the CCTV scheme
2.1 (a) To protect the school buildings and their assets
(b) To increase personal safety and reduce the fear of crime
(c) To support the Police in a bid to deter and detect crime
(d) To assist in identifying, apprehending and disciplining offenders
(e) To protect members of the public and private property
(f) To assist in managing the school
3. Statement of intent
3.1 The CCTV Scheme will be registered with the Information Commissioner under the terms of the Data Protection Act 1998 and will seek to comply with the requirements both of the Data Protection Act and the Commissioner's Code of Practice.
3.2 The school will treat the system and all information, documents and recordings obtained and used as data which are protected by the Act.
3.3 Cameras will be used to monitor activities within the school and its car parks and other public areas to identify criminal activity actually occurring, anticipated, or perceived, and for the purpose of securing the safety and well being of the school, together with its visitors.
3.4.1 Staff have been instructed that static cameras are not to focus on private homes, gardens and other areas of private property.
3.4.2 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 being obtained using the school's forms for Directed Surveillance to take place, as set out in the Regulation of Investigatory Power Act 2000.
3.5 Materials or knowledge secured as a result of CCTV will not be used for any commercial purpose. Recorded materials will only be released to the media for use in the investigation of a specific crime and with the written authority of the police. Recorded materials will never be released to the media for purposes of entertainment.
3.6 The planning and design has endeavoured to ensure that the Scheme will give maximum 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.
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 school CCTV.
4. Operation of the system
4.1 The Scheme will be administered and managed by the Deputy Headmaster, in accordance with the principles and objectives expressed in the code.
4.2 The day-to-day management will be the responsibility of the Estates Manager during the day, out of hours and at weekends.
4.3 The CCTV system will be operated 24 hours each day, every day of the year.
5. Operational Control
5.1 The Estates Manager will check and confirm the efficiency of the system daily and in particular that the equipment is properly recording and that cameras are functional.
5.2 Access to the viewing monitors will be strictly limited to selected senior and administrative staff together with those directly involved in the security of the school site
5.3 Unless an immediate response to events is required, staff must not direct cameras at an individual or a specific group of individuals.
5.4 Staff, Visitors and others entering areas with CCTV viewing monitors will be subject to particular arrangement as outlined below.
5.5 Authorised Staff must satisfy themselves over the identity of any other visitors and the purpose of the visit. Where any doubt exists the CCTV images must be turned off.
5.6 The system may generate a certain amount of interest. It is vital that operations are managed with the minimum of disruption. Casual observations will not be permitted.
5.7 If an emergency arises out of hours permission must be obtained from the Deputy Headmaster or Estates Manager to view or process recorded material.
5.8 Other operational functions will include maintaining recorded materials and hard disc space, filing and maintaining occurrence and system maintenance logs.
5.9 Incidents involving the Emergency Services must be notified to the Deputy Headmaster or Estates Manager
6.1 Liaison meetings will be held as required with all staff involved in the support of the system.
7. Monitoring procedures
7.1 Camera surveillance may be maintained at all times.
7.2.1 Pictures will be continuously recorded or when activated by movement.
7.2.2 If covert surveillance is planned this must be authorised by the Deputy Headmaster, Estates Manager or in emergency by any member of SMT. A written record of this authorisation should be filed on an Authorisation Form.
8. Recorded material procedures
8.1 In order to maintain and preserve the integrity of the recorded material used to record events from the hard drive and the facility to use them in any future proceedings, the following procedures for their use and retention must be strictly adhered to:
(i) Each item of recorded material must be identified by a unique mark.
(ii) Before use each item on which images will be recorded must be cleaned of any previous recording.
(iii) The person making the recording shall register the date and time of recorded material insert, including recorded material reference.
(iv) Any recorded material required for evidential purposes must be sealed, witnessed, signed by the controller, dated and stored in a separate, secure recorded material store. If recorded material 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.
(v) If the recorded material is archived the reference must be noted.
8.2 Recorded materials may be viewed by the Police for the prevention and detection of crime, authorised officers of the Metropolitan Police for supervisory purposes, authorised demonstration and training.
8.3 A record will be maintained of the release of recorded materials to the Police or other authorised applicants. A register will be available for this purpose.
8.4 Viewing of recorded materials by the Police must be recorded in writing and in the log book. Requests by the Police can only be actioned under section 29 of the Data Protection Act 1998.
8.5 Should a recorded material be required as evidence, a copy may be released to the Police under the procedures described in paragraph 8.1 (iv) of this Code. Recorded materials will only be released to the Police on the clear understanding that the recorded material remains the property of the school, and both the recorded material and information contained on it are to be treated in accordance with this code. The school also retains the right to refuse permission for the Police to pass to any other person the recorded material or any part of the information contained thereon. On occasions when a Court requires the release of an original recorded material this will be produced from the secure recorded material store, complete in its sealed bag.
8.6 The Police may require the school to retain the stored recorded materials for possible use as evidence in the future. Such recorded materials will be properly indexed and properly and securely stored until they are needed by the Police.
8.7 Applications received from outside bodies (e.g. solicitors) to view or release recorded materials will be referred to the Headmaster. In these circumstances recorded materials 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. A fee can be charged in such circumstances: £10 for subject access requests; a sum not exceeding the cost of materials in other cases.
9. Breaches of the code (including breaches of security)
9.1 Any breach of the Code of Practice by school staff will be initially investigated by the Deputy Headmaster, in order for him to take the appropriate disciplinary action.
9.2 Any serious breach of the Code of Practice will be immediately investigated and an independent investigation carried out to make recommendations on how to remedy the breach.
10. Assessment of the scheme and code of practice
10.1 Performance monitoring, including random operating checks, may be carried out by the Estates Manager.
11.1.1 Any complaints about the school's CCTV system should be addressed to the Deputy Headmaster.
11.2 Complaints will be investigated in accordance with Section 9 of this Code.
12 Access by the Data Subject
12.1 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.
12.2 Requests for Data Subject Access should be made on an application form available from the Deputy Headmaster. A copy is attached to this document..
13. Public information
Copies of this Code of Practice will be available from the School Office.
Summary of Key Points
This Code of Practice will be reviewed every two years.
The CCTV system is owned and operated by the school.
Liaison meetings may be held with the Police and other bodies when a requirement is identified.
Recording recorded materials will be used properly indexed, stored and destroyed after appropriate use.
Recorded materials may only be viewed by Authorised School Staff and the Police.
Recorded materials required as evidence will be properly recorded witnessed and packaged before copies are released to the police.
Recorded materials will not be made available to the media for commercial or entertainment purposes.
Recorded materials will be deleted from the computer hard drive after 30 days.
Any Covert Surveillance or use of a Covert Human Intelligence Source being considered or planned as part of an operation must comply with the approved policies and procedures.
Any breaches of this code will be investigated by the Deputy Headmaster.
An independent investigation by SMT members will be carried out for serious breaches.
Breaches of the code and remedies will be reported to the Headmaster.
Updated June 2010