1.1 The purpose of this Policy is to regulate
the management, operation and use of the closed circuit television (CCTV)
system at Greenway School, hereafter referred to as ‘the school’.
1.2
The system comprises currently 2 fixed and 4 dome cameras located around the
school site (see site plan - Appendix 1).
The fixed cameras are monitored from the school office by Administrative
staff and the dome cameras are monitored through the school website (discrete
section password protected). The
password is only available to selected senior staff.
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.
2.1 The
objectives of the CCTV scheme are:
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, its grounds and
its car park 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 dome 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. Tapes will only be released to the media for use in the
investigation of a specific crime and with the written authority of the police.
Tapes 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.
4.1
The Scheme will be administered and managed by the Headteacher, in accordance
with the principles and objectives expressed in the code.
4.2
The day-to-day management will be the responsibility of both the Senior
Management Team, the office staff and the ICT Manager during the day and the
Headteacher and ICT Manager Team out of hours and at weekends.
4.3
The CCTV system will be operated 24 hours each day, every day of the year.
5.1
The ICT Manager will check and confirm the efficiency of the systems daily and
in particular that the equipment is properly recording and that cameras are
functional.
5.2
Unless an immediate response to events is required, staff in the ICT room must
not direct cameras at an individual or a specific group of individuals.
5.4
Visitors and other contractors wishing to enter the ICT room will be subject to
particular arrangement as outlined below.
5.5
Personnel in both the office and the ICT room must satisfy themselves over the
identity of any other visitors and the purpose of the visit. Where any doubt
exists access will be refused. Details
of all unscheduled visits and visitors will be endorsed in a CCTV log book.
5.6
Any visit may be immediately curtailed if prevailing operational requirements
make this necessary.
5.7
If out of hours emergency maintenance arises, the Headteacher or designated
responsible person must be satisfied of the identity and purpose of contractors
before allowing entry.
5.8
There must always be at least one member of the normal staff present within the
office when the fixed cameras are in operation. The fixed cameras will be switched off at the end of the day by
the office staff before they leave. The
school office will always be locked during out of school hours, at weekends and
during holidays.
5.9
Other administrative functions will include maintaining video tapes and hard
disc space, filing and maintaining occurrence and system maintenance logs.
5.10
Emergency procedures will be used in appropriate cases to call the Emergency
Services.
6.1
Liaison meetings may be held with all bodies involved in the support of the
system.
7.1
Fixed camera surveillance may be maintained at all times during school times.
7.2.1
A monitor is installed in the office to which pictures from two of the fixed
cameras will be continuously recorded.
7.2.2
If covert surveillance is planned using the school’s surveillance cameras West
Sussex Police will be consulted prior to any action taking place. In the case of covert surveillance a full
record of the action will be made and then reported to the school’s governing
body.
8.1
In order to maintain and preserve the integrity of the tapes 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:
8.2
Tapes may be viewed by the Police for the prevention and detection of crime.
8.3
A record will be maintained of the release of tapes to the Police or other
authorised applicants. A register will be available for this purpose.
8.4
Viewing of tapes 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 tape be required as evidence, a copy may be released to the Police
under the procedures described in paragraph 8.1 (iv) of this Code. Tapes will
only be released to the Police on the clear understanding that the tape remains
the property of the school, and both the tape 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 tape
or any part of the information contained thereon. On occasions when a Court requires
the release of an original tape this will be produced from the secure evidence
tape store, complete in its sealed bag.
8.6
The Police may require the school to retain the stored tapes for possible use
as evidence in the future. Such tapes 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
tapes will be referred to the Headteacher. In these circumstances tapes 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.
9.1
Any breach of the Code of Practice by school staff will be initially
investigated by the Headteacher, in order for him/her 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.
10.1
Performance monitoring, including random operating checks, may be carried out
by the Headteacher.
11.1
Any complaints about the school’s CCTV system should be addressed to the
Headteacher.
11.2
Complaints will be investigated in accordance with Section 9 of this Code.
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 in writing to the Headteacher.
Copies
of this Code of Practice will be available to the public from the School Office
and the Headteacher.