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Murray Edwards College
University of Cambridge

CCTV Code of Practice

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CCTV Code of Practice

Adopted by Domestic & Estates Committee:  2014

Review Date:

Committee Ownership: Domestic & Estates

 

Purposes of the CCTV system

The purposes of maintaining a CCTV system in the college include:

  • Monitoring the security of premises and the members of the college

  • Prevention, investigation and detection of crime

  • Apprehension and prosecution of offenders (including potential use of images in criminal proceedings).

Responsibility for the scheme

The College Council will be responsible for the scheme. Operational responsibility lies with the Bursar (as Data Protection Officer), with delegation to the Head Porter and exceptional delegation to other Heads of Department when required.

The reasons for using CCTV

Murray Edwards College is an open site. The College buildings are situated within gardens open to the public, and grounds are habitually used by members of the public and local residents. Access to buildings, principally inhabited by students, is controlled by an electronic key or by the duty Porter.  The openness is valued by the College, and access between buildings would be impractical under a regime of day-time locking up. Incidents and thefts occur and CCTV cameras installed at strategic points such as vending machines, bicycle sheds and the street entrances assist in the prevention and detection of crime.

Data protection and processing

The College’s Data Protection Registration includes provision for the use of CCTV. The College’s Data Protection Policy states: "The College operates a number of CCTV cameras in order to assist with security for members of the College Community and in respect of College property. If a member of the College Community has any queries regarding the operation of the CCTV system; they should speak to the Data Protection Officer." It is intended that data will be processed only in furtherance of one of the purposes of the CCTV system.

Security and disclosure policies

Data on the CCTV system will routinely be kept and backed up for 30 days and then destroyed. Porters will be trained in the use of the CCTV system and in the data protection principles governing its operation, including the principle that the equipment must be used only for the purposes stated.  Porters will be made aware that access to recorded images must be sought and may only be authorised by the Head Porter, Deputy Head Porter or responsible College Officer. If data is exceptionally kept for one of the purposes outlined, for instance to preserve a copy as evidence for potential criminal proceedings, it will be kept in the Head Porter’s safe. The data will be disclosed only to responsible College Officers and to the police. The data will be accompanied by the following documentation:

  • The date and time on which the images were removed from the general system for use in anticipation of legal proceedings

  • The reason why they were removed from the system

  • The name of the person removing the images

  • The name(s) of any person(s) viewing the images. If this should include third parties, this will include the organisation to which the third party belongs

  • The reason for the viewing

  • The outcome, if any, of the viewing

  • Any crime incident number to which the images may be relevant

  • The location of the images. For instance, if the images are handed to a police officer for retention, the name and station of the police officer.

  • The signature of the collecting police officer, where appropriate.

Viewing of recorded images will take place only in a restricted area, normally the Porter’s Lodge.

Siting of equipment

Cameras are sited to monitor only spaces which are appropriate to the purposes of CCTV system.  Where the system potentially covers private spaces within the College, or neighbouring properties they will be blanked from the view of the cameras. Clear signs will alert the public that they are entering a zone covered by surveillance equipment.

Quality of images and maintenance of the system

The system provides images adequate for the investigation and detection of crime but does not automatically recognise faces. The recorded location of cameras and the accuracy of date and time recorded will be checked on a yearly basis by the Head Porter. The cameras and system will be serviced on a yearly basis. A maintenance log will be kept in the Porters’ Lodge in the CCTV file. Damage and faults are to be reported to the Head Porter in the first instance or other lodge staff in her absence. The Head Porter is responsible for the contract with the CCTV provider and maintaining a 24-hour repair service.

Access to and disclosure of images to third parties

Access to, and disclosure of, the images recorded by the CCTV system is restricted to preserve the rights of individuals and to ensure that the chain of evidence remains intact should images be required for evidential purposes. Access to recorded images is normally restricted to the Head Porter, the Deputy Head Porter, the IT Manager and to responsible College Officers. All access to processed images will be documented.

  • Disclosure of the recorded images to third parties will only normally be made to:

  • Law enforcement agencies where the images recorded would assist in a specific criminal enquiry

  • Prosecution agencies

  • Relevant legal representatives

  • The media, at the request of law enforcement agencies and where it is decided that the public’s assistance is needed in order to assist in the identification of victim, witness or perpetrator in relation to a criminal incident. As part of that decision, the wishes of the victim of an incident will be taken into account.

  • People whose images have been recorded and retained (the "data subject") (unless disclosure to the individual would prejudice criminal enquiries or criminal proceedings).

  • All requests for access or for disclosures will be recorded. If access or disclosure is denied the reason will be documented. If access to, or disclosure of, the images is allowed, the following will be documented:

    • The date and time at which access was allowed or the date on which disclosure was made

    • The identification of any third party who was allowed access to or to whom disclosure was made

    • The reason for allowing access or disclosure

    • The extent of the information to which access was allowed or which was disclosed.

Recorded images will not be made more widely available, for instance by being made routinely available to the media or placed on the internet.

Access by data subjects

Staff involved in operating the equipment must be able to recognise a request for access to recorded images by data subjects (a "Subject Access Request") and operate the following procedure:

  • Any individual requesting access must complete a "CCTV Record Request Form" (available from the Porters’ Lodge).

  • All Subject Access Requests will be dealt with by the Bursar, or in his/her absence, the Head Porter, or Deputy Head Porter (the "responsible person").

  • A copy of the "CCTV Record Request Form" will be given to the Bursar’s Office for their records and to check that the request is, or is not, part of an ordinary Data Protection Subject Access Request.

  • A fee of £10 will be charged and the search for the images requested will not be carried out until the fee has been received.

  • One of these responsible people, with the assistance as necessary of a Computer Officer, will locate the images requested.

  • The responsible person will determine whether disclosure to the individual will entail disclosing images of third parties.

  • The responsible person will determine whether images of third parties are held under a duty of confidence.

  • The responsible person must provide a written response to the individual within 21 days of receiving the request setting out their decision on the request.

The Bursar will undertake a yearly review of the documented system in order to ensure that the provisions of the Code of Practice are being complied with. This will normally take place in mid-May. A report will be made annually to the College Council, including sections on the location and maintenance of the cameras, on the number and nature of enquiries and complaints received. The results will be assessed annually by the College Council against the stated purpose of the scheme.

Complaints procedure

Any individual(s) having concerns about either the use of the CCTV system or non-compliance with the provisions of the Information Commissioner’s Code of Practice are requested to:

  • Write to ask for a copy of the CCTV Record Request Form, the Murray Edwards College Code of Practice and the Information Commissioner’s Code of Practice. The request should be addressed to the Bursar, Murray Edwards College, Cambridge, CB3 0DF.

  • Return the CCTV Record Request Form, together with a letter setting out any complaint, to the Bursar, Murray Edwards College, Cambridge, CB3 0DF.