Adopted by Domestic, Estates and Events Committee: 2020
Review Date: 2023
Committee Ownership: Domestic, Estates and Events
The use of CCTV across the main College site is part of the College’s efforts to ensure the safety and security of its members and visitors, as well as safeguarding property. Although a relatively small site, the College receives a great many visitors and incidents do occur.
CCTV cameras, in conjunction with other security precautions, are installed at strategic points to assist in prevention and detection of crime. The legal basis for this processing is that it is necessary for the purposes of the College’s legitimate interests, where we have concluded that our interests do not impact inappropriately on the fundamental rights and freedoms of the College’s members and visitors.
Purposes of the CCTV system
The CCTV system has been installed by the College for the following purposes:
- To monitor the security of premises
- To help ensure the safety of College members and visitors
- To reduce the fear of crime and reassure members of the College and visitors
- To assist in the prevention and detection of crime
- To aid the identification, apprehension and prosecution of offenders (including the potential use of images in criminal proceedings)
Responsibility for the CCTV system
The College Officer with overall responsibility for the CCTV system is the Bursar, as Data Protection Officer. The system is managed on a day-to-day basis by the Head Porter and the Deputy Bursar.
The CCTV system
The system covers the main College site and the exterior of Buckingham House. It is operated 24 hours a day throughout the year. All cameras are fixed position and although some may have an audio recording function this will always be disabled. The system does not support a facial recognition facility, but meets the D1 resolution standard (720 X 480 pixels). College members and visitors are made aware of the CCTV system by appropriate signage at the entrances to the College site and at its other properties.
In normal circumstances, College CCTV will not be used for intrusive or directed surveillance. Areas such as toilets and sleeping accommodation will not be monitored.
Public bodies such as the police are governed by strict rules within the Regulation of Investigatory Procedures Act 2000 (RIPA) about how and when cameras can be directed to view a location where an individual’s specific activity can be monitored. Whilst the College is not bound by RIPA it will adopt the principles:
- It will not be used speculatively. There must be a sound intelligence case that an individual(s) is committing a crime or a serious breach of College rules. In deciding what amounts to a serious breach, consideration will be taken of the risks to individual(s), College property and College reputation. Consideration will be given to minimising collateral intrusion to those quite properly going about their normal daily business and whose image is captured by a directed camera.
- Once the purpose for use of a camera has finished, the camera will be removed or re-positioned back into general use.
Decisions on the use of directed surveillance will be made by the Head Porter and the Deputy Bursar in conjunction with the Bursar (where staff involvement is suspected), Senior Tutor (for students) or President (for Fellows). They must satisfy themselves that a sound intelligence case exists and that the use of the directed surveillance is proportional to the incident and likely outcome. A record of the rationale will be created for each use of directed surveillance. It will be retained by the Head Porter (see appendix C).
Decisions relating to installing additional cameras onto the general system, e.g. to fill in a gap in coverage or to install cameras at a newly purchased property, will be made by the Head Porter and the Deputy Bursar with the Bursar and the support of the IT Manager. Additional input may come from other members of the College if they have suggested that a need for a camera has arisen. A record of the decision will be created. It will be retained by the Head Porter (see CCTV form 5).
Recordings, storage and access
Live images from all cameras can be viewed by the Porters in the Porters’ Lodge. Recorded images are stored on six recorders. Images are retained for 30 days and then overwritten.
Access to recorded images is limited to the Head and Deputy Head Porter, the Deputy Bursar and the contracted supplier. CCTV images may be personal data and therefore fall within the scope of the Data Protection Act (2018). All processing of personal data will be done in accordance with the College’s Data Protection Policy.
At the end of their useful life all images on discs will be erased and securely disposed of as confidential waste. All images will be deleted from College servers and all still photographs and hard copy prints will be securely disposed of in confidential waste.
Requests to access recorded CCTV images should be addressed to the Head Porter or the Deputy Bursar. In the event they are unavailable, requests should be made to the Bursar. It is expected that most requests to view or receive copies of images will come from the police. This will usually be arranged in advance and the Head Porter will be in attendance. A log of the viewing must be made (see Appendix A). Requests for copies of images by the police will be treated in accordance with the procedure in Appendix A. Applications received from outside bodies (e.g. solicitors) to view or release images will only be accepted when satisfactory documentary evidence is provided showing they are required for legal proceedings or in response to a court order (see Appendix A). Images required for these purposes will be kept for no longer than 6 months after the completion of the prosecution.
Requests for access to the CCTV images may also come from data subjects, i.e. those featuring in the CCTV images. Any such requests should be directed to firstname.lastname@example.org to request a copy of the Subject Access Request: CCTV record request form (see Appendix B).
The location of cameras and accuracy of the date and time recorded will be checked on a yearly basis by the Head Porter in conjunction with our contracted supplier. A maintenance log will be kept in the Porters’ Lodge CCTV file. Damage and faults are to be reported to the Head or Deputy Head Porter in the first instance.
Complaints and contacts
Any individual having concerns about the CCTV system are requested to contact the Bursar in the first instance.
Appendix A: Procedures for viewing or releasing images at the request of the police, for legal proceedings or a court order
Requests should be made in advance to the Head Porter or Deputy Bursar, ideally in writing (email is sufficient) providing as much detail as possible about the images you wish to view (CCTV Form 1) or receive copies of (CCTV Form 2). A date, time window and location would be the absolute minimum of information to be provided. The Head Porter will then ascertain if the footage exists. If it does, an appointment can then be made to view the images. The Head Porter should consider whether the images are close to their over-writing date and if so, should make provision for the images to be transferred to an alternative medium to ensure their preservation.
Prior to the images being viewed, CCTV Form 1 needs to be completed and photographic ID of the viewer (Police Warrant Card, Picture ID Card or Driving Licence etc.), must be shown. If the images are needed by the police, form part of legal proceedings or are required by a Court Order, CCTV Form 2 needs to be completed also. Copies of the images will then be removed from the recorders for transfer. Two copies will be created, one for the party making the request and one for the College to retain. Images removed will be saved to discs that can only be written once. Each copy will be labelled with the date of the images, the date the images were supplied and College contact details. Copy images will only be handed over when CCTV Form 2 has been completed and upon production of a positive ID such as a Police Warrant Card, Picture ID Card or Driving Licence etc. The College’s copy of images supplied will be stored on a shared drive with access only permitted for the Head Porter and the Deputy Bursar. On occasion, it may be necessary to store a physical copy (i.e. on CD) in the Head Porter’s office. This will always be held in the Porters' safe.
Appendix B: Procedures for releasing images requested via a Subject Access Request
The Data Protection Act 2018 allows for those featuring in CCTV to request copies of footage in which they feature. In order to request such footage CCTV Form 3 must be completed and returned to email@example.com. It will be ensured that identification has been checked, any necessary payment has been made and the Head or Deputy Head Porter or IT department will be contacted to seek a copy of the images. Two copies will be created, one for the party making the request and one for the College to retain. Images removed from the recorders will be saved to discs that can only be written once. Each copy will be labelled with the date of the images, the date the images were supplied and College contact details.
Appendix C: Deploying directed or covert cameras
Deploying directed or covert cameras should only be done in exceptional circumstances and may only take place after the situation has been assessed by the Head or Deputy Head Porter in conjunction with the Bursar (where staff involvement is suspected), Senior Tutor (for students) or President (for Fellows). For each incidence of deployment, CCTV Form 4 should be completed.
CCTV Form 1: Request to view CCTV images by the Police, or as part of legal proceedings or as required by a Court Order
CCTV Form 2: Request for copies of CCTV images by the Police, or as part of legal proceedings or as required by a Court Order
CCTV Form 3: Subject Access Request Form - CCTV
CCTV Form 4: Authorisation to deploy directed or covert camera(s)
CCTV Form 5: Authorisation for additional camera(s) to be added to the general CCTV system