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CCTV SYSTEM POLICY

INTRODUCTION (1)
1.1 The purpose of this Policy is to regulate the management, operation and use of the closed circuit television (CCTV) system at Richmond 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 within the School and by the School’s preferred monitoring company.

1.3 This Code follows Data Protection Act guidelines.

1.4 The Code of Practice will be subject to review periodically, but at least biennially, to include consultation as appropriate with interested parties.

1.5 The CCTV system is owned by the school.

OBJECTIVES OF THE CCTV SCHEME (2)
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 prosecuting offenders
(e) To protect members of the public and private property
(f) To assist in managing the school

STATEMENT OF INTENT (3)
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 is 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. 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.

OPERATION OF THE SYSTEM (4)
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 and the Finance and Site Manager during the day.

4.3 The CCTV system will be operated 24 hours each day, every day of the year.

CONTROL ROOM (5)
5.1 The Senior Maintenance Officer will check and confirm the efficiency of the system on a twice-weekly basis and in particular that the equipment is properly recording and that cameras are functional.

5.2 Access to the CCTV facilities will be strictly limited to the SMT, the Site and Finance Manager and the Senior Maintenance Officer.

5.3 Unless an immediate response to events is required, staff in the CCTV Control Room must not direct cameras at an individual or a specific group of individuals.

5.4 Control operators must satisfy themselves over the identity of any other visitors to the Control Room and the purpose of the visit. Where any doubt exists access will be refused.

5.5 The system may generate a certain amount of interest. It is vital that operations are managed with the minimum of disruption.

5.6 If out of hours emergency maintenance arises, the Control Room Operators must be satisfied of the identity and purpose of contractors before allowing entry.

5.7 Full details of visitors including time/data of entry and exit will be recorded.

5.8 When not manned the facility must be kept secured.

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.

LIAISON (6)
6.1 Liaison meetings may be held with all bodies involved in the support of the system.

MONITORING PROCEDURES (7)
7.1 Camera surveillance may be maintained at all times.

7.2.1 A monitor is installed in the Control facility to which pictures will be continuously recorded.

7.2.2 If covert surveillance is planned or has taken place copies of the Authorisation Forms, including any Review must be completed and retained.

VIDEO TAPE PROCEDURES (8)
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:

(i) Each tape must be identified by a unique mark.
(ii) Before using, each tape must be cleaned of any previous recording.
(iii) The controller shall register the date and time of tape insert, including tape reference.
(iv) A tape required for evidential purposes must be sealed, witnessed, signed by the controller, dated and stored in a separate, secure, evidence tape store. If a tape 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 tape store.
(v) If the tape is archived the reference must be noted.

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.

BREACHES OF THE CODE (including breaches of security) (9)
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.

ASSESSMENT OF THE SCHEME AND CODE OF PRACTICE (10)
10.1 Performance monitoring, including random operating checks, may be carried out by the Finance/Site Manager.

COMPLAINTS (11)
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.

ACCESS BY THE DATA SUBJECT (12)
12.1 The Data Protection Act provides Data Subjects (individuals to whom "personal data" relates) 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.

PUBLIC INFORMATION (13)
Copies of this Code of Practice will be available to the public from the School Office and the Headteacher.

Summary of Key Points

• This Code of Practice will be reviewed every two years.
• The CCTV system is owned and operated by the school.
• The Control system is not open to visitors except by prior arrangement and good reason.
• Liaison meetings may be held with the Police and other bodies.
• Any recording tapes will be used properly, indexed, stored and destroyed after appropriate use.
• Tapes may only be viewed by Authorised School Officers and the Police.
• Tapes required as evidence will be properly recorded witnessed and packaged before copies are released to the Police.
• Tapes will not be made available to the media for commercial or entertainment purposes.
• Tapes will be disposed of securely by incineration.
• Any breaches of this Code will be investigated by the Headteacher. An independent investigation will be carried out for serious breaches.
• Breaches of the Code and remedies will be reported to the Headteacher.

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