CCTV Code of Practice

1. Introduction

This Code of Practice sets out the procedures for the use and management of Magdalene College’s closed circuit television (CCTV) systems and images. Responsibility for the Code of Practice lies with the Data Controller (the Assistant Bursar). Day to day management of the CCTV systems is the responsibility of the Head Porter and Deputy Head Porter, and through them the College Porters.

The purpose of the CCTV system within the College is to provide a safe and secure environment for members of the College, its employees and visitors, and to protect the College’s property.

2. Legislation

The use of CCTV systems is subject to UK data protection law, the Human Rights Act 1998, the Freedom of Information Act 2000 and the Regulation of Investigatory Powers Act 2000 (RIPA).

When clarification is required the Assistant Bursar should contact the College's Solicitors for advice and guidance. The College's Solicitors should be contacted in all cases when RIPA request is received.

3. Purpose

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

• To assist in the prevention or detection of crime.
• To assist in the identification and prosecution of offenders.
• To monitor the security of the College’s property and premises.
• To assist in the prevention, investigation and detection of disciplinary matters involving employees and students in accordance with college disciplinary procedures.

The system will not be used:

• To provide live streaming images for public access.
• To provide images for any marketing purpose.
• To monitor time worked or absences.

We respect and support the individual's entitlement to go about their lawful business and this is a primary consideration in the operation of the system. Although there is inevitably some loss of privacy when CCTV cameras are installed, cameras will not be used to monitor the progress of individuals in the ordinary course of lawful business in the area under surveillance. Individuals will only be continuously monitored if there are reasonable grounds to suspect an offence has been, or may be, about to be committed.

Breaches of this section of the Code of Practice by staff will be regarded as gross misconduct and will lead to disciplinary action, which may result in dismissal.

4. Positioning and use of cameras

Most cameras are sited so that they are clearly visible, and publicity is given to the system by clear signing. This ensures that both the maximum deterrent value is achieved and that the public and staff are clearly aware when they are in a monitored area.

The College will only undertake covert recording with the written authorisation of the Assistant Bursar where there is good cause to suspect that criminal activity or equivalent malpractice is taking, or is about to take, place and informing the individuals concerned that the recording is taking place would seriously prejudice its prevention or detection. Covert monitoring will only take place for a limited and reasonable amount of time consistent with the objective of assisting in the prevention and detection of particular suspected criminal activity or equivalent malpractice, and the information obtained will only be used for this purpose. Once the specific investigation has been
completed, covert monitoring will cease.

The system does not utilize non-functioning or “dummy” cameras. The system does not record sound.

5. Recording and retention of images

The College's CCTV systems record digitally; all cameras are recorded 24 hour a day. All images remain the property and copyright of Magdalene College.

Routine recordings are retained for a maximum of 31 days on the hard disc and then over-written. Except for evidential purposes images will not be copied in whole or in part.

External data storage devices, such as memory sticks, are used for copying footage for investigation and the provision of evidence only. A record is kept of all data storage devices on which data is saved (Annex A) and a signed certificate required for any issued to third parties (Annex B). The security of the data storage devices and maintenance of records is the responsibility of the Head Porter and these will be reviewed by the Assistant Bursar at the end of each academic year.

6. Access to images, and disclosure to third parties

Recording equipment is kept in secure accommodation: access to the equipment and images is restricted to the operators of the CCTV system and to those line managers who are authorised to view them in accordance with the purposes of the system. All staff required to operate CCTV equipment are to receive training in the use of the equipment and must conform to this Code of Practice at all times; they are required to sign a confidentiality statement (Annex C). Any other staff will only be allowed access to the equipment by the authorisation of the Assistant Bursar, and will also sign the confidentiality statement. Signed statements should be placed on the member of staff’s personnel file.

The provision of evidence or viewings will normally be requested either by the police or a College department conducting an investigation into criminal activities or disciplinary issues. The release of evidence or permission to view images may only be authorized by the Assistant Bursar or in their absence, the Head Porter, and only in accordance with the purposes described in this Code. Once authorised, arrangements will be made to enable the investigating officer to view the images and if necessary be issued with a copy of recorded material on an external data storage device. All requests for disclosure and access to images by third parties are logged in the CCTV Viewing record (Annex D), which is maintained by the Head Porter and will be reviewed by the Assistant
Bursar at the end of each academic year.

Recorded material may need to be submitted as evidence in criminal proceedings or at internal disciplinary hearings and therefore must be of good quality, and accurate in content. All material provided as evidence will be treated in accordance with clearly defined procedures either under the Police and Criminal Evidence Act (PACE) or this Code of Practice to ensure continuity of evidence and to ensure a clear audit trail.

Recorded material will not be sold or used for commercial purposes or the provision of entertainment. Images provided to the Police or other enforcement or investigatory agencies shall at no time be used for anything other than the purposes for which they were originally released.

7. Individuals’ access rights

Under the data protection legislation, individuals have the right on request to receive a copy of the personal data that the College holds about them, including CCTV images if they are recognisable from the image. Individuals wishing to access any CCTV images of themselves must make a written request to the Assistant Bursar using the Request for Access to Personal CCTV Images form (Annex E). The College will respond promptly and normally within one calendar month of receiving the request.

The Assistant Bursar, or in their absence the Head Porter, will first determine whether disclosure of images will reveal third party information as individuals have no right to access CCTV images relating to other people. In this case, the images of third parties may need to be obscured if it would otherwise involve an unfair intrusion into their privacy. If the College is unable to comply with a request because access could prejudice the prevention or detection of crime or the apprehension or prosecution of offenders, the individual making the request will be advised accordingly.

8. Breaches of the code of practice

Staff who are in breach of this Code of Practice will be dealt with according to the College's disciplinary procedures - a process which could ultimately result in their dismissal. The responsibility for guaranteeing the security of the system will rest with the Assistant Bursar. The Head Porter or their Deputy will, in the first instance, investigate all breaches or allegations of breaches of security and will report their findings to the Assistant Bursar.

Tampering with cameras, monitoring or recording equipment, images or recorded data by unauthorised staff will be regarded as gross misconduct and will lead to disciplinary action, which may result in dismissal or criminal prosecution.

9. Complaints
Complaints about the operation of the CCTV system should be addressed to the Assistant Bursar.