Procedures - CCTV

1. Positioning

Locations have been selected, both inside and out, that the School reasonably believes require monitoring to address the stated objectives in section 4 of the CCTV Policy.
Adequate signage has/will be placed in prominent positions to inform staff and students that they are entering a monitored area.
No images will be captured from areas in which individuals would have a heightened expectation of privacy, Including changing and washroom facilities.
No images of external public spaces will be captured except to a limited extent at site entrances.

2. Maintenance

The CCTV System will be operational 24 hours a day, every day of the year.
The Security and Safety Manager (defined below) will check and confirm that the System is properly recording and that cameras are functioning correctly, on a regular basis.
The System will be checked and (to the extent necessary) serviced no less than annually.

3. Access to the System & Images

Images will be viewed and/or monitored in a suitably secure and private area to minimise the likelihood of or opportunity for access by unauthorised persons.
Access will be granted to key school leaders whose sole purpose of quickly reviewing CCTV to locate missing students, or if a safeguarding incident occurs.
School leaders must only view CCTV footage in private to prevent non authorized viewing.
General viewing is not permitted.
Access to stored CCTV images will only be given to authorised persons, under the supervision of the Security and Safety Manager or a member of SLT, in pursuance of the above objectives (or if there is some other overriding and lawful reason to grant such access).
CCTV footage is classified as confidential and is considered part of the school’s internal security measures. For this reason, parents and guardians are not permitted direct access to CCTV recordings. These recordings often capture multiple students and staff members, and sharing such footage would compromise the privacy and data protection rights of others.
Individuals also have the right to access personal data the School holds on them (please see the Data Protection Policy), including information held on the System, if it has been kept. The School will require specific details including time, date and camera location before it can properly respond to any such requests. This right is subject to certain exemptions from access, including in some circumstances where others are identifiable.
The Director of Operations must satisfy themselves of the identity of any person wishing to view stored images or access the system and the legitimacy of the request. The following are examples of when the Director of Operations may authorise access to CCTV images:

Where required to do so by the Director of Operations, the Police or some relevant statutory authority;

Following suspected criminal behaviour;
To enable the Designated Safeguarding Lead to examine behavior which may give rise to any reasonable safeguarding concern;
To assist the School in establishing facts in cases of unacceptable pupil behavior, in which case, the parents/guardian may be informed (depending on severity) as part of the School’s management of a particular incident;
To the School’s insurance company where required in order to pursue a claim for damage done to insured property; or
In any other circumstances required under law or regulation.
When images are disclosed, a record will be made in the system register including the person viewing the images, the time of access, the reason for viewing the images, the details of images viewed.

4. Storage of Data

The day-to-day management of images will be the responsibility of the Security and Safety Manager who will act as the Security and Safety Manager, or such a suitable person as the Security and Safety Manager shall appoint in his or her absence – usually a security supervisor.
Images will be stored for 30 Days and automatically deleted unless the School considers it reasonably necessary for the pursuit of the objectives outlined above, or if lawfully required by an appropriate third party such as the police or border agency.
Where such data is retained, it will be retained in accordance with the schools Data Protection Policy. Information including the date, time and length of the recording, as well as the locations covered and groups or individuals recorded, will be recorded in the CCTV Register.

5. Other CCTV systems

The School does not own or manage third party CCTV systems, but may be provided by third parties with images of incidents where this is in line with the objectives of the School’s own CCTV policy.
Students travel to School on minivans provided by third party contractors and a number of these vans are equipped with CCTV systems. The School may use these in establishing facts in
cases of unacceptable student behavior, in which case the parents/guardian may be informed (depending on severity) as part of the School’s management of a particular incident.

6. Data Export

Data is exported to the Police when they “compel” the School to do so as part of a Police investigation, and they provide a receipt note which makes clear their responsibility for handling the data in accordance with the Data Protection Law.
Data exported internally to the School will be accompanied by a statement, either e-mail or in writing, that the recipient is responsible for managing the data in accordance with the Data Protection Law.
CCTV images from the Verkada system will be shared by a secure link for a set period of time.
CCTV images from HIKVision will need to be viewed in the CCTV control room.

7. Use of Microphones

While cameras do have microphones located within the camera as standard, the microphone is always in the ‘off’ mode and does not record conversations.
The school, under no circumstances, will turn on a microphone on a camera.
Turning on a microphone, without informing staff, and without proper signage being displayed would be in breach of PDPA.
Examples where organizations use microphones in CCTV include reception desks, security counters, postal collection points, customer service desks, in order to support investigations, discourage inappropriate behavior.

8. Complaints and Queries

Any complaints or queries in relation to the School’s CCTV system, or its use of CCTV, or requests for copies, should be referred to the Director of Operations

9. CCTV Footage Access Request

Information is required before the school can review CCTV footage. The request must be completed on KISSFLOW prior to the footage being checked.
Where the checking of footage is crucial for the health, safety and wellbeing of an individual, the form can be completed retrospectively.
Please note that CCTV footage may contain the information of others that needs to be protected, and that the school typically deletes CCTV recordings after 30 days.

10. Subject Access Requests (SARS)

Individuals may make a request for the disclosure of their personal data and this may include CCTV images. This is called a subject access request. Information about how to exercise this, and other rights, can be found in the personal data protection policy.
To enable the school to locate relevant footage, any requests for recorded CCTV must include the data and time of recording, the location of where the footage was captured and, if necessary, information identifying the individual concerned.
The school will, as part of PDPA, obscure the images of third parties when disclosing CCTV images as part of a subject access request, in all cases where the school considers it necessary to do so.
The school can decline requests on the basis of:
- The footage identifies other people whose privacy may be affected.
- Disclosure would harm the rights or freedoms of others.
- It’s not technically possible to isolate their image.
- It relates to legal proceedings or internal investigations.

11. Audit

The Chair of the Board of Governors may request to view CCTV logs to ensure compliance to the Policies of CCTV and its use of facial recognition and microphones.