WILLIAMSON HALL ABERNETHY – CCTV POLICY
Williamson Hall is owned by the Williamson Trust, and operated by a voluntary Hall Management Committee (Williamson Hall Management Committee – WHMC). It is a registered charity, number SC003200. Closed circuit television (“CCTV”) is installed at Williamson Hall. Cameras are located at various places on the premises and images from the cameras are recorded digitally and then automatically recorded over after approximately three months. This document details the policy and procedures used to control the management, operation, use and confidentiality of the CCTV system.
Purpose & Objectives
1 The purposes and objectives of the CCTV system are:
- to maintain the security of the premises
- to deter, detect and prevent crime, vandalism and anti-social behaviour
- to provide a safe and secure environment for volunteers, staff, hirers, visitors and contractors
- to assist Law Enforcement Agencies to carry out their lawful duties.
2 This use of CCTV falls within the scope of The Data Protection Act 2018 and UK General Data Protection Regulations 2018. WHMC complies with the Information Commissioner’s Office (“ICO”) Code of Practice for CCTV to ensure that it is used responsibly.
CCTV warning signs are clearly and prominently displayed at Williamson Hall’s Main Entrance Door, and at the sides of the property wherever a camera is situated. On the external Hall noticeboard is a CCTV notice, and within the Hall on the lobby noticeboard is a CCTV notice and a copy of this policy and details of the “Data Controller” who has responsibility for the system.
Siting the Cameras and Coverage
The planning and design has endeavoured to ensure that the CCTV system gives 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.
The CCTV system in use at the Hall is external only and does not record audio.
Cameras have been sited carefully so that they only capture images relevant to the purposes for which they are installed (described in “Purpose” above) and care has been taken to ensure that reasonable privacy expectations are not violated. Every effort has been made by WHMC to position cameras so that their coverage is restricted to the WHMC premises which may include public areas. Where possible and necessary digital screening has been added to the system to obscure neighbouring properties.
The cameras are sited on (a) the south elevation of the hall covering the oil tank, the back door and the entrance to the access track from the south, (b) above the Main Entrance Door, (c) the north east corner of the hall overlooking the old entrance door and the parking area (d) the north east corner of the hall overlooking the entrance to the access track from the north
Storage and Retention of CCTV images
Recorded data is stored automatically for approximately three months on a recorder which is secured within Williamson Hall and to which only the members of the Management Committee have access via a protected password. Recorded data will be stored in a way that ensures the security and integrity of the image and allows specific times and dates to be identified.
Normally, recorded data will not be retained for longer than the approximately three months. This longer retention period allows for late identification of damage or vandalism, as the hall is on occasion not in regular use and a period of time may elapse before damage is identified, and does not therefore constitute over retention.
On occasion, images may need to be retained longer where, for example, an incident has been identified or a Subject Access Request has been made or time is required to enable the Law Enforcement Agencies to collect relevant images or the Law Enforcement Agencies are investigating a crime and ask for images to be preserved to afford them the opportunity to view the information as part of an active crime investigation. All retained images will be stored securely.
Access to CCTV Images and Disclosure
Access to recorded images is restricted to members of the Hall Management Committee, and specifically to the Hall Treasurer who acts as the defacto Data Controller. Disclosure of information will be controlled and consistent with the purpose(s) for which the CCTV system has been established. Once information is disclosed to a Law Enforcement Agency, they will become data controller for the copy which they hold.
The following guidelines will be adhered to in relation to the disclosure of images:
a) The disclosure of images will be in line with the above Objectives and will be controlled under the supervision of the Data Controller or his/her nominated deputy;
b) A log will be maintained itemising the date, time(s), camera, person copying, person receiving and reason for the disclosure;
c) The appropriate disclosure documentation from the Law Enforcement Agencies will be filed for future reference;
d) Images must not be forwarded to the media for entertainment purposes or be placed on the internet other than for identification purposes re those responsible for theft from, damage or vandalism to the Hall.
e) Images must not be copied in any way, eg. photographed, downloaded or printed for use other than described in the objectives;
f) Images will only be released to the media for identification purposes in liaison with the Law Enforcement Agencies;
g) The method of disclosing images should be secure to ensure that they are only seen by the intended recipient; and
h) Images of third parties not relevant to the investigation should be obscured where possible to prevent unnecessary identification.
Subject Access Requests
Individuals have the right to request access to CCTV footage relating to themselves under The General Data Protection Regulation.
All requests for access should be made by in writing to the Hall Management Committee, providing sufficient information to enable the footage relating to them to be identified, ie date, time and location. WHMC will respond to requests within 4 weeks of receiving the written request.
All requests for access are recorded. If disclosure is denied, the reason is documented and the individual will be informed within at least 4 weeks of the reason and their right to complain to a statutory authority. WHMC reserves the right to refuse access to CCTV footage where this would prejudice the legal rights of other individuals or jeopardise an ongoing investigation.
A fee of £10 may be charged for a Subject Access Request, depending on circumstances.
Enquiries or complaints about the operation of Williamson Hall’s CCTV system should be directed to the Hall Treasurer (acting as the Data Controller) in the first instance, and in writing to Glenbank, Glenfoot, Abernethy PH2 9LS.
This policy will be reviewed at least annually by the Williamson Hall Management Committee or when new legislation requires this policy to be updated. The CCTV Notice is displayed on the external noticeboard and on the noticeboard in the hall lobby to provide assurances on the proper use of CCTV to volunteers, hirers, visitors and contractors.