CODE OF PRACTICE FOR CCTV SYSTEMS AT EAST COAST CONTROLS PROPERTIES
​1.0 INTRODUCTION
1.1 CCTV Systems installed at East Coast Controls Properties are intended:
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to provide a safer environment for building users, visitors and the general public
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for the prevention and detection of crime
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for the detection or prosecution of offenders
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to lessen the economic costs associated with vandalism to the properties
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for the detection and prevention of anti-social behaviour
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to monitor the integrity of East Coast Controls premises and assets
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to assist with health and safety
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to assist in the event of a civil emergency or disaster
The systems are primarily for community safety and crime prevention / detection and not for staff monitoring.
1.2 This Code of Practice is designed to:
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ensure that the CCTV Systems achieve their purpose with fairness and sensitivity.
1.3The Code of Practice is not applicable to:
any mobile cameras, cameras used covertly or cameras fixed to vehicles.
1.4 The owner of the systems is:
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East Coast Controls, Acre House, Stirling Road, Kilsyth G65 0PT
1.5 The areas covered and the equipment specification is:
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as detailed in the Operating and Maintenance Manuals supplied with the systems.
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6 Copyright:
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East Coast Controls retains the copyright to all recorded images and any still photographs produced from monitors operated by tapes or recorded by this scheme.
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No image obtained from monitoring or recording activity can be reproduced by any organisation or by any individual without the express permission of the System Manager.
1.7 The System Manager is:
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Property Services Manager, Acre House, Stirling Road, Kilsyth G65 0PT
1.8 The Local System Supervisors are:
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as designated by the System Manager in consultation with the Head of the Service occupying the building in which the CCTV system is installed.
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the persons authorised to manage the systems, including supervision of access and operation of the system by the System Operators.
1.9 The System Operators are:
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as designated by the System Manager in consultation with the Head of the Service occupying the building in which the CCTV system is installed.
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the persons authorised to operate the systems.
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2.0 DATA PROTECTION IMPLICATIONS
2.1 The East Coast Controls CCTV Systems are registered with the Information Commissioner for the purposes included in this Code of Practice.
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3.0 CHANGES TO THE CODE
3.1 Changes to the Code can only be made at senior level by the System Manager.
4.0 MANAGEMENT OF THE SYSTEM
4.1 Overall responsibility for the CCTV schemes lies with the System Manager:
4.2 The System Manager will arrange the following:
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devise detailed operational guidelines and review operational arrangements and revise the Code of Practice where appropriate.
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discuss any complaints from the public about operation of the system and take appropriate action.
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designate persons to review recorded images.
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designate and train persons to securely remove or download digital recordings to ensure chain of evidence remains intact
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when required - arrange contractual relationship with appointed maintenance contractor to securely download digital recordings and ensure evidence remains intact
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ensure that privacy is respected, and
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ensure that the requirements of the Data Protection Legislation (namely, the General Data Protection Regulation and the Data Protection Act 2018 are met.
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ensure that regular maintenance of systems is carried out.
4.3 The Local System Supervisor will arrange the following:
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designate day to day responsibility to staff
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ensure that the requirements of the Data Protection Legislation are met.
5.0 PUBLIC INFORMATION
5.1 Camera Positioning:
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All cameras are placed in clear public view with appropriate notification signs advising of the existence of CCTV and the identity of the owner of the system.
5.2 A copy of this Code of Practice is available from:
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Property Services Manager, Acre House, Stirling Road, Kilsyth G65 0PT
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6.0 INDIVIDUALS RIGHTS
6.1 Individual privacy:
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Must be safeguarded and given due regard.
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Private and family life and the home must also be safeguarded.
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Cameras must not be used so as to look into private property.
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Private residences may come into view only as part of a wide angle or long shot or as the camera is panning past them.
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Tracking and monitoring of individuals must be justifiable and strictly related to the purposes of the system as defined above in paragraph 1.1.
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Must be considered in the operation of any system, in accordance with Article 8 (Respect for Private and Family Life) of the Human Rights Act 1998
6.2 Individuals request for viewing (Right of Subject Access): (Form IDRF1)
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Must be made in writing by the individual who requests the viewing and must be sent to the CCTV Systems Officer who will record and process all requests.
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Requests made on behalf of another individual should be accompanied by a mandate from the data subject specifying consent.
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All responses to Subject Access Requests will be provided within one month unless the criteria for extending the timescales are met.
7.0 ASSESSMENT OF THE SYSTEMS AND CODE OF PRACTICE
7.1 The systems shall be evaluated by the System Manager:
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To ensure that the purposes for which the system was established are being achieved.
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To ensure that the operation of all systems complies with the Code of Practice. This shall include carrying out a periodic audit of the system including examination of records, record histories and the content of recorded images
8.0 STAFF
8.1 Local System Supervisors and System Operators:
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shall be designated by the System Manager in consultation with others
(ref clause 1.8 and 1.9)
8.2 Staff training will be provided:
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by the System Manager in conjunction with relevant Heads of Service.
8.3 Staff will be required to:
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maintain high standards of probity and confidentiality.
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sign a declaration of confidentiality (Form CDF1) to ensure proper use of the equipment or recording. Any abuse or improper use may be the subject of disciplinary proceedings.
8.4 Services should maintain and manage a log of the individuals who have system access rights and those individuals who have received CCTV system training.
9.0COMPLAINTS
9.1 About the operation of the system from the public or others:
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will be referred to the System Manager who will assist the relevant Head of Service in the interpretation of this code. Any appropriate disciplinary action will be undertaken by the Head of Service of the member(s) of staff concerned.
9.2 A member of the public may also complain to the Information Commissioner. Further information is available on the website www.ico.org.uk.
10.0 CONTROLS AND OPERATION OF CAMERAS
10.1 Operating Controls:
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Only System Operators shall have access to operating controls.
10.2 Viewing:
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Cameras must not be used to look into private property or into sensitive areas in East Coast Controls properties, where people have right to personal privacy, eg changing areas, toilets etc.
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Where possible, software shall be pre-programmed to avoid residential property and sensitive areas
10.3 Checking:
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Spot checks, as authorised by the System Manager, will be carried out to ensure compliance with the previous clauses. Operators must be aware that recordings are subject to routine audit and they may be required to justify their interest in a member of the public or property.
11.0 ACCESS TO AND SECURITY / VALIDITY OF EQUIPMENT
11.1 Access to view monitors and/ or to operate equipment:
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shall be limited to the designated System Operators, the System Manager or his designated staff and the Police.
11.2 Monitors:
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should be placed so as to be visible only to the System Operator. Where this is not possible all reasonable steps should be taken to prevent images being viewed by
un-authorised individuals.
11.3 Public access to or demonstration of monitors:
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shall not be allowed, except where a demonstration is provided to an individual to reassure that a particular camera does not view into their private residence. The demonstration shall only be authorised by the System Manager.
11.4 Date and time recording equipment:
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shall be checked on a weekly basis by the System Operator and shall be recorded on the appropriate form. (WTD1)
12.0 IMAGE RECORDING PROCEDURES
12.1 Security:
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All recording equipment, discs and other images, and registers must be stored within a secure cabinet which shall be locked at all times when unattended.
12.2 Digital Images:
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Are automatically recorded on the hard drive of the recording equipment and are kept for a maximum of 31 days (dependent on the hard drive capacity) after which the images will be automatically overwritten.
12.3 Suspicious Incidents:
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Where Police have reasonable grounds for believing that a suspicious incident has been recorded, a Police Officer will arrange with the System Manager or the person(s) designated under 4.2 to view the recording and if necessary to authorise the removal of the digital image in the form of a download to CD-R media for evidential purposes. All removals will be logged in the Download Request Register (DRR) by the System Operator and the Police Officer.
12.4 Release of recordings for evidential purposes:
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Recordings will only be released to a Police Officer or as ordered through the normal judicial process. All downloads of digital recordings will be logged in the Download Request Register by the Operator and the Police Officer.
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Once the recordings have been removed by the Police Officer or other person as ordered by judicial process, that Police Officer or other person will assume full responsibility for their security and integrity as evidence to be produced in court.
12.5 Copies of Recordings
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No copies of recordings will be made without the express permission of the System Manager.
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Copies shall not be made other than for the prevention or detection of crime, for the presentation of evidence in court or for access by the defence in accordance with the Data Protection Legislation.
12.6 Physical security of recordings
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The secure cabinet must be kept locked when unattended.
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All recording equipment must be stored within the cabinet.
13.0 DEALING WITH INCIDENTS
13.1 Incidents which require Police investigation:
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Shall be referred to the local Police Station where designated Police Officers will maintain ongoing liaison with the System Operators.
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All such referrals shall be recorded by the System Operators.
14.0LIST OF FORMS
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Download Request Register (DRR)
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Weekly Equipment Date and Time Check Record (WTD1)
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CCTV Confidentiality Declaration Form (CDF1)
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Example of CCTV Signage
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Incident / Event Codes (IER1)
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Calls of Concern from Operators (CCO1)
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Image Download Request Form (IDRF1)
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The Data Protection Principles (DPAP1)
For further information contact: Property Services Manager, Acre House, Stirling Road, Kilsyth G65 0PT
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