Suffolk Owl Sanctuary CCTV Policy

The policy should be reviewed carefully and amended to ensure that it reflects how the Charity operates CCTV.

Introduction

1.     This policy sets out how Suffolk Owl Sanctuary (the Charity) will manage the operation and use of CCTV. 

2.     The purposes of this policy are:

a.     to help the Charity to regulate and manage its use of CCTV;

b.     to help the Charity be transparent about how it uses CCTV;

c.     to help ensure that the use of CCTV remains a proportionate and justified response to the problems that it seeks to address; and

d.     to provide guidance for all staff on how to comply with data protection legislation in relation to the use of CCTV. 

3.     This policy is aimed at members of staff, whether paid or unpaid, whatever their position, role or responsibilities, which includes employees, trustees, contractors, agency staff, work experience / placement, students and volunteers.  It is available to residents' and / or their visitors on request.

The use of CCTV

1.     The Charity's CCTV system comprises a number of cameras located on the premises.

2.     The Charity uses CCTV for the following purposes:

a.     to safeguard the welfare of livestock, staff and visitors;

b.     to protect the Charity, livestock, staff and visitors from criminal activity such as theft and vandalism;

c.     to support the protection of property;

d.     to aid in the investigation of accidents and incidents and the monitoring of health and safety;

e.     to increase personal safety;

f.      to support the protection of property;

g.     to aid in the investigation of accidents and incidents and the monitoring of health and safety; and

h.     to support law enforcement agencies in the reduction, prevention and detection of crime and to assist in the identification, apprehension and potentially prosecution of offenders.  

3.     CCTV footage may contain the personal information of those individuals captured by the recording. 

Governance

1.     The General Manager / Operations Manager has overall responsibility for the management and operation of the CCTV and the implementation of this policy. 

2.     The General / Operations Manager will ensure that the CCTV system is operated according to this policy and that regular audits are carried out to ensure that the relevant procedures are complied with.

Minimising privacy risks

1.     The Charity has carried out a Data Protection Impact Assessment (DPIA) on the use of CCTV. The outcome of the assessment was that the use of CCTV is a necessary and proportionate measure to achieve the purposes listed above provided that certain measures are put in place to mitigate the risks. 

2.     The Charity appreciates that the use of CCTV impacts on individuals' privacy but considers this intrusion to be justified because less privacy intrusive methods would not be sufficient to meet the Charity's purposes for using CCTV. In coming to this conclusion, the Charity has had particular regard to the safeguarding and welfare duties it owes to both it’s Livestock and staff.

3.     The Charity reviews the Data Protection Impact Assessment on an annual basis to ensure that the use of CCTV continues to be justified and that the appropriate measures are in place to mitigate the data protection risks raised by its use. 

4.     The Charity will also review its use of CCTV should a concern be raised about its practices. 

The operation of CCTV

1.     The Charity has sited the cameras to view only areas which need to be monitored, for example, shop area, main access/exit points and covering the Livestock. They do not monitor neighbouring private residences on the holiday park.

2.     Where CCTV cameras are placed on the Charity premises, we will display signs to alert individuals that their image may be recorded. Such signs will identify the Charity as the organisation operating the system, identify the purpose for using the surveillance system and who to contact for further information, where these things are not obvious to those being monitored.

3.     CCTV is not used in areas where individuals will have a heightened expectation of privacy, for example, there are no cameras in private properties.

4.     The cameras have been positioned in a way to ensure their security and to protect them from vandalism.

5.     The Charity has ensured that the cameras can produce images of the necessary clarity and quality to meet the Charity purposes. 

6.     Images can easily be extracted from the system if required, for example, under a disclosure to law enforcement agencies and or under a subject access request

7.     The Charity is able to obscure parts of the images where required to protect the identity of individuals. 

8.     The CCTV does not capture sound recordings.

9.     The CCTV cameras that record the perimeter of the Charity site are in operation 24 hours a day every day of the year because this is necessary to meet the purposes for which they were installed for example, to monitor the livestock & to detect intruders.  Consider removing this paragraph if there is a risk that it could enable an intruder to work out how to gain entry without detection or pose another type of security risk.

10.  The Charity is solely responsible for the operation of all CCTV in accordance with this policy for the purposes identified above.

11.  We will never engage in covert monitoring or surveillance (that is, where individuals are unaware that the monitoring or surveillance is taking place) unless, in highly exceptional circumstances, there are reasonable grounds to suspect that criminal activity or equivalent serious malpractice is taking place and, after suitable consideration, we reasonably believe there is no less intrusive way to tackle the issue.

12.  In the unlikely event that covert monitoring is considered to be justified, the Charity will carry out a Data Protection Impact Assessment.

13.  The rights of individuals whose images may be captured will always be taken into account in reaching any such decision.

Maintenance of the CCTV equipment

1.     The General Manager will check on a weekly basis that the system is operating effectively and in particular that the equipment is recording properly and that cameras are functional.  Any software updates will be applied by the General Manager assisted by the CCTV Operative / installer where necessary.   

2.     The system will be regularly serviced and maintained to ensure that clear images are recorded.  If any defects are found these will be reported to the CCTV Operative / installer for rectification.

3.     The Charity will monitor the operation of the CCTV system by investigating any notifications or concerns regarding the functionality of the CCTV system.

Storage and security

1.     The CCTV footage will be stored securely and will only be accessed by designated members of staff, being The General Manager & Designated Staff.  Other staff may view the CCTV footage as and when required in exceptional circumstances with the permission of the Designated Staff.  Designated Staff will be given additional training on CCTV, as appropriate. 

2.     CCTV recordings, including any copies made, are encrypted. The Charity will also encrypt any copy before it is shared with a third party (such as a law enforcement agency) unless there is a good reason for not doing so. 

3.     The Designated Staff are trained in the Charity’s security procedures. The Designated Staff will ensure that camera footage is not accessed by any unauthorised person.

4.     The only locations where CCTV footage can be viewed are in a secure office, by the General Manager or by Designated Staff. 

5.     Only the General Manager / Operations Manager are authorised to make copies (electronic or paper) of the CCTV footage.

6.     The Operations Manager / General Manager must give permission for any external persons or agencies to view the CCTV footage and this will be done in accordance with section on disclosure below.

7.     Any personal data breach (for example, any unauthorised access to CCTV footage) must be reported immediately to the Operations / General manager in accordance with the Charity’s Information Security Policy.   

8.     All maintenance of ICT or CCTV equipment that could provide access to CCTV footage will only be carried out by the CCTV Operative.

9.     Staff should note that any misuse of the CCTV system might constitute a criminal offence, for example, accessing footage without authorisation from the Operations Manager / General Manager.

10.  Where footage is saved following an incident this will be done securely. 

Internal use of the CCTV

1.     If a member of staff considers that CCTV footage might be needed for an internal matter (e.g. a staff disciplinary issue) they should speak to the Operations Manager / General Manager in the first instance.

Retention

1.     Compliance with data protection law means that the Charity does not retain personal data for longer than is required for the purposes for which it was obtained.  Recorded images will normally be retained for 90 days from the date of recording in accordance with the Charity’s Information and Records Retention Policy

2.     However, the Charity has procedures in place to retain information for a longer period if this is required.  For example, where an incident caught by the CCTV footage is being investigated or where there has been a subject access request.

3.     The Charity may permanently delete images after a shorter period, for example where it can be determined more quickly that there has been no incident giving rise to the need to retain the recorded images.

4.     The Charity has procedures in place to ensure that information is disposed of securely.  This is the responsibility of the Operations Manager / General.