Introduction
This policy sets out the purpose, operation and management of the use of CCTV systems at 1st Stretford (Longford) Scout Group.
It explains the aims of the CCTV system, how it operates, the measures taken to protect the privacy of individuals, how recorded images are stored securely, and how subject access requests are handled.
This CCTV policy has been produced using guidance available from the Information Commissioner’s Office (ICO).
1st Stretford (Longford) Scout Group is the Data Controller for personal data processed through the CCTV system.
Purpose and aims of the CCTV system
The aims of the CCTV system are:
- To deter persons from committing crime and provide opportunities to detect criminal activity
- To provide evidence to support action where a crime has been committed
- To monitor the security of the Group’s premises and equipment
The lawful basis for processing personal data through the CCTV system is legitimate interests, namely the protection of people, property and the prevention and detection of crime.
Particular care is taken to ensure the CCTV system is used proportionately in an environment used by children and young people.
Overview of the system and location of cameras
The system installed is a Swann CCTV system, using a number of cameras located around the site and connected to a single digital video recorder (DVR), which provides all control features.
The CCTV system does not record audio.
Image recording is continuous and motion-activated.
Cameras are positioned to monitor key access points and areas of concern. The system can be remotely monitored.
Cameras are not positioned in areas where individuals would have a reasonable expectation of privacy, such as toilets or changing areas. There are no cameras located inside buildings; coverage is limited to external areas of the site.
Data storage, retention and security
The CCTV system is fitted with a 1TB hard disk drive and records on a rolling basis until storage is full, at which point the oldest footage is automatically overwritten. This is currently estimated to occur every 15–30 days.
Where footage is required for review, it may be securely saved to external media to prevent overwriting.
The DVR is stored in a locked cupboard within a locked room.
Access to the CCTV system and retained footage is restricted to authorised individuals only. Access requires a password, and the list of authorised users is held by the Group Scout Leader.
Access to retained information and subject access requests
CCTV footage will only be accessed where an incident has occurred, a concern has been raised that falls within the aims of this policy, or where a valid subject access request has been made.
Individuals have the right to request access to CCTV footage in which they may be identifiable. To help us locate relevant footage, requests should include sufficient detail such as the date, approximate time and location of the incident or visit.
Where necessary, we may ask the requester to provide proof of identity or additional information to confirm that they are the individual shown in the footage.
Requests will be handled in line with data protection legislation. Footage may be redacted or withheld where disclosure would impact the rights of others, relate to an ongoing investigation, or where identification of the requester is not reasonably possible.
CCTV footage will not be shared with third parties except where required or permitted by law, including sharing with law enforcement agencies or insurers in exceptional circumstances.
Signage and transparency
Clear signage is displayed to inform visitors that CCTV is in operation at the Group’s premises.
Due to conservation area restrictions, the placement of external signage is limited. Signage is therefore positioned at the main entrance to the site and is visible to visitors entering the premises.
Further information about the use of CCTV is available in the Group’s Data Privacy Notice and this CCTV Policy.
Policy review
This policy, and the ongoing need for CCTV, is reviewed periodically.
It is not anticipated that the need for a CCTV system will change, as the site includes periods where it is unoccupied and requires monitoring for security and safety purposes.
