All About CCTV ( Circuit Closed Television ), Code of Practice for CCTV Systems
A Closed Circuit Television System (CCTV) has been installed within various sites owned by Liverpool John Moores University. The system is based around a series of networked digital video recorders (DVRs) which are securely located in key locations around the University. The recorders sit on a virtual LAN within the overall University computer network. The DVRs record locally on site but access to the recorded images is only available over the University network to authorised staff at the University Security control centre. In addition a limited number of management and site security staff may have the facility to monitor cameras sited within their own areas of responsibility. Monitoring of the CCTV systems is located at site or at the Security Control Room, The Lodge, Byrom Street, Liverpool L3 3AF.
1.2 The use of the system and the images recorded by it reflect the spirit and guidance issued by the Information Commissioner’s Office in the “CCTV Code Of Practice revised Edition 2008”
2.0 PURPOSE & USE OF THE SYSTEM
2.1 The purpose of the systems is to assist in providing a safe and secure environment for staff students and visitors within the boundaries of the University.
2.2 The objectives and benefits of the CCTV system are:
o To assist in the detection of crime
o To provide evidence of crime
o To deter those having criminal intent
o To give confidence to Staff, Students & Visitors that they are in a secure environment
o To assist in the overall management of Liverpool John Moores University properties
o To provide information relating to vehicle traffic management
o To assist with issues that impede or disrupt the orderly operation of the University
o To provide the Police, the University, the Customs and Excise and the Health and Safety Executive with evidence upon which to take criminal and civil actions in the Courts.
2.3 The impact of the system will be assessed on an annual basis by the University Security Manager. The frequency of assessment may be increased in direct response to operational circumstance and local concerns.
3.0 ADMINISTRATION
3.1 The CCTV system is operated by the LJMU Security Services Department whose personnel are employed directly by the University. The CCTV system, all recorded material and copyright is owned by Liverpool John Moores University.
Liverpool John Moores University is the “owner” of the system.
3.2 The, University Security Manager, will be the single point of reference on behalf of the University. This role will include a responsibility to:
a) Ensure that all equipment specified as part of the CCTV system is capable of capturing usable images in line with the objectives of the system.
b) Ensure that all equipment associated with the University CCTV system is effectively and regularly maintained in accordance with contractual arrangements which the owners may from time to time enter into.
c) Maintain day to day management of staff associated with the system.
d) In partnership with the University Security Administrator, agree to any proposed alterations and additions to the system, this Code of Practice and / or the procedural manual.
3.3 The University Security Administrator, is responsible for the day to day administration of the system. The role will include a responsibility to:
a) Maintain day to day management of the system and equipment. Ensuring that all images whether displayed or recorded are of useable quality in line with the objectives of the system and that all images are accurately time and date stamped.
b) Carry out regular audits of the system to ensure that this Code of Practice is complied with.
c) Maintain direct liaison with the Security manager over all maintenance issues affecting the system and ensure that all maintenance procedures are properly recorded within the system logs.
3.4 The CCTV equipment and the images obtained from it will be used and operated
strictly in accordance with the purpose and objectives of the system.
4.0 OPERATIONAL PROCEDURES
4.1 System details
The details of the system located on each site will be maintained in the building CCTV register.
The systems, depending on site, will comprise a selection of equipment listed below:
o Fixed position cameras
o Full feature Pan Tilt & Zoom Cameras
o Covert Cameras
o Monitors
o Digital CCTV Recorders
o Public Information Signs ‘CCTV Recording Operational in this area’
The system is operational and images will be monitored and recorded for 24 hours per day throughout the year. The systems will be used in connection with the code of practice to ensure a person’s right to privacy and to ensure it is only used for the objective it was established.
4.2 Covert Recording
The University will only undertake covert recording where:
o Informing the individual(s) concerned that the recording is taking place would seriously prejudice the reason for making the recording;
o There is good cause to suspect that an illegal or unauthorised action(s) is/are taking place or about to take place.
Any such monitoring will only be carried out for a limited and reasonable amount of time consistent with the objectives of the monitoring, and only for a specific unauthorised activity.
All such occasions will be fully documented showing who made the decision to use
covert monitoring and why.
4.3 Signage
Signs will placed at the main entrance points to all University premises indicating that CCTV surveillance is in operation. The signs will also display details of ownership and a contact number for enquiries.
4.4 Camera Locations
Where practical all cameras will be sited so as to only view property, land and access routes directly associated with the University. Where camera positions encroach on adjacent residential property, the privacy of residents will be protected by use of privacy zones within the system programming.
5.0 RECORDED MATERIAL AND USE OF IMAGES
5.1 Images are recorded on Digital Video Recorders which are securely located in various locations across the University. Access to the recorded and live images is restricted to authorised users by user names and passwords.
5.2 There are 4 access levels:
Level 1: Manager Access, full access to all system functions including system configuration, recorded images, live images and image download. This level is restricted to the University Security Manager and the University Security Administrator these are the only people authorised to download recorded images and produce copies of recorded material
Level 2: Control Room Access, access to live and recorded images on an individual basis. Restricted to supervisors and Control room operators.
Level 3: Security Access, access to live images for general observation and camera patrols on all systems.
Level 4: User Access, access to live images on specific cameras as required by the designated role of the individual.
5.3 All recorded CCTV footage will be retained on the system for a period of between 14 and 28 days dependent on the relevant equipment. Systems will be programmed to overwrite all recorded footage after this period. In order to respond to operational needs the overwrite period may be reduced to enhance record rate. This will be agreed between the University security Manager and the System Administrator.
5.4 Where a recorded incident requires further investigation either by the Security Service or by a Statutory Authority with prosecuting powers, that image will be retained for a period relevant to the length of the investigation.
5.5 Recording media no longer in use will be securely destroyed prior to disposal.
6.0 DATA PROTECTION ACT 1998
The principles of the Data Protection Act 1998 will be adhered to and any future changes of legislation will be taken into account.
The University will:
Obtain and process personal data fairly and lawfully
Obtain, hold and use data only for the purposes specified
Use the data only for the purpose, and disclose only to the people, shown within these policies and procedure
Only hold data which is adequate, relevant and not excessive in relation to the purpose for which the data is held
Ensure personal data is accurate and, where necessary, kept up to date
Hold data for no longer than is necessary
Personal data will be processed in accordance with the rights of data subjects under the Data Protection Act 1998
Take security measures to prevent unauthorised or accidental access to, alteration, disclosure, or loss and destruction of information
Personal data will not be transferred outside the University without ensuring there is an adequate level of protection in relation to the processing of personal data
7.0 FREEDOM OF INFORMATION
The Freedom of Information Act 2000 and the Data Protection Act 1998 will be adhered to. Any request for disclosure of information must be formally submitted to the University’s Data Protection Officer. Requests for information by the Police and other authorities must be accompanied by the relevant Data Protection form duly signed by the appropriate authority.
Access to the monitoring and recording facility will be prohibited except for lawful, proper and sufficient reasons (e.g. official visits from law enforcement or inspection agencies, security staff and senior management) and only then with the personal authority (verbal or written) of the Security Services Manager or Security Administrator.
Any other personnel admitted to the control room, such as cleaning staff or engineers effecting repairs must be authorised by the Security Services Manager or Security Administrator (verbally or written) and must be supervised at all times whilst they are in the control room.
8.0 RIGHT OF SUBJECT ACCESS
Members of staff, students and visitors have a right to request that they see
images of themselves that have been captured by the CCTV system, subject to the payment of the relevant fee (currently £10). Any such request MUST be made in writing to the University’s Data Protection officer who will deal with the matter promptly and in any case within 40 days. Before responding to the request advice will be sought from the University Security Manager as to whether and to what extent information will be disclosed. Personal data may be withheld from a person making a subject access request where it has been adjudged that to disclose such would prejudice the detection of crime or the apprehension and prosecution of offenders or breach the data subjects rights of third parties.
8.1 Any individual seeking to prevent the University from processing their personnel data on the CCTV system must make a formal request in writing to the University Data Protection Officer.
9.0 BREACHES OF THE CODE and COMPLAINTS
9.1 A copy of this code of practice will be made available to anyone requesting it and is also available on the University website. Any complaint in relation to use of the system will be investigated by the University Security Manager in line with established University grievance procedures.
9.2 Complaints in relation to the disclosure of images should be addressed to the University Data Protection Officer
9.3 Serious breaches of this code may result in criminal liability on behalf of the individual and may also be considered as gross misconduct. Where appropriate, the police will be asked to investigate any matter relating to the CCTV system which is deemed to be of a criminal nature
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