Introduction
Santon Downham Village Hall. Closed circuit television (“CCTV”) is installed at Santon Downham Village 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 21 Days. 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 The General Data Protection Regulation 2018. Santon Downham Village Hall complies with the Information Commissioner’s Office (“ICO”) CCTV Code of Practice (https://ico.org.uk/media/1542/cctv-code-of-practice.pdf) to ensure that it is used responsibly.
Warning Signs
CCTV warning signs are clearly and prominently displayed Within the Windows, at the front of the Main Building by the Disabled parking, at the side of the Building by the other Entrance of the property.
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.
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 Santon Downham Parish Council to position cameras so that their coverage is restricted to the Building premises which may include public areas.
The cameras are sited at (a) Lobby(b) Outside the Main Entrance Door, (c) Corner off the building overlooking the car park (d) Corner of the Building overlooking the outside seating area for the Hall (e) Side of the building over looing the Tree Seating Area (f) The Rear of the building facing the Outside Storage (g) the Rear of the building facing the Oil Tanks (h) Behind the Bar covering the Bar area
Storage and Retention of CCTV images
Recorded data is stored automatically for up to 21 days on a recorder which is secured within Santon Downham Village Hall and to which only the Chairman and Secretary of the Village Hall sub-committee have access. 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 21 days. 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 Village Hall Sub-Committee, all of whom are deemed by The Charity Commission to be legal Trustees of Santon Downham Village Hall, and to the Chairman and Secretary. 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 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;
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 e-mail or in writing to the Santon Downham Village Hall secretary providing sufficient information to enable the footage relating to them to be identified, ie date, time and location. Santon Downham Village Hall 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. Santon Downham Village Hall 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.
Complaints
Enquiries or complaints about the operation of Santon Downham Village Hall’s CCTV system should be directed to the Santon Downham Village Hall secretary in the first instance at secretary@villagehallsantondownham.co.uk or to Call 07958905199
Review
This policy will be reviewed at least annually by the Santon Downham Village Hall Sub-Committee or when new legislation requires this policy to be updated. The CCTV Notice appended to this policy forms a checklist for the Santon Downham Village Hall Sub-Committee to use and is displayed on the noticeboard in the Santon Downham Village Hall lobby to provide assurances on the proper use of CCTV to volunteers, staff, hirers, visitors and contractors.
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SANTON DOWNHAM VILLAGE HALL
CCTV NOTICE
The CCTV system installed at Santon Downham Village Hall and the images produced by it are controlled by the Santon Downham Village Hall Sub-Committee which is responsible for how the system is used. Day-to-day operational responsibility lies with the Santon Downham Village Hall Secretary who reports directly to the Santon Downham Village Hall Sub-Committee
The Santon Downham Village Hall Sub-Committee has considered the need for using CCTV and has decided that it is required for the prevention and detection of crime and for protecting the safety and security of Santon Downham Village Hall volunteers, staff, hirers, visitors and contractors. It will not be used for other purposes and an annual review of the use of CCTV will be conducted.
Date of Review: 13th February 2025
Date of Next Review: Early 2026
Each of the Criteria listed below has been checked and confirmed by the Santon Downham Village Hall Sub-Committee:
Regular checks are carried out to ensure that the system is working properly and produces high quality images.
Notification has been submitted to the Information Commissioner and the next renewal date is recorded.
There is a named individual who is responsible for the operation of the system.
The problem we are trying to address has been clearly defined and installing cameras is the best solution. This decision should be reviewed at least annually.
A system has been chosen which produces clear images which the Law Enforcement Agencies can use to investigate crime and these can easily be taken from the system when required.
Cameras have been sited so that they provide clear images.
Cameras have been positioned to avoid capturing the images of persons not visiting the premises.
There are visible signs showing that CCTV is in operation, who is responsible for installing and maintaining the system and Santon Downham Village Hall Sub-Committee contact details.
Images from this CCTV system are securely stored, where only a limited number of authorised persons may have access to them.
The recorded images will only be retained long enough for any incident to come to light (eg for a theft to be noticed) and the incident to be investigated.
Except for Law Enforcement Agencies, images will not be provided to third parties.
The potential impact on individuals’ privacy has been identified and taken into account in the use of the system.
The organisation knows how to respond to individuals making requests for copies of their own images.