The purpose of this policy is to outline the University’s approach to the use of closed circuit television systems across the institution and to comply with the requirements of the Data Protection Act 1998, the 2008 CCTV Code of Practice, the Regulation of Investigatory Powers Act 2000 and the Private Security Industry Act 2001.
This policy applies to all CCTV and other systems which capture images of identifiable individuals or information relating to individuals for the purposes of monitoring activities on University premises, car parks and other public areas to identify criminal activity whether occurring, anticipated, or perceived in order to enhance the safety and wellbeing of staff, students, and visitors. All Security Officers have been made aware of this requirement.
The planning and design of CCTV systems has endeavored to ensure maximum effectiveness and efficiency but cannot guarantee to cover or detect every incident occurring within the areas covered.
The use of conventional cameras (not CCTV) for artistic or educational purposes such as for film making is not covered by this policy.
3. Responsible Authorities
This policy is issued by the Executive Director for Estates & Property Services who, as an Officer of the University has:
- the responsibility for physical security of staff, students, buildings and contents,
- the authority to develop, authorise and promulgate policy and procedures relating to such matters, and
- the responsibility to investigate (and the authority to delegate that responsibility) breaches of such policies.
4. Policy Statements
4.1 The University is responsible for all CCTV operated within its buildings and is the data controller for the requirements of the Data Protection Act 1998 ensuring that all obligations are met.
4.2 All CCTV operated is managed by Estates and Property Services and no other unit should operate their own independent system.
4.3 All users of CCTV systems are appropriately trained and licensed.
4.4 Appropriate procedures are created and followed for the use of CCTV systems with recording, viewing and retention of images undertaken in accordance with approved standards.
4.5 CCTV is not used to record conversations.
4.6 The University does not undertake covert surveillance activities without express authority from the Head of Security and the Data Protection Officer.
4.7 Equipment used, image quality, camera siting and locations are appropriate to ensure that the images are adequate for the purpose for which they are being collected.
4.8 An impact assessment on the basis of privacy and human rights are undertaken before installation of any CCTV camera and thereafter on a yearly basis to ensure that the use is justified.
4.9 Disclosure of images from the CCTV system is controlled and is consistent with the purpose for which the system was established.
4.10 The University informs people who may be the recorded by CCTV of its use of and purposes.
5. Monitoring and Enforcement
Adherence to this policy will be audited annually but will not otherwise be monitored actively. Reports of breaches will be investigated thoroughly and in accordance with the appropriate legislation.
As an officer of the University, the Executive Director or his nominee has the authority to investigate alleged breaches of this policy and to refer individuals to Human Resources or their Faculty, School or Division for disciplinary action.