CCTV Policy
1. Introduction: This Policy controls the management, operation, use and confidentiality of the CCTV cameras located in the main hall and kitchen of Eldwick Memorial Hall Ltd. It was prepared after taking due account of the Code of Practice published by the Information Commissioner (May 2015). This policy will be subject to periodic review by the Trustees to ensure that it continues to reflect the public interest and that it and the system meets all legislative requirements. The Trustees accept the principles of the 1998 Act based on the Data Protection Principles as follows:
- Data must be fairly and lawfully processed;
- Processed for limited purposes and not in any manner incompatible with those purposes;
- Adequate, relevant and not excessive;
- Accurate;
- Not kept for longer than is necessary;
- Processed in accordance with individuals’ rights;
- Secure;
2. Statement of Purpose and Scope of Operation: The purpose of the camera is to ensure that the hall is only accessed by authorised hirers and is only used during the agreed hours. The system will not be used to invade the privacy of any individual. Camera’s installed in the Hall and Kitchen are positioned so that it can only record activity within the Hall and kitchen porch and not outside the premises. The camera’s range does not extend to the public highway and cannot record images of anyone outside the Hall and kitchen. The system is a continuous loop system operating 24 hr a day 7 days per week.
3. The Trustees of Eldwick Memorial Hall take full responsibility for the management and operation of the system. Any major change that would have a significant impact on either, the purpose, scope or policy of operation of the CCTV scheme will take place only after discussion at a Trustee meeting. This change would then be incorporated into this policy. Hirers of the Village Hall will be informed of the existence of the camera in the standard conditions of hire and will be encouraged to advise their guests that CCTV cameras are in use in the Hall.
4. Management of the System and Accountability: Day-to-day operational responsibility rests with two named Trustees. The operation of the system and the outcome of any investigations which required footage to be retained will be reviewed at Trustee meeting.
5. Control and Operation of the Camera: The following points must be understood and strictly observed:
- The system will be only be operated by trained individuals using authorised access devices. Currently this is only the two named Trustees, using their phone.
- Passwords and access codes for the camera are stored securely and never disclosed. If other access devices are enabled, this will be done by the named trustees.
- No public access will be allowed to the camera images except for lawful, proper purposes with approval of the Chair of the Trustees.
- The Police are permitted access to recorded material if they have reason to believe that such access is necessary to investigate, detect or prevent crime. The Police are able to visit the Village Hall to review and confirm the operation of the CCTV arrangements. Any visit by the Police to view images will be logged by the one of the Trustees.
- The named trustee should regularly check the accuracy of the date/time displayed by taking a snapshot and verifying the time stamp with the date/time on the email alert sent. Records of these checks will be retained.
- Digital records should be securely stored to comply with data protection laws and should only be handled by the named trustees.
6. The use of camera images:
- For each registered booking: ¨ the named trustee to verify that the Hall is being accessed at the booked time by the authorised hirer and will review the first few seconds of recordings. ¨ along with the last exit from the Hall, by the hirer will be taken and retained for a maximum of 6 months or until invoices for the hire have been raised and settled. ¨ Camera recordings between the first entry and last exit will not normally be viewed unless there is an incident requiring investigation. ¨ All camera recordings for registered bookings (other than the snapshots) will be erased from the recorder within 48 hours of the booking being completed. Erased recordings cannot be recovered. ï For unauthorised or unscheduled access: ¨ Camera footage will be reviewed by one of the named trustees as soon as possible in an attempt to identify the person accessing the Hall. ¨ If the person is known to the trustees and the access to the Hall is for a legitimate purpose, then a snapshot may be taken to correlate with other entry records, but then the recording will be immediately erased. ¨ If the person is not known to the Clerk or the access is not legitimate, then the Clerk will retain the recording whilst an investigation is undertaken. It will be erased once the investigation is completed. ¨ Any event that requires investigation and the retention of recordings should be clearly detailed in the log book of incidents, and the Trustees should be notified at the next available opportunity. ï Images will not be supplied to the media, except on the advice of the police if it is deemed to be in the public interest. The Trustees would inform the Chairman of any such emergency. ï Any request by an individual member of the public for access to their own recorded image must be made by email before the erasure period expires. After this period, there is no way of retrieving the erased images