CCTV System Policy of Mohill Community College
CCTV SYSTEM POLICY
CCTV SYSTEM POLICY
This CCTV SYSTEM POLICY should be read in conjunction with CCTV Policy for ETBs and Data Protection Policy for ETBs, approved by the Board of Management of MCC 13th October 2015.
1.1 The purpose of the CCTV System Policy of Mohill Community College (“the Policy”) is to regulate the management, operation and use of the closed circuit television (CCTV) system (“the System”) at Mohill Community College (“the School”).
1.2 The system comprises a number of housed (external) and dome (internal) cameras located around the school site. The Policy follows Data Protection Commissioner Guidelines and is drafted in conformity with the Data Protection Act, 1988 and the Data Protection (Amendment) Act, 2003 (“the Acts”).
1.3 Comments from interested parties are welcome and will be considered when the policy is reviewed.
1.4 The System is wholly owned by the School
2. Objectives of the System
2.1 (a) To protect the school buildings and their assets,
(b) To increase personal safety of staff, pupils and visitors and reduce the fear and incidence of crime,
(c) To support the Gardai in a bid to deter and detect crime,
(d) To assist in identifying, apprehending and prosecuting offenders,
(e) To protect members of the public and private property,
(f) To assist in managing the School,
(g) To assist in relation to matters other than security, namely, the promotion of and compliance with Health and Safety standards and taking appropriate disciplinary measures, where so required.
(h) The System will not be used to monitor staff conduct or performance, except where required to investigate the alleged commission of a crime.
3. Statement of Intent
3.1 The School will treat the System and all information, documents and recordings obtained and used there from as data which may be deemed personal data requiring protection under the Acts.
3.2 Cameras will be used to monitor activities within the school circulation areas and its car parks and other public areas as an adequate, relevant and proportionate response to the achievement of the objectives identified at paragraph 2.1.
3.3 Materials or knowledge secured as a result of the use of the System will not be used for any commercial purpose. The recorded images shall be stored on DVDs/USBs which will only be released to the media or other third parties for use in the investigation of a specific crime and with the written authority of the Garda Siochana. DVDs/USBs containing personal data will never be released to the media or other third parties for any purpose that is not permitted under the Policy without the Data Subject’s consent.
3.4 The planning and design of the System has endeavoured to ensure that it will give maximum effectiveness and efficiency insofar as is reasonably practicable but it is not possible to guarantee that the System will cover or detect every single incident taking place in the areas of coverage.
3.5 Warning signs, as required by the Code of Practice of the Data Protection Commissioner have been placed at all access routes to areas covered by the school CCTVs to inform all persons who may be deemed Data Subjects, of the operation of the System.
4. Operation of the System
4.1 For the purposes of the Data Protection Acts 1988-2003 the Data Controller will be Mohill Community College. In practice, the System will be managed by the Principal, in accordance with the principles and objectives expressed in the Policy.
4.2 The day-to-day management will be the responsibility of the Principal. Other personnel may also be authorised by the Principal to view recorded images for the purposes outlined in this policy, e.g. the Deputy Principal, Year Heads, Caretakers.
4.3 The System will be operated 24 hours each day, every day of the year, except for periods of breakdown or necessary maintenance.
4.4 A schedule for regularly checking the quality of images being collected and also checking whether the date and time are accurate will be the responsibility of the Principal. A maintenance contract with Lock Up Alarms will include such checking.
4.5 During times of school closure, the CCTV system will continue to operate as normal and will be maintained and monitored by Caretaking Staff.
5. Control Room
5.1 The Principal’s Office is where the system is installed and from where it is controlled. The Principal will check and confirm the efficiency of the System regularly and in particular that the equipment is properly recording and that cameras are functional. The recording equipment is located in a locked cabinet in the Principal’s Office. The key will be held by the Principal.
5.2 Access to the Principal’s Office will be limited to the authorised people while recorded data is being viewed.
5.3 If out of hours emergency maintenance arises, the security staff must be satisfied of the identity and purpose of contractors before allowing access to the Control cabinet.
5.4 The Control cabinet will be kept locked.
5.5 Emergency procedures will be used in appropriate cases to call the Emergency Services
6. Monitoring Procedures
6.1 Camera surveillance will be maintained at all times through the constant operation of cameras. Monitoring will be possible when the Principal/Deputy Principal/designated personnel are in the Office.
6.2 Monitors are installed in the Principal’s Office and will be used only in accordance with this Policy.
7. Video Recording Procedures
7.1 Recordings are initially made to a hard disk which is located in the locked Control cabinet in the Principal’s office. The equipment is programmed to delete images automatically after a certain period of time. Data can be recorded on to DVDs/USBs for specific purposes in accordance with this policy and with the authorisation of the Principal. Such DVDs/USBs will be stored in a locked cabinet.
7.2 In order to maintain and preserve the integrity of the DVDs/USBs used to record events from the hard drive and the facility to use them in any future proceedings, the following procedures for their use and retention must be strictly adhered to:
(i) Before use each DVD/USB must be cleaned of any previous recording.
(ii) The Principal shall register the date of DVD/USB insert.
(iii) A DVD/USB required for evidential purposes must be sealed, witnessed, signed by the Principal, dated and stored in a secure place.
(v) If the DVD/USB is archived the reference must be noted.
7.3 DVDs/USB may be viewed by the Gardai for the prevention and detection of crime
7.4 A record will be maintained of the release or viewing of DVDs/USBs to the Gardai or other authorised persons. A register will be maintained for this purpose.
7.5 Should a DVD/USB recording be required as evidence, a copy may be released to the Gardai. DVDs/USBs will only be released to the Gardai on the clear understanding that the recording remains the property of the School, and both the DVD/USB and information contained on it are to be treated in accordance with this code. The School also retains the right to refuse permission for the Gardai to pass to any other person the DVD/USB or any part of the information contained thereon.
7.6 The Gardai may require the school to retain the stored DVDs/USBs for possible use as evidence in the future. Such DVDs/USBs will be properly indexed and properly and securely stored until they are needed by the Gardai.
7.7 In respect of DVDs/USBs not required to be retained for security, crime detection or other legitimate purposes, the School will ensure its best endeavours are used to safely and properly dispose of the contents of the DVDs/USBs after a reasonable period.
7.8 Applications received from outside bodies (e.g. solicitors) to view or release personal data stored on DVDs/USBs and held by the School will be referred to the Principal. In these circumstances a copy of the relevant DVD/USB will normally be made available for viewing or released where satisfactory documentary evidence is produced showing that they are required for legal proceedings, a subject access request, or in response to a Court Order.
8. Breaches of the Policy (including breaches of security)
8.1 Any breach of the Policy by the School staff or any other person with responsibility under the Policy will be initially investigated by the Principal, in order for him/her to take the appropriate disciplinary action.
8.2 Any serious breach of the Policy will be immediately investigated and an independent investigation will be carried out by nominees of the Principal to make recommendations on how to remedy the breach.
9. Assessment of the System
9.1 Performance monitoring, including random operating checks, will routinely be carried out by the Principal.
9.2 Lock Up Alarms will be responsible for annual maintenance, and for more regular maintenance as necessary.
10.1 Any complaints about the School’s CCTV system should be addressed to the Principal.
10.2 Complaints will be investigated in accordance with paragraphs 8.1 and 8.2 of the Policy.
10.3 Any person who might be deemed a Data Subject in relation to the System shall be at liberty to make a complaint directly to the office of the Data Protection Commissioner, Canal House, Station Road, Portarlington, Co. Laois.
11. Access by the Data Subject
11.1 The Acts provide Data Subjects (individuals to whom “personal data” relate) with a right of access to personal data held about themselves (including images recorded by the System and stored on DVDs/USBs), under the terms of the Acts.
11.2 Requests by Data Subjects for such access should be made in writing to the Principal.
11.3 The form of access granted may consist of facilities being offered at the School premises to view the relevant personal data or the release of a copy DVD/USB storing the relevant personal data.
Summary of Key Points
The CCTV system is owned and operated by the school.
The Control cabinet will be secured at all times.
Recording DVDs/USBs will be used properly and in accordance with the Acts and indexed, stored and destroyed within a reasonable period when it is no longer reasonably necessary to retain such data.
DVDs/USBs may only be viewed by Authorised School Officers, and the Gardai.
DVDs/USBs required as evidence will be properly maintained and preserved and witnessed and packaged before copies are released to the Gardai.
DVDs/USBs will not be made available to the media or third parties generally for commercial or entertainment use. DVDs/USBs will be disposed of securely.
Any breaches of the Policy will be investigated by the Principal. An independent investigation will be carried out for serious breaches.
Breaches of the Policy and remedies will be reported to the Principal.
This policy is published under the Freedom of Information Act and is available by contacting the Principal.
Effective Date: 17th May 2010 on approval of Board of Management, Mohill Community College.
Review Date: To be reviewed regularly.
Appendix 1: RECORD OF ANNUAL MAINTENANCE OF CCTV SYSTEM
Appendix 2: RECORD OF REGULAR MAINTENANCE OF CCTV SYSTEM
Appendix 3: RECORD OF REQUESTS TO REVIEW DATA FROM CCTV SYSTEM
Appendix 4: REGISTER OF REQUESTS TO OBTAIN COPY/COPIES OF DATA FROM CCTV SYSTEM