This policy supports the Rights Respecting principles adopted by Durdans Park Primary School and is particularly relevant to the following articles:
UNICEF – Convention on the Rights of the Child (CRC)
Article 3
The best interests of the child must be a top priority in all things that affect children.
Article 19
Governments must do all they can to ensure that children are protected from all forms of violence, abuse, neglect and bad treatment by their parents or anyone else who looks after them.
This policy aims to set out the school’s approach to the operation, management and usage of surveillance and closed-circuit television (CCTV) systems on school property.
1.1 Statement of intent
The purpose of the CCTV system is to:
The CCTV system will not be used to:
The list of uses of CCTV is not exhaustive and other purposes may be or become relevant.
The CCTV system is registered with the Information Commissioner under the terms of the Data Protection Act 2018. The system complies with the requirements of the Data Protection Act 2018 and UK GDPR.
Footage or any information gleaned through the CCTV system will never be used for commercial purposes.
In the unlikely event that the police request that CCTV footage be released to the media, the request will only be complied with when written authority has been provided by the police, and only to assist in the investigation of a specific crime.
The footage generated by the system should be of good enough quality to be of use to the police or the court in identifying suspects
This policy is based on:
2.1 Legislation
2.2 Guidance
Surveillance: the act of watching a person or a place
CCTV: closed circuit television; video cameras used for surveillance
Covert surveillance: operation of cameras in a place where people have not been made aware they are under surveillance
Covert surveillance will only be used in extreme circumstances, such as where there is suspicion of a criminal offence. If the situation arises where covert surveillance is needed, the proper authorisation forms from the Home Office will be completed and retained.
Cameras are located in places that require monitoring in order to achieve the aims of the CCTV system (stated in section 1.1).
Cameras are located in the following areas:
| Camera Type | Location | Sound Y/N | Recording capacity Y/N | Swivel/Fixed S/F |
| Hikvision | Vehicle entrance gate | N | Y | F |
| Hikvision | Pedestrian entrance gate | N | Y | F |
| Hikvision | Pedestrian entrance | N | Y | F |
| Hikvision | Staff front car park | N | Y | F |
| Hikvision | Office reception area | N | Y | F |
| Hikvision | KS1 courtyard | N | Y | F |
| Hikvision | Mound outside year 5 | N | Y | F |
| Hikvision | KS2 playground rear of IT suite | N | Y | F |
| Hikvision | N | Y | F | |
| Hikvision | KS1 playground | N | Y | F |
| Hikvision | Rear of year 1 | N | Y | F |
| Hikvision | Rear of nursery | N | Y | F |
| Hikvision | Front of nursery | N | Y | F |
| Hikvision | Rear of IT suite | N | Y | F |
| Hikvision | KS2 playground year 5 | N | Y | F |
| Hikvision | Kaleidescope outside area | N | Y | F |
| Hikvision | Kaleidescope internal | N | Y | F |
Wherever cameras are installed appropriate signage is in place to warn members of the school community that they are under surveillance.
The signage:
Cameras are not and will not be aimed off school grounds into public spaces or people’s private property.
Cameras are positioned in order to maximise coverage, but there is no guarantee that all incidents will be captured on camera.
6.1 The governing board
The governing board has the ultimate responsibility for ensuring the CCTV system is operated within the parameters of this policy and that the relevant legislation (defined in section 2.1) is complied with.
6.2 The Head of Business
The Head of Business will:
6.3 The data protection officer
The data protection officer (DPO) will:
6.4 The system manager
The system manager will:
The CCTV system will be operational 24 hours a day, 365 days a year.
The system is registered with the Information Commissioner’s Office.
The system will not record audio.
Recordings will have date and time stamps. This will be checked by the system manager termly and when the clocks change.
Footage will be retained for 30 days. At the end of the retention period, the files will be overwritten automatically.
On occasion footage may be retained for longer than 30 days, for example where a law enforcement body is investigating a crime, to give them the opportunity to view the images as part of an active investigation.
Recordings will be downloaded and encrypted, so that the data will be secure and its integrity maintained, so that it can be used as evidence if required.
The DPO will carry out annual checks to determine whether footage is being stored accurately, and being deleted after the retention period.
Access will only be given to authorised persons, for the purpose of pursuing the aims stated in section 1.1, or if there is a lawful reason to access the footage.
Any individuals that access the footage must record their name, the date and time, and the reason for access in the access log.
Any visual display monitors will be positioned so only authorised personnel will be able to see the
footage.
9.1 Staff access
The following members of staff have authorisation to access the CCTV footage:
CCTV footage will only be accessed from authorised personnel’s work devices, or from the visual display monitors.
All members of staff who have access will undergo training to ensure proper handling of the system and footage.
Any member of staff who misuses the surveillance system may be committing a criminal offence, and will face disciplinary action
9.2 Subject access requests (SAR)
According to UK GDPR and DPA 2018, individuals have the right to request a copy of any CCTV footage of themselves.
Upon receiving the request the school will immediately issue a receipt and will then respond within 30 days during term time. The school reserves the right to extend that deadline during holidays due to difficulties accessing appropriate staff members.
All staff have received training to recognise SARs. When a SAR is received staff should inform the DPO in writing. When making a request, individuals should provide the school with reasonable information such as the date, time and location the footage was taken to aid school staff in locating the footage.
On occasion the school will reserve the right to refuse a SAR, if, for example, the release of the footage to the subject would prejudice an ongoing investigation.
Images that may identify other individuals need to be obscured to prevent unwarranted identification. The school will attempt to conceal their identities by blurring out their faces, or redacting parts of the footage. If this is not possible the school will seek their consent before releasing the footage. If consent is not forthcoming the still images may be released instead.
The school reserves the right to charge a reasonable fee to cover the administrative costs of complying with an SAR that is repetitive, unfounded or excessive.
Footage that is disclosed in a SAR will be disclosed securely to ensure only the intended recipient has access to it.
This footage will either be provided on an encrypted memory stick or shared via a secure password-protected link on the school website.
Records will be kept that show the date of the mdisclosure, details of who was provided with the information (the name of the person and the organisation they represent), and why they required it.
Individuals wishing to make a SAR can find more information about their rights, the process of making a request, and what to do if they are dissatisfied with the response to the request on the ICO website.
9.3 Third-party access
CCTV footage will only be shared with a third party to further the aims of the CCTV system set out in section 1.1 (e.g. assisting the police in investigating a crime).
Footage will only ever be shared with authorised personnel such as law enforcement agencies or other service providers who reasonably need access to the footage (e.g. investigators).
All requests for access should be set out in writing and sent to the Interim Head of School and the DPO.
The school will comply with any court orders that grant access to the CCTV footage. The school will provide the courts with the footage they need without giving them unrestricted access. The DPO will consider very carefully how much footage to disclose, and seek legal advice if necessary.
The DPO will ensure that any disclosures that are made are done in compliance with UK GDPR.
All disclosures will be recorded by the DPO.
The school follows the principle of privacy by design. Privacy is taken into account during every stage of the deployment of the CCTV system, including the replacement, development and upgrading.
The system is used only for the purpose of fulfilling its aims (stated in section 1.1).
When the CCTV system is replaced, developed or upgraded a DPIA will be carried out to be sure the aim of the system is still justifiable, necessary and proportionate.
The DPO will provide guidance on how to carry out the DPIA. The DPIA will be carried out by Amanda Hancock
Those whose privacy is most likely to be affected, including the school community and neighbouring residents, will be consulted during the DPIA, and any appropriate safeguards will be put in place.
A new DPIA will be done annually or whenever cameras are moved, or new cameras are installed.
If any security risks are identified in the course of the DPIA, the school will address them as soon as possible.
Complaints should be directed to the interim head of the school or the DPO and should be made according to the school’s complaints policy.
The policy will be reviewed annually by the Head of Business and DPO to consider whether the continued use of a surveillance camera remains necessary, proportionate and effective in meeting its stated purposes
Approved by the:
Governing Body
Date:
13/09/2022
Last Review Date:
August 2025
Next Review Date by:
August 2026