1.       Introduction
 

Larkmead School uses closed circuit television (CCTV) and the images produced to prevent or detect crime, to monitor the school buildings and grounds in order to provide a safe and secure environment for its pupils, staff and visitors, and to prevent loss or damage to school property.

1.1.     The system comprises a number of fixed dome cameras

1.2.     The system does not have sound recording capability.

1.3.     The CCTV system is owned and operated by the school.

1.4.     The CCTV is accessible from the IT Support & Site Offices

1.5.     The physical CCTV recording equipment is in a secure cabinet in a locked room, accessible only by designated ICT Network Manager and Site Manager. The ICT Technician has access in their absence.

1.6.     Access to the images are controlled by the ICT Network Manager or Site Manager. The ICT Technician has access in their absence. Access to the images is password protected.

1.7.     The introduction of, or changes to, CCTV monitoring will be subject to consultation with the school Leadership Team.

1.8.     The school’s CCTV Scheme is registered with the Information Commissioner.

1.9.     All authorised employees with access to images are aware of the procedures that need to be followed when accessing the recorded images. Through this policy, all operators are made aware of their responsibilities in following the ICO CCTV Code of Practice.

2.       Statement of Intent

2.1.     The school complies with the Information Commissioner’s Office (ICO) CCTV Code of Practice to ensure that CCTV is used responsibly and safeguards both trust and confidence in its continued use. The Code of Practice is published at https://ico.org.uk/media/1542/cctv-code-of-practice.pdf 

2.2.     CCTV warning signs are clearly and prominently placed at the main site entrance(s) to the school, including further signage at entrances to buildings where CCTV is installed.

2.3.     Signs will contain details of the purpose for using CCTV & contact information at the main site entrance(s).

2.4.     Further signage will be displayed where CCTV is operational in areas where privacy is assumed. Footage is redacted where images could invade that privacy.

2.5.     The original planning, design and installation of CCTV equipment endeavored to ensure that the scheme will deliver 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.

3.       Siting the Cameras
 

3.1.     Cameras are sited so that they only capture images relevant to the purposes for which they are installed, and care will be taken to ensure that reasonable privacy expectations are not violated.

3.2.     The School will ensure that the location of equipment is carefully considered to ensure that images captured comply with the GDPR.

3.3.     The school will make every effort to position cameras so that their coverage is restricted to the school premises, which includes outdoor/indoor areas.

3.4.     CCTV will not be used in all classrooms but in limited areas within the school building that have been identified as requiring monitoring. (E.g. social spaces).

 

4.       Covert Monitoring

4.1.     It is not the school’s policy to conduct covert monitoring unless there are exceptional

reasons for doing so.

4.2.     The school may, in exceptional circumstances, determine a sound reason to set up covert monitoring. For example: i) Where there is good cause to suspect that an illegal or unauthorised action(s), is taking place, or where there are grounds to suspect serious misconduct; ii) Where notifying the individuals about the monitoring would seriously prejudice the reason for making the recording.

4.3.     In these circumstances authorisation must be obtained from the Headteacher and the

school’s Data Controller advised before any commencement of such covert monitoring.

4.4.     Covert monitoring must cease following completion of an investigation.

4.5.     Cameras sited for the purpose of covert monitoring will not be used in areas which are reasonably expected to be private, for example toilet cubicles, changing areas, etc.

 

5.       Storage and Retention of CCTV images
 

5.1.     Recorded data will not be retained for longer than is necessary. While retained, the integrity of the recordings will be maintained to ensure their evidential value and to protect the rights of the people whose images have been recorded.

5.2.     All retained data will be stored securely at all times and permanently deleted as appropriate/required.

 

6.       Access to CCTV images
 

6.1.     Access to recorded images will be restricted to those staff authorised to view them and will not be made more widely available.

6.2.     Viewing of footage by school staff investigating an incident will be accompanied by approved staff detailed in para.1.6 and limited to the images relevant to the investigation.

6.3.     Approval must be sought from a member of the Senior Leadership Team before access to footage is viewed. This includes members of Senior Leadership requesting access from another member of the Senior Leadership Team.

6.4.     All viewing requests must be recorded via the CCTV Viewing Approval form, this must be done by the member of staff requesting CCTV access and after gaining approval from a member of SLT, the form is found in several locations including workspace 365 under ‘Jotforms’ or here

 

7.       Subject Access Requests (SAR)
 

7.1.     Individuals have the right to request access to CCTV footage relating to themselves under the Data Protection Act/GDPR.

7.2.     All requests should be made in writing to the Headteacher. Individuals submitting requests for access will be asked to provide sufficient information to enable the footage relating to them to be identified. For example, date, time and location.

7.3.     The school will respond to requests within 40 calendar days of receiving the written request and any fee. This is as per the ICO CCTV Code of Practice.

7.4.     A fee  of  £10  may  be  charged  per  request.  This is  as  per  the  ICO  CCTV  Code  of  Practice.

7.5.     The school reserves the right to refuse access to CCTV footage where this would prejudice the legal rights of other individuals or jeopardies an on-going investigation.

7.6.     Where other parties are identifiable within the   footage   consent will be required prior  to the footage being shown. Where consent is refused, the school will attempt to redact the footage.

 

8.       Access to and Disclosure of Images to Third Parties
 

8.1.     There will be no disclosure of recorded data to third parties other than to authorised personnel such as the Police and service providers to the school where these would reasonably need access to the data.

8.2.     Requests for images / data should be made in writing to the Head Teacher.

8.3.     The data may be used within the school’s discipline and grievance procedures as required,

and will be subject to the usual confidentiality requirements of those procedures.

 

9.       Complaints
 

9.1.     Complaints and enquiries about the operation of CCTV within the school should be directed to the Head Teacher in the first instance.

9.2.     Further Information on CCTV and its use is available from the https://ico.org.uk/your-data- matters/cctv/