1.1       This Code of Practice explains the purpose, use, and management of the CCTV installations at the University of Westminster.

 

1.2       The purposes of the CCTV installations are:

 

·        the protection of staff, students, visitors, and the assets of the University;

 

·        the prevention, investigation and detection of crime and disciplinary offences in accordance with the University disciplinary procedures;

 

·        the apprehension and prosecution of offenders (including the use of images/data as evidence in criminal / civil proceedings);

 

·        the monitoring of the security of premises.

           

1.3       The principles of the Code of Practice are:

 

·        that individuals' rights are respected and protected;

 

·        that the installations are operated fairly and within the law;

 

·        that the CCTV system is operated for the purposes for which it was set up;

 

·        that the recorded material/data stored is fairly and lawfully processed;

 

·        that recorded material/data is adequate, relevant and not excessive for the purposes;

 

·        that recorded material/data is accurate, securely stored, and not kept for longer than is necessary.

 

1.4       This Code of Practice has been developed in consultation with staff and students within the University and approved by the Vice Chancellor's Executive Group.

 

 

 

2.1       The CCTV installations comprise all fixed cameras, printer monitors, signs, recording and playing equipment, information, material, data, and any ancillary equipment required for the operation of the installations (e.g. cabling, printers, power supplies).

 

2.2       Recorded material/data means any material recorded by the installations, either in digital or analogue form on video cassette tape, PC computer system tape, hard copy print, or any document copy.

 

2.3       The recorded material/data are the property of the University of Westminster.

 

2.4       A list of CCTV installations as at June 2001 is given in Appendix A. This will be updated and re-issued as required.

 

 

 

3.1       The University officers with accountability for ensuring compliance with this Code of Practice and the principles of the Data Protection Act 1998 are:

 

·        Provosts, for academic buildings;

 

·        the Halls of Residence Estate Manager, for the Halls of Residence buildings.

 

3.2       Campus Service Managers (CSMs) are responsible to the Provosts for the operation of the CCTV system in academic buildings.

 

3.3       The Halls of Residence Managers (HoRMs) are responsible to the Halls of Residence Estate Manager for operation of the CCTV systems in the Halls of Residence.

 

3.4       For the purpose of compliance with the Data Protection Act 1998:

 

·        the CSMs are the Data Controllers for their Campus and are responsible to the Provosts in this capacity;

 

·        the HoRMs are the Data Controllers for their Hall of Residence and are responsible to the Halls of Residence Estate Manager in this capacity.

 

3.5       The CSMs and HoRMs will ensure that their systems are operated strictly in compliance with this Code of Practice.

 

3.6       The CCTV systems operating companies (see 4 below) will operate the CCTV systems in a manner which complies with the Data Protection Act 1998 and the Human Rights Act 1998.

 

3.7       The systems will be operated 24 hours per day, 365 days of the year with images/pictures from the cameras being available to be continuously monitored by authorised staff.

 

 

 

4.1       The systems will be operated on behalf of CSMs and HoRMs by the University's Security Contractors. These are currently:

 

            Harrow Academic Buildings                        PEGASUS SECURITY LTD

 

            London Academic Buildings                       ICTS/ (UK Ltd)

 

            Harrow Halls of Residence                          EXTREME SECURITY LTD

 

            London Halls of Residence                          ICTS/ (UK LTD)

 

4.2       Although the security contractor companies operate the CCTV equipment, the legal responsibility under the current legislation rests with the Data Controllers as defined above.

 

4.3       The Security Contractors are subject to this Code of Practice.

 

 

 

5.1       CCTV systems will not be installed or operated on University property other than for the purposes detailed at paragraph 1.  The procedures for operation shall be as follows:

 

5.1.1   Location of CCTV Systems

 

The CCTV camera positions shall be determined by the relevant Provost or the Halls of Residence Estate Manager with advice from the Health and Safety Adviser and CSMs as appropriate; no other camera positions will be allowed. 

 

Cameras will not be situated such that images can be obtained of areas which do not require surveillance in accordance with the purposes of the installation.

 

Each area of the University buildings/premises monitored by CCTV systems will be identified by a sign/notice in the format detailed at Appendix B.

 

5.1.2   Recordings

 

The CCTV equipment installations shall be fit for the purposes detailed in the Code of Practice at paragraph 1.

 

The equipment will perform properly and provide clear images/data, and the tapes used will be of sufficient quality (no deterioration) to allow previous recorded images to be seen.

 

The equipment which records material/data and features the location of the camera and/ or date and time reference will be accurate.

 

Only high quality tapes will be used and will be replaced by new tapes once they have been used to the limit detailed in the manufacturer's instructions.

 

The CCTV camera images will be recorded continuously in time-lapse mode, capturing images/data every few seconds.

 

A maintenance log/record will be kept, indicating that images/data recorded is accurate, and cameras and recording system are working correctly.

 

5.1.3   Sites of Recording Equipment

 

Recording equipment will be located in a secure room where access is limited to:

 

·        the Data Controller and his/her support staff;

 

·        the Systems Operating Company staff;

 

·        equipment maintenance staff, as required;

 

·        specialist editing company staff, as required (see 6.7 below).

 

When recorded tapes are being viewed, access by other personnel will be refused.

 

Access to the CCTV recording equipment by these and any other persons will be documented and such records kept for a twelve (12) month period.           

 

5.1.4       Handling Recorded Material 

 

A video cassette tape log shall be kept which provides a record of individual tape usage for the period covered.

 

Both analogue and digital video recordings are to be kept for a period of 28 days after recording, then erased completely, and the tapes reused; tapes shall be re-used only to the limit detailed in the manufacturer's instructions.

 

A log/record sheet to the format detailed at Appendix C shall be kept at each recording location where record/material data is made.

 

5.1.5       Recording Material Life

 

Video cassettes are to be reused only up to the limit detailed in the manufacturer's instructions.

 

Video tapes are then to be erased and disposed of securely. This action should be recorded and signed for in the log/record sheet.

 

5.1.6   Viewing Recorded Material

           

            The right to view recorded material is restricted to the following persons:

 

·        authorised employees/contractors;

 

·        the Police (Metropolitan Police and other authorised UK Police Authority staff) in support of a criminal investigation;

 

·        accused persons or defendants in criminal proceedings;

 

·        witnesses to alleged crimes, to assist Police or University crime investigations;

 

·        plaintiffs and defendants in civil proceedings;

 

·        solicitors/legal representatives;

 

·        statutory authorities with powers to prosecute (e.g. Customs and Excise, Trading Standards officers);

 

·        disciplinary panel members where recorded material is being presented in evidence in a disciplinary case.

 

·        maintenance contractors in carrying out performance checks of the equipment;

 

·        staff of specialist editing companies in editing the tapes to meet the requirements of the Data Protection Act 1998 (see 6.7 below).

 

The only circumstances under which recorded material shall be released for publication by television or photographic media is where it is essential for the identification to the general public of a person wanted for or convicted of a crime, assault, violence, substantial theft, or fraud. This shall only be with the joint agreement of the investigating police officer's supervising Inspector and the Vice Chancellor.

 

5.1.7       Authorising Tape Viewing/Copying of Recorded Material

 

Data Controllers will authorise tape viewing.  Authorisation shall be given only where examination of the recording is being carried out in accordance with the purposes and principles of this Code of Practice.

 

Tapes identified as containing information relevant to an investigation are to be secured within an approved safe.

 

5.1.8       Custody of Recorded Material

 

No Recorded Material shall be taken from the recording system secure area unless authorised by Data Controllers.

 

This authorisation is to be provided in writing to the format detailed at Appendix D.  Logs are to be kept of all data viewing and tape removals in the formats detailed at Appendix E and F.

 

5.1.9       Maintenance 

 

The CCTV installations will be maintained in compliance with manufacturers' recommendations by a specialist company under contract to the University. 

 

Before selection this contractor will demonstrate that its company procedures are in full compliance with the Data Protection Act 1998. 

 

This contract will also provide for a defect response 'call out' time of less than four hours.

 

These maintenance checks will in particular provide an assessment that the equipment is functioning at its optimum performance and that its location time/data referencing information (where this facility is provided) is accurate.

 

The results of these inspections shall be recorded in a system maintenance log in the format shown at Appendix G.

 

5.1.10Training

 

The University will provide a training programme for the Data Controllers covering the operational features of the system, the operational procedures to be used, and the requirements in respect of CCTV operation of the Data Protection Act 1998.

 

The University will require training for all security personnel operating the CCTV systems which provides full acknowledgement and awareness of the principles of the Data Protection Act 1998 and the Human Rights Act 1998.

 

All CCTV operators shall be trained in their responsibilities under this Code of Practice, including the procedures for persons to have access to recorded material/data.

 

 

 

6.1       University staff, students and other individuals using the University premises (e.g. visitors, contractors) may apply to view a tape.

 

6.2       The request must be made in writing to the CSM/HoRM responsible for the building in which the CCTV installation is located.

 

6.3       The request should give the date, location, and time of the recording required for viewing and a reason for the request. The reason must comply with one of the purposes set out in paragraph 1.

 

6.4       Requests must be received within 28 days, before the tape is re-used. The CSM /HoRM will set aside the relevant tape and refer the request as appropriate to either the Provost or the Halls of Residence Estates Manager. 

 

6.5       The Provosts/Hall of Residence Estate Manager will consider each request according to the circumstances and decide whether access to view tapes will be permitted.  This consideration will take account of compliance with the purposes set out in paragraph 1. Requests to view tapes for personal interest will not be granted.

 

6.6       In compliance with the Data Protection Act 1998 and the Human Rights Act 1998 applicants may view only themselves.  Requests to view other persons will be refused other than in the circumstances detailed in 5.1.6 above.

 

6.7       When an individual is permitted to view a tape, details by which another individual may be identified will be masked out.  This restriction will require tapes to be edited. Such editing will be carried out by a specialist company under contract to the University.  This company's contract will require it to carry out such work in full compliance with the Data Protection Act 1998.

 

 

 

7.1       The University's CCTV installations will be registered under the Data Protection Act 1998 and all release of information will be in accordance with the registration.

 

7.2       An exemption to the provisions of the Data Protection Act 1998 covers the disclosure of information for the purposes of:

 

·        Preventing or detecting crime

 

·        Apprehending or prosecuting offenders

 

·        Assessing or collecting any tax or duty

 

This exemption applies only where non-disclosure would be likely to prejudice one of these purposes.

 

 

 

8.1       The operation of this Code of Practice will be audited annually by personnel nominated by the University Secretary. Staff and students will be consulted. The results of this audit will be available to all staff.

 

 

 

9.1       Leaflets describing the CCTV system, its purpose and operation will be provided at each building reception and will be issued to staff and students on request.

 

 

 

 

 

 

 

 

10.1    The system description leaflet will provide a pro forma for complaints and enquiries on the use of each system. 

 

10.2    Written responses will be provided to members of staff, students and members of the public to complaints and queries within 21 days of their receipt.  A record of all complaints and enquiries will be kept.  This record will show the action taken in each case.  Examination of this record will form part of the annual audit of the system.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

From:Data Controller Name:

Position within University:

Address:

 

 

To:      Systems Operating Company Officer

            Operating Company Name

 

 

 

(Name, Address, Telephone Number of Person being authorised) is hereby authorised to view/remove (delete that not applicable) CCTV tapes covering the period __________________________ to _______________________ for the purpose of (give reason)_______________________________________________________________ providing images at the following locations.

 

Please make the necessary arrangements ensuring that all the requirements of the University CCTV Code of Practice are followed.

 

Signature___________________________

 

Name______________________________

* Provost HOR Estate.  Manager Data Controller. 

* When Police Officer (Address of Police Station)