Introduction

Marshfield Village Hall (“MVH”) is a registered charity, number: 509170.  Closed circuit television (“CCTV”) is installed at MVH.  Cameras are located at various places on the premises and images from the cameras are recorded digitally and then automatically recorded over after approximately three month.  This document details the policy and procedures used to control the management, operation, use and confidentiality of the CCTV system.

Purpose & Objectives

1    The purposes and objectives of the CCTV system are:

• to maintain the security of the premises
• to deter, detect and prevent crime, vandalism and anti-social behaviour
• to provide a safe and secure environment for volunteers, staff, hirers, visitors and contractors
• to assist Law Enforcement Agencies to carry out their lawful duties.

2   This use of CCTV falls within the scope of The Data Protection Act 2018 and The General Data Protection Regulation 2018.  MVH complies with the Information Commissioner’s Office (“ICO”) CCTV Code of Practice (https://ico.org.uk/media/1542/cctv-code-of-practice.pdf) to ensure that it is used responsibly.

Warning Signs

CCTV warning signs are clearly and prominently displayed at MVH’s Main Entrance Door, at the front of the Main Hall and n the coffee shop. 

Siting the Cameras and Coverage

The planning and design has endeavoured to ensure that the CCTV system gives 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.

Cameras have been sited carefully so that they only capture images relevant to the purposes for which they are installed (described in “Purpose” above) and care has been taken to ensure that reasonable privacy expectations are not violated.  Every effort has been made by MVH to position cameras so that their coverage is restricted to the MVH premises which may include public areas.

The cameras are sited on (a) the corner of the building overlooking the car park entrance, (b) above the Main Entrance Door, (c) the main foyer (d) the rear of the building overlooking the coffee shop entrance and fields (x2), (e) inside the coffee shop looking over the counter.

Storage and Retention of CCTV images

Recorded data is stored automatically for up to 90 days on a recorder which is secured within MVH and to which only the members of the MVH Management Committee have access. Recorded data will be stored in a way that ensures the security and integrity of the image and allows specific times and dates to be identified.

Normally, recorded data will not be retained for longer than 90 days. On occasion, images may need to be retained longer where, for example, an incident has been identified or a Subject Access Request has been made or time is required to enable the Law Enforcement Agencies to collect relevant images or the Law Enforcement Agencies are investigating a crime and ask for images to be preserved to afford them the opportunity to view the information as part of an active crime investigation.  All retained images will be stored securely.

Access to CCTV Images and Disclosure

Access to recorded images is restricted to members of the MVH Management Committee, all of whom are deemed by The Charity Commission to be legal Trustees of MVH.  Disclosure of information will be controlled and consistent with the purpose(s) for which the CCTV system has been established.  Once information is disclosed to a Law Enforcement Agency, they will become data controller for the copy which they hold.

The following guidelines will be adhered to in relation to the disclosure of images:

1. The disclosure of images will be in line with the above Objectives and will be controlled under the supervision of the Data Controller or his/her deputy;
2. A log will be maintained itemising the date, time(s), camera, person copying, person receiving and reason for the disclosure;
3. The appropriate disclosure documentation from the Law Enforcement Agencies will be filed for future reference;
4. Images must not be forwarded to the media for entertainment purposes or be placed on the internet;
5. Images must not be copied in any way, eg photographed, downloaded or printed for use other than described in the objectives;
6. Images will only be released to the media for identification purposes in liaison with the Law Enforcement Agencies;
7. The method of disclosing images should be secure to ensure that they are only seen by the intended recipient; and
8. Images of third parties not relevant to the investigation should be obscured where possible to prevent unnecessary identification.

Subject Access Requests

Individuals have the right to request access to CCTV footage relating to themselves under The General Data Protection Regulation.

All requests for access should be made by e-mail or in writing to the MVH Chair providing sufficient information to enable the footage relating to them to be identified, ie date, time and location.  MVH will respond to requests within 4 weeks of receiving the written request.

All requests for access are recorded.  If disclosure is denied, the reason is documented and the individual will be informed within at least 4 weeks of the reason and their right to complain to a statutory authority.  MVH reserves the right to refuse access to CCTV footage where this would prejudice the legal rights of other individuals or jeopardise an ongoing investigation. 

A fee of £10 may be charged for a Subject Access Request, depending on circumstances.

Complaints

Enquiries or complaints about the operation of MVH’s CCTV system should be directed to the MVH Chair in the first instance at mvhmc.treasurer@hotmail.com.

Review

This policy will be reviewed at least annually by the MVH Management Committee or when new legislation requires this policy to be updated.  The CCTV Notice appended to this policy forms a checklist for the MVH Management Committee to use and is displayed on the noticeboard in the MVH lobby to provide assurances on the proper use of CCTV to volunteers, hirers, visitors and contractors.

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MARSHFIELD VILLAGE HALL

CCTV NOTICE

The CCTV system installed at Marshfield Village Hall (“MVH”) and the images produced by it are controlled by the MVH Management Committee which is responsible for how the system is used. 

The MVH Management Committee has considered the need for using CCTV and has decided that it is required for the prevention and detection of crime and for protecting the safety and security of MVH volunteers, hirers, visitors and contractors. It will not be used for other purposes and an annual review of the use of CCTV will be conducted.

Date of Review:          5th May 2024

Date of Next Review:  May 2025

Each of the Criteria listed below has been checked and confirmed by the MVH Management Committee:

• Notification has been submitted to the Information Commissioner and the next renewal date is recorded.
• There is a named individual who is responsible for the operation of the system.
• The problem we are trying to address has been clearly defined and installing cameras is the best solution.  This decision should be reviewed at least annually.
• A system has been chosen which produces clear images which the Law Enforcement Agencies can use to investigate crime and these can easily be taken from the system when required.
• Cameras have been sited so that they provide clear images.
• Cameras have been positioned to avoid capturing the images of persons not visiting the premises.
• There are visible signs showing that CCTV is in operation, who is responsible for installing and maintaining the system and MVH contact details.
• Images from this CCTV system are securely stored, where only a limited number of authorised persons may have access to them.
• The recorded images will only be retained long enough for any incident to come to light (eg for a theft to be noticed) and the incident to be investigated.
• Except for Law Enforcement Agencies, images will not be provided to third parties.
• The potential impact on individuals’ privacy has been identified and taken into account in the use of the system.
• The organisation knows how to respond to individuals making requests for copies of their own images.
• Regular checks are carried out to ensure that the system is working properly and produces high quality images.