Date approved: March 2017
Review date: under review
Please be aware that this full policy may include acronyms or technical jargon used internally within Raven. If you have any questions, please contact us.
1. INTRODUCTION AND SCOPE
1.1. The purpose of this policy is to outline the way in which Raven will use Closed Circuit Television (CCTV).
1.2. Raven may consider the use of CCTV in the following circumstances:
- The prevention and detection of any crime against Raven staff or property,
- Ensuring public safety,
- To protect public and private property,
- Monitoring the security of premises and assets,
- Working with Police, local authorities and other partnership organisations to identify and take appropriate actions against perpetrators of crime, ASB or breaches of tenancy.
1.3. CCTV can be used ‘overtly’ where cameras are clearly on display with appropriate signs or on occasions for ‘covert’ purposes where the use of the camera is not intended to be seen. Signage may also be installed to advise of the regular use of covert mobile CCTV camera’s.
2. POLICY PRINCIPLES / STATEMENT
2.1. Raven will operate CCTV in accordance with its Data Protection policy and procedure and will comply with all relevant statutory guidelines and legislation applicable to the Trust.
2.2. In reviewing this Policy Raven have taken into account and implemented recommendations from the ICO – “In the picture: A data protection code of practice for surveillance cameras and personal information”.
2.3. Raven will routinely use overt CCTV to provide reassurance to residents and to reduce crime. Raven will only monitor an adequate and not excessive area, as necessary for the purpose of capturing evidence to support breach of tenancy and possibly crime prevention and detection; this includes but is not limited to:
- Reception areas and doorways in Raven offices.
- Stairwells and doorways at schemes / estates.
- CCTV at sheltered housing schemes and temporary accommodation schemes
- Entrances to individual properties with residents agreement
2.4. Raven will consider the use of covert mobile CCTV where it is practical and cost effective to do so in order to assist in the reduction of significant crime, ASB, breaches of tenancy or damage to Raven property or estates.
2.5. Raven will work with partner local authorities, and other agencies, contractors or suppliers to seek advice on best practices and advances in CCTV equipment.
2.6. Whilst Raven is not subject to RIPA legislation we will adopt their guidelines for best practice.
2.7. Raven will consider placing mobile cameras in locations which need to be monitored for crime prevention and detection purposes, and which do not have an adverse impact on people’s privacy. Neighbouring gardens and properties not owned by Raven will not be monitored without obtaining consent of the owners.
2.8. Raven has separate procedures/guidance for the installation & monitoring of fixed CCTV for Raven premises, Sheltered Accommodation, Temporary Accommodation and general needs accommodation.
2.9. Raven’s Procedure on the installation of mobile cameras contains a Request Referral Form, which also includes a Privacy Impact Assessment.
3. OVERT MONITORING (it is intended that cameras are deliberately seen by the public)
3.1. Raven will take all reasonable steps to make it clear when an area is monitored by CCTV.
3.2. Raven will ensure there are adequate signs to inform any person that they are entering an area likely to be within the range, or potential range, of the cameras.
4. COVERT MONITORING (it is intended that cameras are hidden from the public)
4.1. Raven will only consider covert monitoring in limited circumstances where required for a specific investigation.
4.2. Raven will only undertake covert mobile CCTV where it is needed to obtain evidence of an identified crime, ASB or Tenancy Breach. Examples are listed below:-
- A specific criminal activity / gross misconduct has been identified
- There is an identified need to obtain evidence
- The need for covert, rather than overt, monitoring has been assessed
- The decision process has been documented and authorised
- It has been agreed for a documented time period
- Where appropriate we will share details of CCTV use with partnership agencies
4.3. Raven will disregard any information discovered through mobile covert monitoring which is not directly relevant to the purpose for which it was introduced, unless it is evidence of a criminal activity which it is not reasonable to overlook
5.1. The Senior Neighbourhood Warden and Tenancy Enforcement Officers will be responsible for viewing live and recorded images from the mobile CCTV and for the storage of and requests for access to images/recordings.
5.2. The Head of Housing Management or another senior manager with equivalent responsibility must authorise the use of mobile CCTV. Images or recordings will only be reviewed by an appropriate member of staff. Advice should be taken before sharing any images/recordings with Police, Local Authorities or partnership organisations. Reference should be made to Raven’s Data
Protection policy and procedure.
5.3. The Facilities & Asset Management Team will be responsible for viewing, storage and requests for access to images/recordings relating to Raven premises.
5.4. The Supported Housing Manager will be responsible for viewing, storage and requests for access to images/recordings captured in Sheltered & Temporary Accommodation.
6. DATA MANAGEMENT
6.1. Recorded images and stills will be kept for a maximum of 28 days from the date of initial download or until investigations are completed or until required for evidential purposes.
7. VIEWING/PLAYING OF IMAGES AND RECORDINGS
7.1. Images or recordings will only be reviewed by appropriate members of staff; and will only be kept as long as they are needed to assist with investigation, prosecution and future prevention.
7.2. Wherever possible the monitoring and recording equipment will be located in an access restricted area and a limited number of people permitted to use it
7.3. Where the images are recorded directly onto a hard disc, these will be password protected to prevent unauthorised access
7.4. In some circumstances CCTV can be viewed on a Raven mobile device, however images will not be stored on the device directly and extra care should be taken in regard to data protection.
7.5. Any images captured by a member of staff on a mobile phone (or equivalent) will be transferred to a hard disc as soon as possible, as per 7.3, and the images deleted from the phone.
8. REVIEW OF MOBILE CCTV SITES
The Senior Neighbourhood Warden or Tenancy Enforcement Officers will be responsible for reviewing CCTV sites regularly to ensure there is still a need for a CCTV camera on site which is in line with RIPA & ICO best practice.
9. 3RD PARTY ACCESS
Disclosures to 3rd parties will be limited to the following:
- Law enforcement agencies or the Local Authority , where it is believed that the images will assist in a :-
- legal enquiry;
- Prosecuting agencies;
10. ACCESS TO DATA SUBJECTS
Requests for access to images or recordings from data subjects should be requested and agreed by the Head of Housing or a more senior manager in writing providing it is required for a legitimate and valid reason and the disclosure satisfies all legal and data protection requirements.
Anyone wishing to make a subject access request must complete an application form, stating the data they want to check and the reasons, and must pay an administration charge to Raven. The charge is set out in the subject access request procedure.
11. MONITORING AND REVIEW
11.1. The use of the CCTV equipment will be reviewed on at least an annual basis by all relevant managers mentioned above to ensure that the use complies with legal obligations and this policy. This policy document will be formally reviewed every three years and updated to reflect any changes to corporate/customer requirements and targets.
11.2. We will ensure that any contractors we use to maintain CCTV equipment meet the Information Commissioners standards and requirements.
11.3. Any staff found abusing CCTV systems will be subject to disciplinary action in accordance with the Disciplinary Policy and Disciplinary Procedure and may be subject to criminal action.