Bentley Heath Community Centre

CCTV Policy

Introduction 

Bentley Heath Community Centre(“BHCA”) is a registered charity, number 523002.  Closed circuit television (“CCTV”) is installed at BHCA.  Cameras are located at various places on the premises and images from the cameras are recorded digitally and then automatically recorded over after 9 days.  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, hirers, visitors and contractors 
  • to assist Law Enforcement Agencies to carry out their lawful duties. 
  1.  This use of CCTV falls within the scope of The Data Protection Act 2018 and The General Data Protection Regulation 2018.  BHCA complies with the Information Commissioner’s Office (“ICO”) Video surveillance (including guidance for organisations using CCTV) to ensure that it is used responsibly. 

Warning Signs 

CCTV warning signs are clearly and prominently displayed on external walls of the building.   

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 BHCA to position cameras so that their coverage is restricted to the BHCA premises which may include public areas. 

Six cameras are sited as follows (a) front of building (b) rear of building (c) left of building (Bentley Heath park side) (d) right of building (car park) (e) front recessed area. 

Storage and Retention of CCTV images 

Recorded data is stored automatically for up to 9 days on a recorder which is secured within BHCA and to which only the BHCA Facilities Manager has 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 9 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 BHCA Management Committee, all of whom are deemed by The Charity Commission to be legal Trustees of BHCA. 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: 

a)  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; 

b)  A log will be maintained itemising the date, time(s), camera, person copying, person receiving and reason for the disclosure; 

c)  The appropriate disclosure documentation from the Law Enforcement Agencies will be filed for future reference; 

d)  Images must not be forwarded to the media for entertainment purposes or be placed on the internet; 

e)  Images must not be copied in any way, e.g. photographed, downloaded or printed for use other than described in the objectives; 

f)  Images will only be released to the media for identification purposes in liaison with the Law Enforcement Agencies; 

g) The method of disclosing images should be secure to ensure that they are only seen by the intended recipient; and 

h) 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 BHCA bentleyheathhall@gmail.com providing sufficient information to enable the footage relating to them to be identified, i.e. date, time and location.  BHCA 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.  BHCA 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 BHCA’s CCTV system should be directed to BHCA bentleyheathhall@gmail.com BHCA is registered with the Information Commissioners Office (ICO) registration number ZB855832. 

Review 

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

Date: February 2025