Gosport Borough Council CCTV Policy

The purpose of this policy is to regulate the management and operation of the Closed Circuit Television (CCTV) System Gosport Borough Council (the Council). It also serves as a notice and a guide to data subjects (including visitors, staff, volunteers and councillors of the Council) regarding their rights in relation to personal data recorded via the CCTV system (the System).

The System is administered and managed by the Council, who act as the Data Controller. This policy will be subject to review from time to time, and should be read with reference to the Council's Data Protection Policy. For further guidance, please review the Information Commissioner's CCTV Code of Practice (accessible here link).

All fixed cameras are in plain sight on the Council premises and the Council does not routinely use CCTV for covert monitoring or monitoring of private property outside the Council grounds. 

The Council 's purposes of using the CCTV system are set out below and, having fully considered the privacy rights of individuals, the Council believes these purposes are all in its legitimate interests. Data captured for the purposes below will not be used for any commercial purpose.

Objectives of the System

  • To protect staff, volunteers, visitors and members of the public with regard to their personal safety.
  • To support the management of safeguarding on Council grounds.
  • To protect the Council buildings and equipment, and the personal property of, staff, volunteers, visitors and members of the public.
  • To support the police and community in preventing and detecting crime, and assist in the identification and apprehension of offenders.
  • To provide evidence of damage or loss to the Council's insurance company.

Positioning

  • Locations have been selected, that the Council reasonably believes require monitoring to address the stated objectives.
  • Adequate signage has been placed in prominent positions to inform staff and visitors that they are entering a monitored area.
  • No images of public spaces will be captured except to a limited extent at Town Hall entrances.

Maintenance

  • The CCTV System will be operational 24 hours a day, every day of the year. 
  • The IT Manager will check and confirm that the System is properly recording and that cameras are functioning correctly, on a regular basis.
  • The System will be checked and (to the extent necessary) serviced regularly.

Supervision of the System

  • Employees authorised by the Council to conduct routine supervision of the System is limited to IT technicians.
  • Images will be viewed and/or monitored in a suitably secure and private area to minimise the likelihood of or opportunity for access to unauthorised persons.

Storage of Data

  • The day-to-day management of images will be the responsibility of the IT Manager, or such suitable person as the IT Manager shall appoint in their absence.
  • Images will be stored for 4 weeks, and automatically over-written unless the Council considers it reasonably necessary for the pursuit of the objectives outlined above, or if lawfully required by an appropriate third party such as the police.
  • Where such data is retained, it will be retained in accordance with the Act and our Data Protection Policy. Information including the date, time and length of the recording, as well as the locations covered and groups or individuals recorded will be recorded in the system log book.

Access to Images

  • Access to stored CCTV images will only be given to authorised persons, under the supervision of the IT Manager, in pursuance of the above objectives (or if there is some other overriding and lawful reason to grant such access).  
  • Individuals also have the right to access personal data the Council holds on them (please see the Data Protection Policy), including information held on the System, if it has been kept. The Council will require specific details including at least to time, date and camera location before it can properly respond to any such requests. This right is subject to certain exemptions from access, including in some circumstances where others are identifiable.
  • The IT Manager must satisfy themselves of the identity of any person wishing to view stored images or access the system and the legitimacy of the request. The following are examples when the IT Manager may authorise access to CCTV images:
  • Where required to do so by the Police or some relevant statutory authority;
  • To make a report regarding suspected criminal behaviour;
  • To data subjects (or their legal representatives) pursuant to an access request under the Act; 
  • To the Council 's insurance company where required in order to pursue a claim for loss or damage to insured property; or
  • In any other circumstances required under law or regulation.
  • Where images are disclosed as detailed above a record will be made in the system log book including the time of access, the reason for viewing the images, the details of images viewed and a crime incident number (if applicable).
  • Where images are provided to third parties under the above rights, wherever practicable steps will be taken to obscure images of non-relevant individuals.

Complaints and queries

If you have any further questions about the Council 's CCTV system, or its use of CCTV, or requests for copies, should be referred to The Data Protection Officer. foi@gosport.gov.uk