CCTV, Webcam and Body Worn Video Camera Operation
References:
A. Surveillance Camera Code of Practice 2013
B. General Data Protection Regulations 2018
C. Information Commissioners Office guidelines for CCTV
1. Introduction
1.1 - This policy has been created to set out the purpose, operation and responsibilities of Closed Circuit Television (CCTV) surveillance, bodyworn camera surveillance and webcam footage undertaken by Lyme Regis Town Council (LRTC) and is based on the twelve guiding principles of the Surveillance Camera Code of Practice 2013 and in line with GDPR legislation. LRTC takes its CCTV and GDPR responsibilities seriously and this policy sets out the rules for the operation of CCTV by this council. Two independent CCTV consultants were consulted during the project in 2018 to confirm feasibility, operational requirement and privacy impact assessments.
2. Background
2.1 Lyme Regis Town Council installed a CCTV system in 2012 (upgraded in 2019) which covered the market area, performance area, in front of the two shops either side of the Jubilee Pavilion and the walkway above and behind the Jubilee Pavilion. Also in 2012 the Cobb and Marine Theatre webcams were installed and the council registered with the Information Commissioners Office. In 2019 this system was upgraded and an additional camera was installed on the Candles on the Cobb pavilion and a camera was sited above the front door of the council office due to damage caused to the Grade II* listed Guildhall by passing traffic. LRTC enforcement officers began wearing body worn video cameras in 2021.
2.2 A further CCTV project to install cameras on Broad Street, at Monmouth car park, in the Langmoor and Lister gardens, at the skatepark, and upgrade the existing cameras, linking them all to the Dorset Council CCTV Control Room in Dorchester was due for completion in 2024. A further risk assessment and operational requirement documents will be required.
3. Twelve Guiding Principles (Reference A)
3.1 Specified Purpose. Legitimate Aim. Pressing Need.
Lyme Regis Town Council commissioned a new operational requirement document in 2018 through an independent specialist consultant. The purpose of the system is threefold. Prevention and deterrence of anti-social behaviour. Prevention and deterrence of nuisance incidents. Reassurance for members of the community and visitors. Prevention of Crime.
3.2 Individuals Privacy. Regular Reviews.
Lyme Regis Town Council commissioned a privacy impact assessment in 2018 through an independent specialist consultant. The CCTV system has a privacy screening facility which obscures images of private property in the field of view of the cameras. The CCTV policy will be reviewed every two years.
3.3 Transparency. Contact Points. Access to Information.
Lyme Regis Town Council displays relevant legally compliant signage in all the areas CCTV is in use, which details how to contact Lyme Regis Town Council.
3.4 Clear Roles and Responsibilities. Good Governance arrangements.
Only two Lyme Regis Town Council officers are authorised to review camera footage; the town clerk and the operations manager. The town clerk, as duty holder, is responsible for the CCTV system and for day-to-day operations the operations manager reviews footage as necessary.
3.5 Must have Rules and Policy. Communicated to all users.
Lyme Regis Town Council has written this policy to detail compliance with these twelve principles.
3.6 Policy in place on information. Information deleted when not needed.
Lyme Regis Town Council has a Data Protection policy in place, complies with GDPR and is registered with the Information Commissioner’s Office. CCTV camera footage is automatically overwritten every 30 days. All footage downloaded or stored is deleted when no longer needed. Footage will be released on request to the police. Footage will only be released to private individuals if the footage requested shows no other person.
3.7 Restricted Access. Clearly defined rules. Specified purpose or law enforcement.
Within Lyme Regis Town Council only the town clerk and the operations manager have access to the footage.
3.8 Consider approved standards. Maintain standards.
Lyme Regis Town Council is committed to meet the standards set out in these guidelines and GDPR. This policy is regularly reviewed. Lyme Regis Town Council does not actively monitor the live footage and therefore does not require a licence from the Security Industry Authority (SIA) for Public Space Surveillance. When the system is linked to the Dorchester Control Room those personnel monitoring are licenced to do so.
3.9 Safeguards. Secure against unauthorised access.
Access points in various locations for the footage are physically and/or electronically secure. Only the town clerk and the operations manager are authorised to review footage.
3.10 Effective review and Audit mechanism. Ensure legal compliance. Regular reports.
This policy and the requirement for CCTV is reviewed every two years.
3.11 Evidential value. Legitimate Aim.
Footage requested by the police will be released.
3.12 Supporting information. Accurate. Relevant
Two independent consultants delivered a risk assessment,operational requirement and privacy impact assessment for the CCTV system in 2018. These are reviewed every two years in line with this policy.
4. Review
4.1 This policy and associated documents will be reviewed every two years or sooner if there are changes in legislation or best practice. The next review is due in July 2026.
Implementation Date: 17 July 2024
Review Date: July 2026
John Wright
Town clerk