CCTV Policy

Summary

CCTV has become a common feature of our daily lives, supporting and aiding public confidence in its use is essential if its benefits are to be realised and its use is not to become increasingly viewed with suspicion as part of a surveillance society

Anchor Meadow Management Ltd believes that everyone has the right to their own privacy. In addition we believe that there should be no interference by any public body with the exercise of this right except in accordance with the law, for the prevention of disorder or crime, for the protection of health or morals, or for the protection of the rights and freedoms of others.

This policy provides a framework for the planning, installation, management and maintenance of Closed Circuit Television (CCTV) system at Anchor Meadow Health Centre

Anchor Meadow Management Ltd (AMML) places the health, safety and wellbeing of its service users, staff and visitors among its highest priorities and will make every effort to ensure the maintenance of a safe and secure environment throughout the health centre

The provision of proper safety and security arrangements in Health Service premises is essential if a safe environment and protection is to be provided for patients, visitors and employees and for the proper safeguarding of information, equipment and goods.

Purpose

The purpose of the use of Closed Circuit Television is:

1. To promote the safety, confidence and comfort of staff, service users and visitors at all times.
2. To protect staff, service users and visitors by specifically minimising and preventing violence against those providing services.
3. To protect the buildings assets from criminal actions and other inappropriate occurrences

Notices must be visible to the public where CCTV is in place to explain the purpose of the CCTV.

The purpose of this policy is to ensure:

• That the use of CCTV adheres to the principles of relevant legislation
• That any CCTV system is not abused or misused
• That all people (service users, staff, carers and visitors) can be assured of the safeguards put in place.
• That CCTV is correctly and efficiently installed and operated

To ensure the use of Closed Circuit Television (CCTV) adheres to the principles of the Data Protection Act 2018, Human Rights Act 1998, Regulation Investigatory Powers Act 2000 (RIPA) and other relevant legislation. To ensure any CCTV system is not abused or misused and that it is correctly efficiently installed and operated. 

Responsibilities

The security of Anchor Meadow Health Centre and property is a management responsibility. Managers operating such systems will be responsible for overseeing that monitoring of all images is done so in accordance with this policy and that suitable operation, backup, retention, destruction and maintenance of all storage media is conducted in accordance with the written operational procedures

Cameras will not be hidden from view and appropriate steps must be taken, i.e. by signing and displaying posters, to inform the public of the presence of the system and its ownership at all times.

There is no sound recording undertaken from any part of the system

It is the intention to restrict the camera sites to ensure that they do not view areas that are not of interest and are not intended to be used for surveillance, or to view private property.

They will also, on occasions, following a risk assessment undertaken by the Site Manager, be used to enhance the security of service users within patient areas, monitoring communal areas. The particular purpose of all schemes must relate to promoting safer services and, unless specifically identified circumstances, should be in accordance with the following rationale:

• To promote the health, safety and wellbeing of service users, staff and visitors using facilities in Anchor Meadow Health Centre.
• To promote the safety, confidence and comfort of staff, service users at all times
• To protect staff, service users and visitors specifically reducing risks and prevention of violent or aggressive behaviour against those providing and receiving services.
• To support safeguarding of vulnerable service users.
• To assist in the prevention of crime against both persons and property
• To facilitate the identification, apprehension and prosecution of offenders in relation to crime
• To ensure the security of property belonging to AMML and to employees and visitors of the Trust
• All employees are expected to co-operate with Management in the application and implementation of the Trust’s CCTV Policy. Employees are expected to perform their duties in accordance with local procedures, and accept an element of personal responsibility for security and crime prevention. This duty in no way alters their obligations under law to assist the Police in their investigations into any incident

Installation

The CCTV system has been installed by ADT and will be maintained by ADT.

When consideration is being given to the use of CCTV, staff must consider the rationale for its installation. This should include:- 

• To promote the safety, confidence and comfort of staff, service users and visitors at all times.
• To protect staff, service users and visitors specifically minimising and preventing violence and aggression against those providing services
• To protect the Trust assets from criminal actions and other inappropriate occurrences.
• Promoting Safer Services
• Safeguarding vulnerable service users

Local Procedures

• The building manger will keep a comprehensive maintenance log book which records all adjustments, alterations and servicing.
• Image are kept for 30 days and deleted automatically by the NVR (Network Video Recorder)
• If the system records location, time, date these will be periodically checked for accuracy and adjusted accordingly. In cases of alterations to “British Summer Time” the system should as a matter of course be checked for accuracy

Information Sharing

• All staff should be made aware of the procedures for granting subject access requests to recorded images or the viewing capabilities of CCTV
• CCTV images are only available to the Police

Permission to access CCTV footage will be unlikely to be granted in these instances :

• Where the person wishing to view has NO connection with the incident or has no management role relating to an incident.
• Where viewing is purely inappropriate iii. Where the performance of a member of staff not relating to a serious service user incident, assault or crime, is involved.
• Access to the recorded images should be restricted to the Service/Site/Team Manager or designated member of staff. All accessing or viewing of recorded images should ONLY occur within a restricted area and other employees should not be allowed to have access to that area or the images when a viewing is taking place
• If images are to be specifically retained for evidential purposes i.e. following an incident, break-in etc; then these recordings must be retained in a secure place.
• Any incidents in the car park. This data cannot be disclosed due to containing third party data and the system doesn’t have the facility to edit or blur third party data

Requests may be granted and will arise in a number of ways and will be considered on a case by case basis including:

• Requests for a recording, in order to trace incidents that have been reported to the Police
• Immediate action relating to live incidents i.e. immediate pursuit.
• Individual police officers seeking to review tapes/digital images

When a request is made by the Police for disclosure to them of confidential information about users of our service (without service user consent). AMML will require the following information from the Police –

• The purpose for which the information is required, and why it is necessary
• What information is required (must be specific)
• Details of the Act and the particular provision of the Act under which the information is considered to be necessary
• Why it would prejudice the investigation to ask the service user for consent to disclose the information to the Police
• The name, rank, number and signature of the officer making the request

A balancing judgement then needs to be made as to which of our duties is paramount, i.e. the duty of confidence to the service user or the duty to assist the Police when it is in the substantial public interest to do so

If disclosure is appropriate then the building manager should be careful to disclose only the minimum information necessary to satisfy the Police’s expressed purpose

If copies are required of the footage on tape/disc, two copies must be made. One copy is to be retained by AMML and the other given to the Police/Fraud Department. The event will be noted in the log book the details and signature of the recipient obtained

Monitors displaying images in areas in which individuals would have an expectation of privacy must NOT be viewed by anyone other than the authorised employee of the user of the equipment. 

This policy has been written by the facilities Manager for Anchor Meadow Management Ltd and approved by Anchor Meadow Management Ltd directors