CCTV policy and codes of practice from Cheltenham Borough Council
Source: data.gov.uk (2016-07-06)

Cheltenham Borough Council CCTV policy and codes of practice for its buildings.

Code of Practice for CCTV surveillance 
system 
located at 
The Wilson, Cheltenham Art Gallery & 
Museum  
Cheltenham 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

 
2
 
 
 
1.1. 
Management of the scheme 
 
1.2. 
A risk assessment has been carried out to assess the need and requirements of 
CCTV systems at The Wilson. This risk assessment is reviewed on an annual 
basis by the Building & Security Officer. 
 
1.3. 
43 Cameras covering all entrance / exits, public areas and cash handling areas 
of the Wilson have been sited to capture images which are relevant to the 
identified purposes of the installation. 
 
1.4. 
The scheme will be operated using overt cameras which are sited so as not to 
intrude unreasonably on members of the public or staff. The CCTV scheme 
seeks to comply with both the Data Protection Act 1988 and the Commissioners 
code of practice.  
 
1.5. 
The owners, users and any visitors to the control, monitoring and recording 
facilities will be required to sign a formal confidentiality declaration. They will 
treat any viewed and/or written material as being strictly confidential and will 
undertake not to divulge it to any other person. 
 
1.6. 
Those who have authorised access (Building & Security Officer, Customer & 
Visitor Service manager, Collections & Engagement Manager, Services 
Managers and others as appropriate) are aware of the purpose(s) for which the 
scheme has been established and that the CCTV equipment is only used to 
achieve the identified purposes which are: 
 
(a) To contribute to the provision of a safe and secure environment for the benefit 
of those employed, visiting or using The Wilson. 
(b) To protect the Council’s building and assets  
(d) To assist in identifying, apprehending and prosecuting offenders  
(e) To assist in the general day to day management of the facility  
 
1.7. 
Scheme and Signage 
 
1.8. 
This scheme aims to provide surveillance of the public areas within The Wilson, 
Cheltenham, in order to fulfil the purposes of the scheme as listed above. The 
area protected by CCTV will be indicated by the presence of signs. The signs 
will be placed so that the public are aware that they are entering a zone which is 
covered by surveillance equipment. The signs will state the Cheltenham 
Borough Council as being the organisation responsible for the scheme , the 
purposes of the scheme (Crime prevention and public safety) and a contact 
telephone number xx-xxxx-xxxx) 
 
1.9. 
Data will not be held for longer than necessary and disposal of information will 
be regulated by the Wilson Service Manager. The disposal of records happens 
as part of a managed process and is adequately documented within the service 
document retention schedule 

 
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1.10. 
Point of contact 
 
1.11. 
All enquiries for further information about the system should be addressed to: 
 
The Customer Relations Manager 
Cheltenham Borough Council 
Promenade 
Cheltenham 
GL50 9SA 
 
Tel: xx-xxxx-xxxx 
Email: xxx@xxx.xx  
 
 
1.12. 
Release of information (subject access) 
 
1.13. 
Individuals may request to view information concerning them held on record in 
accordance with the Data Protection Act 1998. Any request from an individual for 
the disclosure of personal data which he/she believes is recorded by virtue of the 
system will be directed in the first instance to the Customer Relations Manager. 
They will be required to request any information with reasons in writing and must 
be able to satisfactorily prove their identity and provide sufficient information to 
enable the data to be located. 
  
1.14. 
Information will be released if the reasons are deemed acceptable, the request 
and release of information complies with current legislation and on condition that 
the information is not used for any other purpose than that specified.  
 
1.15. 
The information may not be released if disclosure to the data subject would 
prejudice the criminal enquiries or criminal proceedings. 
 
 
1.16. 
Information on how to obtain an application form can be found on Cheltenham 
Borough Council web site www.cheltenham.gov.uk or by writing to Customer 
Relations. 
 
 
1.17. 
Access to data by third parties and statutory prosecuting bodies 
 
1.18. 
Access to images by third parties will only be allowed in limited and prescribed 
circumstances. Disclosure will be limited to the following:- 
 
• Law enforcement agencies where the images recorded would assist in a 
specific criminal enquiry 
• Prosecution agencies 
• Legal representatives. 
 
1.19. 
The media, where it is assessed by the Police that the public’s assistance is 
needed in order to assist in the identification of victim, witness or perpetrator in 
relation to a criminal incident. As part of that assessment the wishes of the victim 
of an incident should be taken into account. 
 
1.20. 
The policy is to assist statutory prosecuting bodies such as the Police, and 
statutory authorities with powers to prosecute and facilitate the legitimate use of 
the information derived from the scheme.  
 
 

 
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1.21. 
Statutory bodies may have access to information permitted for disclosure on 
application to the owner of the scheme Building & Security Officer or Customer & 
Visitor Service Manager, Collections & Engagement Manager these applications 
must be in writing and provide the reasons and statement of purpose, according 
with the objectives of the scheme and conditions outlined above. 
 
1.22. 
The information will be treated as evidential exhibits. 
 
 
1.23. 
System Registration  
 
1.24. 
All Council systems are registered with the Information Commissioner‘s Office 
(ICO)  
 
 
1.25. 
Accountability 
 
1.26. 
Cheltenham Borough Council  supports the principle that the community at large 
should be satisfied that the Public CCTV systems are being used, managed and 
controlled in a responsible and accountable manner and that in order to meet 
this objective there will be independent assessment and scrutiny. 
 
1.27. 
A member of the public wishing to make a complaint about the system may do 
so through the Cheltenham Borough Council complaints procedure and by 
contacting The Customer Relations Manager. 
 
1.28. 
A copy of the Code of Practice will be made available to anyone on request by 
contacting the CCTV system owner (Building & Security Officer), Customer & 
Visitor Service Manager, Collections & Engagement Manager, Service manager.  
 
1.29. 
CCTV Control Management And Operation 
 
1.30. 
Access to the monitoring and recording area is restricted. 
 
1.31. 
Only those persons with a legitimate purpose will be permitted access to the 
Control, Recording and Monitoring system. 
 
 
1.32. 
The System Manager (Security and Buildings Officer) is authorised to determine 
who has access to the monitoring area. This will normally be: 
 
• Authorised Personnel (including Council Representatives) 
• Police officers requiring to view a particular incident, or intelligence or 
evidential purposes. These visits will take place by prior appointment. 
• Engineers and cleaning staff (These people will receive supervision 
throughout their visit) 
 
1.33. 
Inspectors/Auditors may visit the monitoring and recording facility without prior 
appointment. 
 
1.34. 
Organised visits by authorised persons are to be conducted in controlled 
circumstances. All visitors to the monitoring and recording area, including Police 
Officers, will be required to sign a visitors log and a declaration of confidentiality. 
(ACTION) 
 
 
 
 

 
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1.35. 
Observation and recording of incidents 
 
1.36. 
Recording will be throughout a 24 hour period. The system will be monitored on 
the basis of operational necessity. Images will be held for approximately 7 days 
and they will then be over recorded. 
 
1.37. 
Privacy And Disclosure Issues 
 
1.38. 
Cameras will not be used to infringe individual’s rights of privacy. 
 
1.39. 
All employees will be aware of the restrictions set out in this Code of  Practice in 
relation to access to, and disclosure of, recorded images 
 
1.40. 
Images not required for the purposes of the scheme will not be retained longer 
than necessary 
 
1.41. 
The Security and Building Manager  will only disclose to third parties who intend 
processing the data for purposes which are deemed compatible with the 
objectives of the CCTV system 
 
1.42. 
Monitors displaying images from areas in which individuals would have an 
expectation of privacy will not be viewed by anyone other than authorised 
persons. 
 
1.43. 
Recorded material will only be used for the purposes defined in the objectives of 
this policy 
 
1.44. 
Access to recorded material will be in accordance with policy and procedures 
 
1.45. 
Information will not be disclosed for commercial purposes and entertainment 
purposes 
 
1.46. 
All access to the medium on which the images are recorded will be documented  
 
1.47. 
Access to recorded images will be restricted to those staff who need to have 
access in order to achieve the purpose(s) of using the equipment 
 
 
1.48. 
Viewing of the recorded images should take place in a restricted area.  
 
 
1.49. 
Access to recorded images 
 
1.50. 
Access to recorded images will be restricted to the Building & Security Officer or 
other designated member of staff who will decide whether to allow requests for 
access by third parties in accordance with the disclosure policy. Those requests 
must be in writing.  
 
1.51. 
Monitoring employees  check 
 
1.52. 
As the CCTV is located in a workplace it inevitably captures pictures of 
employees, even if they are not the main subject of surveillance. The purpose of 
the CCTV is not to monitor the amount of work done nor compliance with 
company procedures. However, if there is a breach in Council procedures then 
CCTV footage can be used for reference purposes. 
 
1.53. 
The overt monitoring of any employee using CCTV can only be done with the 
consent of the Director and after consultation with HR GOSS 

 
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1.54. 
The covert monitoring of employees must not take place unless it has been 
specifically authorised in advance using the codes of practice, guidance and 
procedures under The Regulation of Investigatory Powers Act 2000 . There is no 
covert monitoring that takes place on this site. 
 
 
 
1.55. 
Recorded Material Management 
 
1.56. 
Images that are not required for the purpose(s) for which the equipment is being 
used will not be retained for longer than is necessary. The detail as to how long 
data should be held will be defined within the service retention schedule. While 
images are retained access to and security of the images will be controlled in 
accordance with the requirements of the Data Protection Act.  
 
1.57. 
Recorded material should be of high quality. In order for recorded material to be 
admissible in evidence total integrity and continuity must be maintained at all 
times. 
 
1.58. 
Security measures will be taken to prevent unauthorised access to, alteration, 
disclosure, accidental loss or destruction of recorded material. 
 
1.59. 
Recorded material will not be released to organisations outside the ownership of 
the system other than for training purposes or under the guidelines referred to 
previously. 
 
1.60. 
Images retained for evidential purposes will be retained in a secure place where 
access is controlled – safe in the strong room. 
 
1.61. 
The system records features such as the location of the camera and/or date and 
time reference. 
 
1.62. 
In order to ensure that clear images are recorded at all times the equipment for 
making recordings will be maintained in good working order with regular 
servicing in accordance with the manufacturer’s instructions. 
 
1.63. 
Recorded Material Register 
 
1.64. 
There will be a register documenting the access to recorded media.  
 
1.65. 
Documentation 
 
1.66. 
Log books must be sequential in order that pages or entries cannot be removed 
and full and accurate records kept. 
   
 
1.67. 
Administrative documents 
 
The following shall be maintained: 
 
• Media tracking register 
• occurrence/incident book 
• visitors register 
• maintenance of equipment, whether routine or breakdown 
• list of installed equipment

 
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Action Plan 
 
Task 
Action 
Completed 
Risk assessment to be 
documented 
Lance Sperry 
 
Disposal of Records 
Copies of CDs given to 
Police etc? 
Design a disposal of 
records log sheet for CCTV 
JH 
 
Query system registration – 
look as though the existing 
registration might need 
amending 
Contact Karen Watson 
 
Visitors log to control room 
and CCTV 
?? 
 
Training notes on using the 
system to be created 
?? 
 
Training to be given to JH 
and poss TM 
?? 
 
Manual to be produced  
With fault logs, maintenance 
agreements, list of installed 
equipment 
?? 
 
Revisit subject access 
request 
?? 
 
 
 
 
Check interpretation of 
employees monitoring 
?? 
 
Publish