CCTV Policy
CCTV POLICY
1. Introduction and Control of the System
The CCTV system covers the Village Hall and surrounding areas and is controlled by Witham St Hughs Parish Council. The CCTV system is operated on behalf of the Parish Council by the Clerk to the Parish Council, or the Clerk’s authorised deputy.
The Parish Council is the Data Controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
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2. Purpose of CCTV
CCTV images are monitored for the purposes of public safety, crime prevention and the detection and prosecution of offenders.
The CCTV system is not used for covert surveillance and is not used to routinely monitor staff, councillors, volunteers, or members of the public, unless access is authorised under an appropriate authority
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3. Lawful Basis and Legal Framework
The Parish Council operates CCTV in accordance with the following legislation and guidance:
- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018
- Human Rights Act 1998 (Article 8 – Right to Private and Family Life)
- Protection of Freedoms Act 2012
- Information Commissioner’s Office (ICO) guidance on CCTV and video surveillance
The lawful basis for processing personal data captured by CCTV is the Parish Council’s legitimate interests in the prevention and detection of crime, safeguarding the public, and protecting Council property and assets.
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4. Retention of Images
The images are retained for a 30 day period. This is a reasonable period for any incident that may have occurred within the range of the cameras to be brought to the attention of those responsible for the system.
Images are automatically deleted after this period unless required for an active investigation, insurance claim, or legal proceedings.
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5. Signage
CCTV notices are displayed on the outside of the Village Hall, in the Parish Office window and by both entrances to the MUGA.
Signage clearly states that CCTV is in operation and identifies Witham St Hughs Parish Council as the system operator, together with contact details for further information.
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6. Maintenance and Monitoring
The Clerk to the Parish Council keeps a maintenance log for the system. A record is kept of the date and time, item number and description, fault or servicing description and confirmation of the date and time the engineer was called and the date and time the fault was rectified.
The log may be used as a check that the cameras and recording equipment are properly maintained and serviced to ensure that clear images are recorded.
The Clerk should check the monitor on opening the office to ensure that all cameras are operational. If they are not, the CCTV maintenance company should be informed immediately.
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7. Access to and Disclosure of CCTV Images
Access and disclosure to third parties: All requests should be recorded and the reasons for allowing or refusing the request should be documented.
Any viewing of a recording should not necessarily require the agreement of the police.
Any enquiry concerning the CCTV system must be actioned by two members of the Parish Council or one Parish Councillor and the Clerk and may involve the Police.
Where viewing of a recording is granted, a record of the following is required:
- Time and date of viewing
- Name and signature of the person authorising the viewing
- Name and address of the person viewing the recording
- Reason for viewing
- Date and time of the recording viewed
- Outcome (if any) of the viewing and finishing time
Viewing should be undertaken with only designated persons having access to the equipment. As owners of the system, the Parish Council reserves the right to have a representative present to view the recording. Owing to the sensitive and confidential nature of some of the matters dealt with in the Village Office, this must be by arrangement with the Parish Council.
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8. Copying and Removal of CCTV Data
Copying and removal of CCTV data, if required by the Police as evidence, is permissible. Details of the Police officer’s name, number and station must be recorded.
Unauthorised use of the system or removal of CCTV data may be a criminal offence.
Members of the public, including representatives of organisations using Parish Council premises, are not permitted to view recordings.
The following may be authorised to remove CCTV data:
- Law enforcement agencies where images would assist with a specific criminal enquiry
- Prosecution agencies
- Relevant legal representatives
Where copying and removal of CCTV data is granted, a record is kept of:
- Date and time of copying and removal
- Name and signature of the person authorising removal
- Name and address (or police number and station) of the person removing the data
- Reason for removal and crime reference number where applicable
The data storage media should be numbered, and the number recorded along with the printed name and signature of the person receiving the material.
The Parish Council Data Controller will retain a duplicate copy for the duration of any investigation. The duplicate copy will be held in accordance with the Parish Council’s data storage and retention policies.
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9. Requests for Access by Individuals (Subject Access Requests)
CCTV footage that identifies individuals constitutes personal data. Individuals have the right to request access to images of themselves under the UK GDPR.
Requests must be made in writing to the Parish Clerk and will be handled in accordance with the Parish Council’s Data Protection Policy and statutory timescales.
Requests may be refused or images redacted where disclosure would prejudice the prevention or detection of crime or infringe the rights of other individuals.
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10. Denial of Access
Where access (for viewing or removal purposes) is denied, a record is kept of:
- Time and date of the request
- Name and address of the person making the request
- Reason for denying the request
- Name of the person dealing with the enquiry
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11. Complaints
Any complaints regarding the use of CCTV should be directed to the Parish Clerk in the first instance.
If a complainant is not satisfied with the Parish Council’s response, they may escalate the matter to the Information Commissioner’s Office (ICO).
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12. Authorised Access
Any two of the following are required to be present when accessing the CCTV system:
- Any two Witham St Hughs Parish Councillors; or
- One Parish Councillor and the Clerk.
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13. Review of Policy
This policy will be reviewed annually or sooner if required by changes in legislation or guidance.
Version Control
- Version 1 – May 2017 – Adopted 17 May 2017
- Version 2 – July 2019 – Operatives amended
- Version 3 – April 2020 – Contact names amended
- Version 4 – April 2021 – Amendment to wording
- Version 5 – April 2024 – Revised policy
- Version 6 – April 2026 – Updated to reflect UK GDPR, ICO guidance, and current NALC aligned best practice