Introduction

This policy is to explain how 1^st Wootton Bassett Scout Group uses closed circuit television (CCTV) images to provide a safe and secure environment at the Group’s premises, for members, volunteers, visitors, contractors, suppliers, and to protect the Group’s property.

It also sets out the use and management of the CCTV equipment and video images in compliance with the Data Protection Act 2018 and the Information Commissioner’s Office CCTV Code of Practice.

The Group’s CCTV facility records images and audio.

Purpose

The purposes of using CCTV systems at 1^st Wootton Bassett Scout premises include:

• To assist in the prevention or detection of crime or equivalent malpractice.

• To assist in the identification and prosecution of offenders.

• To monitor the security of the Group’s premises.

1^st Wootton Bassett Scout Group seeks to operate its CCTV system in a manner that is consistent with respect for the individual’s privacy.

Implementation

The Trustee Board is responsible for the implementation of and compliance with this policy and the operation of the CCTV system.

Camera Locations

All cameras are clearly visible and are located at strategic points on the outside of the headquarters building. The cameras cover the grounds and car park, and are positioned to not focus on public areas outside of the premises or use privacy masking where more appropriate.

Appropriate signs are prominently displayed making users and visitors aware they are entering an area covered by CCTV.

1^st Wootton Bassett Scout Group does not utilise hidden CCTV of any kind.

System interface

The CCTV cameras are hard wired and connected to a dedicated on-premise Network Video Recorder (NVR). The cameras are wired directly into the NVR. The data between the cameras and NVR is encrypted and requires a password to unencrypt and view the camera feed. Access to recorded images is restricted to the authorised operators of the CCTV system.

Operators of the system require an account name and password to access the cameras and NVR management interface and/or images.

Live footage can also be viewed remotely by authorised persons.

Recording and Retention of Images

The images that are filmed are recorded centrally and held in a secure location. Images are recorded in real-time (24 hours a day throughout the year). The cameras installed provide images that are of suitable quality for the specified purposes for which they are installed.

Maintenance checks of the equipment are undertaken on a regular basis ensuring that the images remain fit for purpose and that the date and time stamp recorded on the images is accurate.

Unless required for evidential purposes, the investigation of an offence or as required by law, CCTV images will be retained for no longer than 30 days from the date of recording. Images will be automatically overwritten after this point.

Once a hard drive has reached the end of its use, it will be erased prior to disposal.

Images that are shared with Law enforcement will be retained in line with that organisation’s retention policy.

Audio

The use of audio is only used to assist with the identification and prosecution of offenders. Although audio is captured this is considered collateral intrusion. The CCTV is not routinely re-played unless there has been a request for access.

The audio is part of the image recording and is therefore managed and overwritten as part of the video image files.

Access to, and disclosure of Images

Access to, and disclosure of, images recorded on CCTV is restricted. Only authorised personnel can view recorded footage. When viewing recordings, personnel should ensure that it cannot be viewed by unauthorised persons.

Disclosure of images to third parties will only be made in accordance with the purposes for which the system is used and will be limited to:

• The police and other law enforcement agencies, where the images recorded could assist in the prevention or detection of a crime or the identification and prosecution of an offender or the identification of a victim or witness.

• Prosecution agencies, such as the Crown Prosecution Service.

• Relevant legal representatives.

• Individuals whose images have been recorded and retained (unless disclosure would prejudice the prevention or detection of crime or the apprehension or prosecution of offenders).

Authorisation for disclosure of images must be sought from two members of the Trustee Board and good practice would suggest one member to be the Group Scout Leader (GSL), although it is recognised this is not always possible or appropriate.

All requests for disclosure and access to images will be documented, including the date of the disclosure, to whom the images have been provided and the reasons why they are required. If disclosure is denied, the reason will be recorded.

Individuals’ access rights

Requests by individual data subjects for images relating to themselves “Subject Access Request” should be submitted in writing to the Trustee Board together with satisfactory proof of identification to cctv@woottonbassettscouts.org.uk.

In order to locate the images, sufficient detail must be provided by the data subject in order to allow the relevant images to be located and the data subject to be identified.

The Trustee Board will respond to the request within one month of receiving the request in accordance with data protection legislation.

Where the Trustee Board is unable to comply with a Subject Access Request without disclosing the personal data of another individual who is identified or identifiable from that information, it is not obliged to comply with the request unless satisfied that the individual has provided their express consent to the disclosure, or if it is reasonable, having regard to the circumstances, to comply without the consent of the individual.

ICO Registration

The group has registered with the Information Commissioners Office (ICO).

Complaints procedure

Any complaints about the operation of the Group’s CCTV system should be addressed to the Trustee Board via cctv@woottonbassettscouts.org.uk.