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St. Peter’s N.S.
CCTV POLICY
INTRODUCTION
Closed Circuit Television Systems (CCTVS) are installed in St. Peter’s N.S.
Where systems are already in operation, the Board of Management reserves the right to amend this policy but will endeavour to review it in consultation with staff and the Parents’ Association.
PURPOSE OF POLICY
The purpose of this policy is to regulate the use of Closed Circuit Television and its associated technology in the monitoring of both the internal and external environs of the premises under the remit of the BOM of St. Peter’s N.S.
CCTV systems are installed (both internally and externally) in the premises for the purpose of enhancing security of the building and its associated equipment as well as creating a mindfulness among the occupants, at any one time, that a surveillance security system is in operation within and/or in the external environs of the premises during both the daylight and night hours each day. CCTV surveillance at the School is intended for the purposes of:
1. protecting the school buildings and school assets, both during and after school hours;
2. promoting the health and safety of staff, pupils and visitors;(including resolving breaches of the Code of Behaviour which includes bullying)
3. preventing bullying;
4. reducing the incidence of crime and anti-
5. supporting the Gardaí in a bid to deter and detect crime;
6. assisting in identifying, apprehending and prosecuting offenders; and
SCOPE
This policy relates directly to the location and use of CCTV and the monitoring, recording and subsequent use of such recorded material. Where classes and activities are carried out in rented premises, the St. Peter’s N.S. will ensure that CCTV systems, where installed, are operated only in a way that is compatible with the provisions of this policy.
GENERAL PRINCIPLES
The BOM of St. Peter’s N.S., as the corporate body has a statutory responsibility for the protection of its property, equipment and other plant as well providing a sense of security to its employees, pupils and invitees to its premises. The BOM of St. Peter’s N.S. owes a duty of care under the provisions of Safety, Health and Welfare at Work Act 2005 and associated legislation and utilises CCTV systems and their associated monitoring and recording equipment as an added mode of security and surveillance for the purpose of enhancing the quality of life of the school community by integrating the best practices governing the public and private surveillance of its premises.
The use of the CCTV system will be conducted in a professional, ethical and legal manner and any diversion of the use of CCTV security technologies for other purposes is prohibited by this policy e.g. CCTV will not be used for monitoring employee performance.
Information obtained through the CCTV system may only be released when authorised by the Principal, following consultation with the Chairperson of the BoM. Any requests for CCTV recordings/images from An Garda Síochána will be fully recorded and legal advice from the Data Protection Commissioner/legal advice will be sought if any such request is made. (See “Access” below)
CCTV monitoring of public areas for security purposes will be conducted in a manner consistent with all existing policies adopted by the school, including the provisions set down in equality and other educational and related legislation.
This policy prohibits monitoring based on the characteristics and classifications contained in equality and other related legislation e.g. race, gender, sexual orientation, national origin, disability, etc.
Video monitoring of public areas for security purposes within school premises is limited to uses that do not violate the individual’s reasonable expectation to privacy.
Information obtained in violation of this policy may not be used in a disciplinary proceeding against an employee of the school or a pupil attending this school.
All CCTV systems and associated equipment will be required to be compliant with this policy following its adoption by the BOM of St. Peter’s N.S. Recognisable images captured by CCTV systems are personal data. They are therefore subject to the provisions of the Data Protection Acts 1988 to 2018.
JUSTIFICATION FOR USE OF CCTV
Data Protection legislation requires that data is “adequate, relevant and not excessive” for the purpose for which it is collected. This means that the BOM of St. Peter’s N.S. needs to be able to justify the obtaining and use of personal data by means of a CCTV system. The use of CCTV to control the perimeter of the school buildings for security purposes has been deemed to be justified by the BoM. The system is intended to capture images of intruders or of individuals damaging property or removing goods without authorisation.
CCTV systems will not be used to monitor normal teacher/pupil classroom activity in school.
In other areas of the school where CCTV has been installed, e.g. foyer,hallways, stairwells, the Principal has demonstrated that there is a proven risk to security and/or health & safety and that the installation of CCTV is proportionate in addressing such issues that have arisen prior to the installation of the system.
LOCATION OF CAMERAS
The location of cameras is a key consideration. Use of CCTV to monitor areas where individuals would have a reasonable expectation of privacy would be difficult to justify. The BOM of St. Peter’s N.S. has endeavoured to select locations for the installation of CCTCV cameras which are least intrusive to protect the privacy of individuals. Cameras placed so as to record external areas are positioned in such a way as to prevent or minimise recording of passers-
CCTV Video Monitoring and Recording of Public Areas in St. Peter’s N.S. may include the following:
Protection of school buildings and property: The building’s perimeter, entrances and exits, hallways and corridors, storage areas, foyer/receiving areas for goods/services
Monitoring of Access Control Systems: Monitor and record restricted access areas at entrances to buildings and other areas.
Verification of Security Alarms: Intrusion alarms, exit door controls, external alarms
Video Patrol of Public Areas: Parking areas, Main entrance/exit gates, Traffic Control
Criminal Investigations (carried out by An Garda Síochána): Robbery, burglary and theft surveillance
St. Peter’s N.S. will not engage in covert surveillance.
Where An Garda Síochána requests to carry out covert surveillance on school premises, such covert surveillance may require the consent of a judge. Accordingly, any such request made by An Garda Síochána will be requested in writing and the school will seek Data Protection Commissioner/legal advice.
NOTIFICATION – SIGNAGE
The Principal will provide a copy of this CCTV Policy on request to staff, pupils, parents and visitors to the school. This policy describes the purpose and location of CCTV monitoring, a contact number for those wishing to discuss CCTV monitoring and guidelines for its use. The location of CCTV cameras will also be indicated to the BoM.
Adequate signage will be placed at each location in which a CCTV camera(s) is sited to indicate that CCTV is in operation. Adequate signage will also be prominently displayed at the entrance to St. Peter’s N.S.’ property. Signage shall include the name and contact details of the data controller as well as the specific purpose(s) for which the CCTV camera is in place in each location
WARNING
These premises are protected by Closed Circuit Television.
Images are recorded for the purpose of Health and Safety, Crime-
This system is controlled by the BoM of St. Peter’s N.S.
and operated by APM Securities
For more information contact 0949360316
24 HOUR VIDEO RECORDING
at entrances to premises i.e. external doors, school gates
reception area
at or close to each internal camera
STORAGE & RETENTION
Data Protection legislation states that data “shall not be kept for longer than is necessary for” the purposes for which it was obtained. A data controller needs to be able to justify this retention period. For a normal CCTV security system, it would be difficult to justify retention beyond a month (28 days), except where the images identify an issue – such as a break-
Accordingly, the images captured by the CCTV system will be retained for a maximum of 28 days, except where the image identifies an issue and is retained specifically in the context of an investigation/prosecution of that issue.
The images/recordings will be stored in a secure environment with a log of access kept. Access will be restricted to authorised personnel. Supervising the access and maintenance of the CCTV System is the responsibility of the BoM. The Principal may delegate the administration of the CCTV System to another staff member. In certain circumstances, the recordings may also be viewed by other individuals in order to achieve the objectives set out above (such individuals may include the Gardaí, the Deputy Principal, other members of the teaching staff, representatives of the Department of Education and Skills, representatives of the HSE and/or the parent of a
DVDs/portable storage devices will be stored in a secure environment. Access will be restricted to authorised personnel. The area will be locked when not occupied by authorised personnel. A log of access to images will be maintained.
Access to the CCTV system and stored images will be restricted to authorised personnel only i.e. the Principal of the school/The chairperson of the B.O.M..
In relevant circumstances, CCTV footage may be accessed:
1. By An Garda Síochána where St. Peter’s N.S. (or its agents) are required by law to make a report regarding the commission of a suspected crime; or
2. Following a request by An Garda Síochána when a crime or suspected crime has taken place and/or when it is suspected that illegal/anti-
3. By the HSE and/or by any other statutory body charged with child safeguarding; or
4. To assist the Principal in establishing facts in cases of unacceptable pupil behaviour, in which case the parents/guardians will be informed; or
5. To data subjects (or their legal representatives), pursuant to an access request where the time, date and location of the recordings is furnished to St. Peter’s N.S., or
6. To individuals (or their legal representatives) subject to a court order
Requests by An Garda Síochána: Information obtained through video monitoring will only be released when authorised by the Principal following consultation with the Chairperson of the BoM. If An Garda Síochána request CCTV images for a specific investigation, An Garda Síochána may require a warrant and accordingly any such request made by An Garda Síochána should be made in writing and the school shall immediately seek legal advice.
Access requests: On written request, any person whose image has been recorded has a right to be given a copy of the information recorded which relates to them, provided always that such an image/recording exists i.e. has not been deleted and provided also that an exemption/prohibition does not apply to the release. Where the image/recording identifies another individual, those images may only be released where they can be redacted/anonymised so that the other person is not identified or identifiable. To exercise their right of access, a data subject must make an application in writing to the school Principal. The school must respond within 1 month.
Access requests can be made to the following: The Board of Management/The Principal, St. Peter’s N.S.,Snugboro, Castlebar, Co. Mayo. A person should provide all the necessary information to assist St. Peter’s N.S. in locating the CCTV recorded data, such as the date, time and location of the recording. If the image is of such poor quality as not to clearly identify an individual, that image may not be considered to be personal data and may not be handed over by the school.
In giving a person a copy of their data, the school may provide a still/series of still pictures, a tape or a disk with relevant images. However, other images of other individuals will be obscured before the data is released.
RESPONSIBILITIES
The Principal on behalf of the BOM will:
1. Ensure that the use of CCTV systems is implemented in accordance with the policy set down by the BOM of St. Peter’s N.S.
2. Oversee and co-
3. Ensure that all existing CCTV monitoring systems will be evaluated for compliance with this policy.
4. Ensure that the CCTV monitoring at St. Peter’s N.S is consistent with the highest standards and protections.
5. Review camera locations and be responsible for the release of any information or recorded CCTV materials stored in compliance with this policy.
6. Maintain a record of access (e.g. an access log) to or the release of tapes or any material recorded or stored in the system.
7. Ensure that monitoring recorded tapes are not duplicated for release unless in the event of a Data Access Request.(See terms mentioned above)
8. Ensure that the perimeter of view from fixed location cameras conforms to this policy both internally and externally.
9. Approve the location of temporary cameras to be used during special events that have particular security requirements and ensure their withdrawal following such events. NOTE: [Temporary cameras do not include mobile video equipment or hidden surveillance cameras used for authorised criminal investigations by An Garda Síochána]
10. Give consideration to both pupils’ and staff feedback and/or complaints regarding possible invasion of privacy or confidentiality due to the location of a particular CCTV camera or associated equipment
11. Ensure that all areas being monitored are not in breach of an enhanced expectation of the privacy of individuals within the school and be mindful that no such infringement is likely to take place
12. Co-
13. Ensure that external cameras are non-
14. Ensure that monitoring DVDs/digital recordings are stored in a secure place with access by authorised personnel only
15. Ensure that images recorded on DVDs/digital recordings are stored for a period not longer than 28 days and are then erased unless required as part of a criminal investigation or court proceedings (criminal or civil) or other bona fide use as approved by the BoM.
16. Ensure that when a zoom facility on a camera is being used, there is a second person present with the operator of the camera to guarantee that there is no unwarranted invasion of privacy.
17. Ensure that camera control is solely to monitor suspicious behaviour, criminal damage etc. and not to monitor individual characteristics.
18. Ensure that camera control is not infringing an individual’s reasonable expectation of privacy in public areas.
19. Ensure that where An Garda Síochána request to set up mobile video equipment for criminal investigations, Data Protection Commissioner/legal advice has been obtained and such activities have the approval of the Chairperson of the Board.
SECURITY COMPANIES
The school CCTV system is controlled by a security company contracted by the school BoM. The following applies:
The school has a written contract with the security company in place known as a Third Party Service Agreement which details the areas to be monitored, how long data is to be stored, what the security company may do with the data, what security standards should be in place and what verification procedures apply. The written contract also states that the security company will give the school all reasonable assistance to deal with any subject access request made under Data Protection legislation which may be received by the school within the statutory time-
Security companies that place and operate cameras on behalf of clients are considered to be ‘Data Processors’. As data processors, they operate under the instruction of data controllers (their clients i.e. School BoM). Data Protection legislation places a number of obligations on data processors. These include having appropriate security measures in place to prevent unauthorised access to, or unauthorised alteration, disclosure or destruction of, the data, in particular where the processing involves the transmission of data over a network and against all unlawful forms of processing. This obligation can be met by having appropriate access controls to image storage or having robust encryption where remote access to live recording is permitted. Staff of the security company have been made aware of their obligations relating to the security of data. See Third Party Service Agreement for further guidance.
This policy will be reviewed and evaluated from time to time. On-
The date from which the policy will apply is the date of adoption by the BoM. Implementation of the policy will be monitored by the Principal of the school.
Chairperson of the Board of Management Principal
10/02/2021
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