1. Policy Statement

1.1 Leigh Village Halls (“LVH”) uses Close Circuit Television (“CCTV”) on the premises.

The purpose of this policy is to set out the position of LVH as to the management, operation and use of CCTV on its premises.

1.2 This policy applies to all visitors, employees, volunteers to the LVH and the surrounding area and all other persons whose images may be captured by the CCTV system.

1.3 This policy takes account of all applicable legislation and guidance.

1.4 This policy sets out the position of LVH in relation to its use of CCTV.

2. Purpose of CCTV

2.1 The LVH trustees will use CCTV for the following purposes:

• To provide a safe and secure environment for all users and visitors
• To prevent the loss of or damage to the buildings and/or assets
• To assist in the prevention of crime and assist law enforcement agencies in apprehending offenders

3. Description of System
3.1 some of the areas will have more than one camera in and outside of the buildings. Some cameras have sou8nd recording capabilities.

4. Siting of Cameras

4.1 All CCTV cameras will be sited  in such a way as to meet the purpose for which the CCTV is operated. Cameras will be sited in prominent positions where they are clearly visible.

4.2 Cameras will not be sited, so far as possible, in such a way as to record areas that are not intended to be the subject of surveillance. LVH will make all reasonable efforts to ensure that areas outside the premises are not recorded.

4.3 Signs will be erected to inform individuals that they are in an area within which CCTV is in operation.

4.4 Cameras will not be sited in any areas where individuals have an expectation of privacy, such as changing rooms or toilets.

4.5 Cameras may be located in communal areas and, where this is the case, individuals will be made aware. Access to the footage is restricted and will only be used to fulfil the purposes in 2.1.

5. Privacy Impact Assessment
5.1 Prior to the installation or repositioning of any CCTV camera, or system, a privacy impact assessment will be conducted by the LVH to ensure that the proposed installation is compliant with legislation and ICO (Information Commissioners Office) guidance.

5.2 LVH recording and storing excessive amounts of personal data. LVH will adopt a privacy by design approach when installing new cameras and systems, considering the purpose of each camera so as to avoid recording and storing excessive amounts of personal data.

6. Management and Access

6.1 The CCTV system will be managed by a member of the Trustees of LVH.

6.2 The viewing of CCTV images will be restricted to the LVH Trustees and to those persons deemed appropriate by the Chair of the Trustees on a need to know basis.

6.3 No other individual will have the right to view or access any CCTV images unless in accordance with the terms of this policy as to disclosure of images.

6.4 The CCTV system is checked regularly to ensure that it is operating effectively.

7. Storage and Retention of Images

7.1 Any images recorded by the CCTV system will be retained only for as long as necessary for the purpose for which they were originally recorded.

7.2 Recorded images are stored for a maximum of 30days unless there is a specific purpose for which they are retained for a longer period.

8. Disclosure of Images to Data Subjects

8.1 Any individual recorded in any CCTV image is a data subject for the purposes of the Data Protection Legislation and has a right to request access to those images.

8.2 Any individual who requests access to images of themselves will be considered to have made a subject access request pursuant to the Data Protection Legislation.

8.3 When such a request is made the appropriate individual with access to the CCTV footage (ref 6.2)will review the footage, in respect of relevant time periods where appropriate, in accordance with the request.

8.4 If the footage contains only the individual making the request, then the individual may be permitted to view the footage. This must be strictly limited to that footage which contains only the image of the individual making the request. The individual accessing the footage must take appropriate measures to ensure that the footage is restricted in this way.

8.5 If the footage contains images of other individuals, the the LVH must consider whether:

• 8.5.1 The request requires the disclosure of the images of individuals other than the requester, for example whether the images can be distorted so as not to identify other individuals;
• 8.5.2 The other individuals in the footage have consented to the disclosure of the images, or their consent could be obtained: or
• 8.5.3 If not, then whether it is otherwise reasonable in the circumstances to disclose those images to the individual making the request.

8.6 A record must be kept, and held securely, of all disclosures which sets out:

• 8.6.1 when the request was made;
• 8.6.2 The process followed by the individual with access to the CCTV footage in determining whether the images contained third parties;
• 8.6.3 The considerations as to whether to allow access to those images;
• When the individuals that were permitted viewed the images;
• Whether a copy of the images was provided, and if so to whom, when and in what format.

Note that when a subject access request is made then, unless an exemption applies (such as in relation to third party data that would be unreasonable to disclose) then the requester is entitled to a copy in permanent form. There is reference here only to “access” as opposed to “permanent copy” as the LVH may consider it preferable in certain circumstances to seek to allow access to images by viewing in the first instance without providing copies of images. If an individual agrees to viewing the images only then a permanent copy does not need to be provided. However, if a permanent copy is requested then this should be provided unless to do so is not possible or would involve disproportionate effort.

9. Disclosure of Images to Third-Parties

9.1 The LVH will only disclose recorder CCTV images to third parties where it is permitted to do so in accordance with the data protection legislation.

9.2 CCTV images will only be disclosed to law enforcement agencies in line with the purpose for which the CCTV system is in place.

9.3 If a request is received from a law enforcement agency for disclosure of CCTV images, then the individual with access to the CCTV footage must follow the same process as above in relation to subject access requests. Detail should be obtained from the law enforcement agency as to exactly what they want the CCTV images for, and any individuals of concern. This will then enable proper consideration to be given to what should be disclosed of any third-party images.

9.4 The information above must be recorded in relation to any disclosure.

9.5 If an order is granted by a Court for disclosure of CCTV images, then this should be complied with. however very careful consideration must be given to exactly what the Court order requires. If there are any concerns as to disclosure, then the appropriate legal advice may be required.

10. Review of Policy and CCTV System

10.1 This policy will be reviewed every two years or earlier should the need arise.

11. Misuse of CCTV Systems

11.1 The misuse of the CCTV system could constitute a criminal offence.

12. Complaints Relating to this Policy

12.1 Any complaints relating to this policy or to the CCTV system operated by the LVH should be made to the LVH Management Committee Trustees.