1.1 Horseman Coaches uses closed circuit television (CCTV) and the images produced to prevent or detect crime and to monitor the behavior either on our premises or our vehicles in order to provide a safe and secure environment for its pupils, staff and visitors, and to prevent loss or damage property.
1.2 Our systems are comprised of several fixed and dome cameras.
1.3 Some systems may have sound recording capability.
1.4 The CCTV systems are owned and operated by the company.
1.5 The CCTV is monitored centrally from a manager’s office. Access to the images is controlled by the data controller, James Horseman (Company Director) or in his absence, David Elliott (General Manager). Systems are user and password protected.
1.6 Both authorised operators are aware of the procedures that need to be followed when accessing the recorded images.
- Statement of Intent
2.1 The company complies with the Information Commissioner’s Office (ICO) CCTV Code of Practice to ensure that CCTV is used responsibly and safeguards both trust and confidence in its continued use. The Code of Practice is published at: https://ico.org.uk/media/1542/cctv-code-of-practice.pdf
2.2 CCTV warning signs are clearly and prominently around the sites and on all coaches.
- Siting the Cameras
3.1 Cameras are sited so that they only capture images relevant to the purposes for which they are installed, and care will be taken to ensure that reasonable privacy expectations are not violated. The company will ensure that the location of equipment is carefully considered to ensure that footage captured complies with the Data Protection Act/GDPR.
3.2 CCTV will not be used in any staff offices or rest facilities.
3.3 Members of staff will have access to details of where CCTV cameras are situated, with the exception of cameras placed for the purpose of covert monitoring. The location of all cameras are denoted with the image in Annex A or similar.
- Covert Monitoring
4.1 It is not the company’s policy to conduct ‘Covert Monitoring’ unless there are ‘exceptional reasons’ for doing so.
4.2 The company may, in exceptional circumstances, determine a sound reason to set up covert monitoring. For example: i) Where there is good cause to suspect that an illegal or unauthorised action(s), is taking place, or where there are grounds to suspect serious misconduct; ii) Where notifying the individuals about the monitoring would seriously prejudice the reason for making the recording.
4.3 Covert monitoring must cease following completion of an investigation.
4.4 Cameras sited for the purpose of covert monitoring will not be used in areas which are reasonably expected to be private, for example toilet cubicles, changing areas etc.
- Storage and Retention of CCTV images
5.1 Recorded data will not be retained for longer than is necessary. While retained, the integrity of the recordings will be maintained to ensure their evidential value and to protect the rights of the people whose images have been recorded.
5.2 All retained data will be stored securely at all times and permanently deleted as appropriate / required.
- Access to CCTV images
6.1 Access to recorded images will be restricted to those staff authorised to view them and will not be made more widely available.
- Subject Access Requests (SAR)
7.1 Individuals have the right to request access to CCTV footage relating to themselves under the Data Protection Act/GDPR.
7.2 All requests should be made in writing to the Company Director. Individuals submitting requests for access will be asked to provide sufficient information to enable the footage relating to them to be identified. For example, date, time and location.
7.3 The company will respond to requests within 30 calendar days of receiving the written request and any fee. This is as per the ICO CCTV Code of Practice.
7.4 A fee of £10 may be charged per request. This is as per the ICO CCTV Code of Practice.
7.5 The company reserves the right to refuse access to CCTV footage where this would prejudice the legal rights of other individuals or jeopardise an on-going investigation.
- Access to and Disclosure of Images to Third Parties
8.1 There will be no disclosure of recorded data to third parties other than to authorised personnel such as the Police and service providers to the company where these would reasonably need access to the data (e.g. investigators).
8.2 Requests for images / data should be made in writing to the Company Director.
8.3 The data may be used within the company’s discipline and grievance procedures as required and will be subject to the usual confidentiality requirements of those procedures.
9.1 Complaints and enquiries about the operation of CCTV should be directed to the General Manager in the first instance.
Further information on CCTV and its use is available from the following:
• CCTV Code of Practice Revised Edition 2017 (published by the Information Commissioners Office) Version 1.2
• Regulation of Investigatory Powers Act (RIPA) 2000
• Data Protection Act 1998
• GDPR (wef 25 May 2018)