(A pdf version of this policy is available for download here)
Introduction
St Stephen in Brannel Parish Council operates a Closed Circuit Television (CCTV) system to ensure a safe and secure environment for residents, staff, councillors, and visitors, as well as to prevent the loss or damage of Council property. This system is a key component of the Council’s efforts to prevent, identify, and reduce crime.
The Council owns and manages the CCTV system directly and serves as the system operator and data controller for the images produced. It is registered with the Information Commissioner’s Office (ICO) under Registration Number Z7787866.
The CCTV system operates 24 hours a day, 365 days a year, and is monitored as necessary to achieve its stated purposes.
Purpose
This policy governs the installation, operation, and use of the Council’s CCTV system.
The primary purposes of CCTV surveillance are:
- Protecting Council assets.
- Promoting the health and safety of residents, staff, councillors, and visitors by enhancing perceptions of public safety.
- Reducing crime and anti-social behaviour, including theft and vandalism.
- Supporting the Police to deter and detect crime.
- Assisting in the identification, apprehension, and prosecution of offenders.
Scope
This policy applies to:
- The Council, its staff, and councillors.
- Contractors and volunteers working on behalf of the Council.
Non-compliance with this policy may result in disciplinary action, including dismissal. All staff involved in operating the CCTV system will be trained and authorised to ensure proper use consistent with the stated purposes and procedures.
Individuals accessing, recording, or processing CCTV images must possess the necessary skills and training to handle operational, technical, and privacy considerations.
Policy Statement
The Council is committed to operating its CCTV system responsibly and in accordance with the ICO CCTV Code of Practice (2017).
CCTV will be used professionally, ethically, and legally, with respect for individual privacy. Cameras are positioned to:
- Cover only areas necessary to achieve the system’s purpose.
- Minimise intrusion into private spaces.
- Ensure recordings are of high quality and unobstructed.
- Reduce the risk of damage or theft of equipment.
The system will not be used for live streaming public activities.
Location and Signage
CCTV cameras are strategically located to monitor Council property and public spaces, including:
- Nanpean Cemetery, St Georges Rd, Nanpean.
- St Stephen Churchtown Cemetery, Fore Street, St Stephen.
- Churchtown Craft Workshop Complex, Fore Street, St Stephen.
Signage is displayed to inform the public about CCTV operation.
Monitoring and Recording
CCTV footage is recorded on secure servers and accessible only to authorised personnel.
Additional staff may be granted “view only” access with the Clerk’s authorisation for cameras within their areas of responsibility.
To maintain data integrity:
- Recordings are stored with accurate metadata (e.g., time, date, and location).
- Monitors are screen-protected and powered off when not in use to prevent unauthorised access.
- Cameras are regularly checked to ensure images are of sufficient quality and timestamps are accurate.
Recorded images remain the property of St Stephen in Brannel Parish Council.
Covert Surveillance
The Council does not conduct covert surveillance under any circumstances.
Facial Recognition
When cameras are used to capture facial images, they must be of high quality to ensure accuracy and fulfil the intended purpose.
Live Streaming
The Council’s CCTV system is not used for live streaming, as its purpose is solely safety and security.
Data Protection
The Council complies with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018, in line with its Data Protection Policy.
Applications for Disclosure of Images
Subject Access Requests (SARs):
Individuals may request footage relating to themselves by submitting a Subject Access Request to the Clerk. Further details are available on the Council’s website.
The Council may decline a request if fulfilling it would disclose another person’s data, unless consent is provided or disclosure is deemed reasonable under the circumstances.
Third-Party Requests:
Disclosure of images to third parties (e.g., law enforcement) will only occur when:
- Required by law.
- Necessary for crime prevention or detection.
Requests must be made to the Clerk, who will log all disclosures, including:
- Date, time, and camera details.
- Requestor’s details and reason for disclosure.
- Authoriser’s name and the lawful basis for disclosure.
Before release, images of third parties may be obscured to protect their privacy. Secure transfer methods must always be used.
Retention of Images
CCTV footage is retained for up to 31 days unless required for:
- Evidentiary purposes.
- Legal investigations.
Footage held beyond the standard retention period must be authorised by the Clerk and stored securely for no more than six months after the last action. A review will be conducted every three months, and any unnecessary images will be deleted.
Complaints Procedure
Complaints regarding CCTV use or image disclosure should be directed to the Clerk. The Council’s complaints procedure is available on its website.
Anonymised complaint data may be shared with the Surveillance Commissioner upon request.
Review Procedure
The CCTV system is reviewed annually to ensure it remains necessary, proportionate, and effective. The review includes:
- Assessment of camera locations and potential relocation or removal.
- Evaluation of monitoring operations.
- Consideration of less intrusive alternatives.
Responsibilities
The Council oversees the overall management and operation of the CCTV system, including:
- Installation and maintenance of equipment.
- Monitoring and recording footage.
- Ensuring compliance with this policy and relevant legislation.
The Clerk, acting as the Council’s Data Protection Officer, is responsible for authorising image disclosures and maintaining a disclosure log.
Adopted by Full Council at the meeting held on Wednesday 4th December 2024 under minute number FPC269/24. Due for review in December 2027.