Public Space CCTV - Community Safety Glasgow · 1.1. Glasgow’s Public Space Close Circuit TV...

Public Space CCTV

Code of Practice

Reducing Offending and Antisocial Behaviour

Supporting Victims of Gender Based Violence

Improving Community Safety

Reducing Environmental Incivility

Community Safety Glasgow Public Space CCTV - Code of Practice

Contents

The Content of this Code of Practice is hereby approved in respect of Community Safety Glasgow (on behalf of Glasgow City Council) Closed Circuit Television System (CCTV) and as far as reasonably practicable, will be complied with by all who are involved in the management and operation of the system.

Section 1: Introduction and Objectives

Section 2: Commitment to Good Practice

Section 3: Statement of Purpose and Principle

Section 4: Privacy and Data Protection

Section 5: Transparency

Section 6: Control and Operation of Cameras

Section 7: Accountability and Responsibilities

Section 8: Access and Security

Appendix A: Supportive Information

Appendix B: Owner Information


Section 1 - Introduction and Objectives

1.1. Glasgow’s Public Space Close Circuit TV (CCTV) systems are operated by Community Safety Glasgow (CSG) on behalf of Glasgow City Council. The scheme covers the boundaries of Glasgow City Council only. Glasgow currently has 430 Public Space CCTV cameras (PSCCTV) in operation across the city to provide a network of coverage.

1.2. Objectives of the System

The ‘System’ is all activities, processes, procedures that incorporate the management, monitoring, reviewing and storing of CCTV images and data by the Glasgow Operations Centre.

The objectives of the scheme as determined by the System owners and key partners which form the lawful basis for the processing of this data are:

• To help with the reduction or negation of criminal activity within the areas covered by the CCTV provisions

• To help with the increased apprehension and prosecution of offenders

• Risk management and environmental concerns

• Increase in public safety & public reassurance

• Reduction in the fear of crime

• Increase of and compliment partnership working

• To assist in Traffic Management where applicable (partnership working)

CCTV provisions are not intended to solve or eliminate all crime and fear of crime from communities covered by the network. However it is a powerful and effective tool that enables the collection of accurate, ‘real time’ information that supports the delivery of more effective and speedy responses as well as supporting the legal process in prosecuting those that do engage with criminality or do harm.

CSG firmly believes CCTV is an essential tool in enhancing public reassurance, crime detection and prevention of harm. It is an effective deterrent to would be criminals and provides the majority of Glasgow’s citizens with reassurance that they can go about their business safely. The public space CCTV provisions across the city also support other initiatives that together deliver the commitment to ensuring Glasgow continues to be a ‘safer, better, cleaner and thriving’ city for all residents and visitors.

• For the purposes of this document Glasgow City Council is the owner of the System

• For the purposes of this document Community Safety Glasgow is the Data Controller

• The Glasgow City Council System has been notified to the Information Commissioners office Registration number Z9994208


Section 2 - Commitment to good practice

CSG have considered relevant principles in relation to the scope and purpose of utilising CCTV, notably that the scheme will be operated fairly, in accordance with applicable legislation, and only for the purpose for which it is established or agreed in accordance with this Code of Practice. The CCTV System will at all times be operated with due regard to the privacy of the individual. Public confidence in the scheme will be enhanced and protected by ensuring the security and integrity of operational procedures and of personal data.

CSG recognises that public authorities and those organisations carrying on the functions of a public service nature are required to observe the obligations imposed by the Human Rights Act 1998, and consider that the use of CCTV in Glasgow is a necessary, proportionate and suitable tool to help reduce crime, reduce the fear of crime and improve public safety.

Community safety, as an objective, does not exist in isolation. Instead it is interlinked with other elements such as Community Planning and Best Value. These three areas were inextricably linked under the Local Government in Scotland Act 2003, which was designed to enable the delivery of efficient, integrated local services that were to specifically meet the needs of communities across Scotland

While there is no legislation dedicated specifically to community safety in Scotland, there is a significant amount of legislation that has a direct application to community safety. Much of the legislation applies to more than one area of community safety.

For example:

• The Anti-Social Behaviour etc. (Scotland) Act 2004 relates to personal safety, home safety, public space safety and environmental safety.

• The Environmental Protection Act (1990) and Dog Fouling (Scotland) Act 2003 empower CSG, on behalf of Glasgow City Council, to serve notice on a person suspected of having committed an offence in relation to littering and dog fouling respectively.

It is recognised that operation of the Glasgow CCTV System may be considered to infringe on the privacy of individuals. CSG recognise that it is their responsibility to ensure that the scheme should always comply with all relevant legislation, to ensure its legality and legitimacy. The scheme will only be used as a proportional response to identified problems and be used only in so far as it is necessary in a democratic society, in the interests of national security, public safety, the economic well-being of the area, for the prevention and detection of crime or disorder.

The Codes of Practice and observance of the Operational Procedures contained in the Operations Manual shall ensure that evidence is secured, retained and made available as required.


Section 3 - Statement of Purpose and Principles

CCTV surveillance has become a common feature in the daily lives of those that reside, work in or visit Glasgow. Indeed, CCTV is now used across almost all major cities in the United Kingdom and abroad.

CSG recognises that maintaining public trust and confidence in the use of CCTV is es-sential to ensure that this provision is delivered in partnership with the citizens and com-munities across the city.

3.1.This documents looks to:

• Highlight the benefits of the CCTV provisions and the intention of the owners and managers to support the objectives of the Glasgow City CCTV System.

• Demonstrate how this provision will be delivered

• Enhance trust and co-operative working with communities and citizens by showing that we have robust management & operational procedures in place.

In developing this document, CSG has incorporated the standards and practices from the Information Commissioner’s Office (ICO) Code of Practice covering CCTV and A National Strategy for Public Space CCTV in Scotland (2011) to ensure we work within the law and develop a model of best practice and standards that is consistent to those delivered across the United Kingdom.

This Code of Practice is supplemented by a separate process & operations manual which provides guidelines on all aspects of the day to day operation of the System. To ensure the purpose and principles of the CCTV System are realised, the procedure manual is based upon and expands the contents of the code.

3.2. General Principles of Operation

The System will be operated in accordance with all the requirements and the principles of the Human Rights Act 1998.

The operation of the System will also recognise the need for formal authorisation of any covert ‘Directed’ surveillance or crime –trend (hotspot’) surveillance as required by the Regulation of Investigatory Powers (Scotland) Act 2000.

The System will be operated in accordance with the Data Protection Act 1998 at all times

The System will be operated fairly, within the law, and only for the purposes for which it was established and are identified within this Code, or which are subsequently agreed in accordance with this Code of Practice.

The System will be operated with due regard to the principle that everyone has the right to respect for his or her private and family life and their home.

The public interest in the operation of the System will be recognised by ensuring the security and integrity of operational procedures.

Throughout this Code of Practice it is intended, as far as reasonably possible, to balance the objectives of the CCTV System with the need to safeguard the individual’s rights. Every effort has been made throughout the Code to indicate that a formal structure has been put in place, including a complaints procedure, by which it can be identified that the System is not only accountable, but is seen to be accountable.



3.3 Copyright

Copyright and ownership of all material recorded by virtue of The System will remain with the data controller.

3.4. Cameras and Area Coverage

The areas covered by CCTV to which this Code of Practice refers are the public areas within the responsibility of the operating partners and cover the Glasgow City Council boundary area.

From time to time re-deployable or mobile cameras may be temporarily sited within the area. The use of such cameras, and the data produced by virtue of their use, will always accord with the objectives of the CCTV System and be governed by this Code and the operational procedures for the Glasgow Operations Centre.

All cameras offer full colour, pan tilt and zoom (PTZ) capability

None of the cameras forming part of the System will be installed in a covert manner.

A map showing the number and location of all fixed Public Space CCTV cameras is available on the Community Safety Glasgow Website: www.communitysafetyglasgow.org

3.5. Monitoring & Recording Facilities

A fully staffed Control Room operates 24/7 with the cameras recording 24/7.

This Code is intended to provide a framework for the delivery of good practice for CSG Staff and management who are involved in managing & operating Public Space CCTV.

CCTV operators are able to record images from selected cameras in real-time, produce hard copies of recorded images, replay or copy any pre-recorded data at their discretion (with authorisation) and in accordance with the Code of Practice. All viewing and recording equipment shall only be operated by trained and authorised users.

Information that relates to a living person is deemed as personal data; as such the management of this data is subject to the protection and provisions of the Data Protection Act 1998 (DPA) and the exemptions therein. Please note that, while not covered by the provisions of the DPA, any information relating to a deceased person will, in accordance with Glasgow City Council policy, be protected by appropriate measures and any requests for such information will only be complied with where the law confers such a right or where it can be seen to be compatible with ongoing professional obligations of confidentiality to the deceased person and their right to privacy.

Management of CCTV data complies fully with the legal requirements of the DPA. This is outlined in the key principles of data protection.



3.6. Human Resources

Unauthorised persons will not have access without an authorised member of staff being present.

The monitoring room shall be staffed by specially trained operators in accordance with the industry and accreditation standards

All operators shall receive training relevant to their role in the requirements of the relevant legislation and the Codes of Practice and Procedures. Further training will be provided as necessary.

3.7. Processing and Handling of Recorded Material

Every request for the release of personal data generated by this CCTV System will be channelled through the System Manager.

In complying with the national standard for the release of data to third parties, it is intended, as far as reasonably practicable, to safeguard the individual’s rights to privacy and to give effect to the following principles:

Recorded material shall be processed lawfully and fairly, and used only for the purposes defined in this Code of Practice;

Members of the police service or other agency having a statutory authority to investigate and / or prosecute offences may, subject to compliance with relevant legislation and Appendix C, release details of recorded information to the media only in an effort to identify alleged offenders or potential witnesses.

It may be beneficial to make use of ‘real’ video footage for the training and education of those involved in the operation and management of CCTV systems, and for those in-volved in the investigation, prevention and detection of crime. Any material recorded by virtue of this CCTV System will only be used for such bona fide training and education purposes.

All recorded material, whether recorded digitally, in analogue format or as a hard copy video print, will be processed and handled strictly in accordance with this Code of Practice and the Procedural Manual.

Recorded data will be used only for the purposes defined in the Code of Practice and relevant legislative requirements.

Recorded data will be kept for a maximum of 14 days before being erased unless required for a specific enquiry

Access to recorded data will only take place as defined in the Code of Practice and relevant legislation.

In particular, recorded personal data will not be sold or used for commercial purposes or the provision of entertainment without the written consent of the data subject(s).

Recorded data can relate to DVDs, DAT, Compact Disc, and Computer Disk, video print and film or any mechanism for storing images, which can be viewed or processed after the event.

The type of data recording for storage used at the Glasgow Operations Centre is Digital Hard drives.



3.7. Processing and Handling of Recorded Material (Continued)

Several legally enforceable principles apply to this section, notably:

• Recorded data may be used in court as evidence. It must be of good quality, and be accurate in content. Recorded data must be treated according to defined procedures to provide continuity of evidence and to avoid contamination of this evidence.

• Appropriate security measures shall be taken against the unauthorised access to, alteration of, disclosure of and against accidental loss or destruction of, recorded data.

• Recorded data should be held only for the purposes provided by this Code of Practice and relevant legislation.

• Information recorded should be accurate, adequate, and relevant and not exceed that necessary to fulfil the purposes and key objectives of this Code of Practice.

• Recorded data shall be kept no longer than is necessary for the purposes and key objectives of the scheme. It must then be securely destroyed.

• Members of the public must be confident that information recorded about their ordinary activities in the area covered by the cameras is treated with due regard to their individual privacy.

3.8. Data Management

• All CSG CCTV footage is stored in a secure location

• All data is automatically erased after the required retention period

• Relevant security protocols and levels are applied to all CCTV footage

• Any images transferred to Police Scotland or other relevant agency is done so in a secure and proportionate manner.

3.9. Operators Instructions

Technical instructions on the use of equipment housed within the monitoring room are contained in a separate manual provided by the equipment suppliers.

3.10. Changes to the Code or the Procedural Manual

Any major changes to either the Code of Practice or the Procedural Manual, (i.e. such as will have a significant impact upon the Code of Practice or upon the operation of the System) will take place only after consultation with, and upon the agreement of all organisations with a participatory role in the operation of the System.

A minor change, (i.e. such as may be required for clarification and will not have such a significant impact) may be agreed between the manager and the owners of the System


Section 4 - Privacy and Data Protection

4.1. Information Commissioner’s Office

CSG is registered with the Information Commissioner’s Office (ICO) as the data controller, on behalf of Glasgow City Council, for the information gathered and managed through the Public Space CCTV System. ICO Registration Number: Z9994208

4.2. Data Protection Legislation

CSG delivers the management of data in compliance with the Data Protection Act 1998 (DPA).

Key principles of the DPA concerning the processing of data include the following:

• All personal data will be obtained and processed fairly and lawfully.

• Personal data will be held only for the purposes specified.

• Personal data will be used only for the purposes, and disclosed only to the people, shown within these codes of practice.

• Only personal data will be held which is adequate, relevant and not excessive in relation to the purpose for which the data is held.

• Steps will be taken to ensure that personal data is accurate and where necessary, kept up to date.

• Personal data will be held for no longer than is necessary.

• Individuals will be allowed access to information held about them and, where appropriate, permitted to correct or erase it.

• Procedures will be implemented to put in place security measures to prevent unauthorised or accidental access to, alteration, disclosure or loss and destruction of information.

4.3 Personal Data

CSG is fully compliant with the lawful reasons for processing Personal Data, as detailed under Schedule 2 of the Data Protection Act 1998: (http://www.legislation.gov.uk/ukpga/1998/29/part/II)

• Procedures will be implemented to deliver security measures to prevent unauthorised or accidental access to, alteration, disclosure or loss and destruction of information.

• The Data Subject has consented (appropriate signage erected to denote CCTV coverage).

• Processing is necessary for the purposes of legitimate interests pursued by the Data Controller and third party discloser’s and does not prejudice the rights and freedoms and legitimate interests of others and with the lawful reasons for processing Sensitive Personal Data, under Schedule 3 of the Act, wherein the process:

• Is in the substantive public interest

• Is necessary for the purposes of the prevention and detection of any unlawful act

• Must necessarily be carried out without the explicit consent of the data subjects so as not to prejudice those purposes.



4.4. CCTV Data

CSG uses CCTV and the data collected therein, for the following approved purposes:

• To help with the reduction or negation of criminal activity within the areas covered by the CCTV provisions

• To help with the increased apprehension and prosecution of offenders

• Risk management and environmental concerns

• Increase in public safety & public reassurance

• Reduction in the fear of crime

The storage, security and processing of the data will be strictly in accordance with the requirements of the Data Protection Act 1998 and additional locally agreed procedures.

Note: ‘Processing’ means obtaining, recording or holding the information or data or carrying out any operation or set of operations on the information or data, including;

i) Organisation, adaptation or alteration of the information or data;

ii) Retrieval, consultation or use of the information or data;

i) Disclosure of the information or data by transmission, dissemination or otherwise making available, or

iv) Alignment, combination, blocking, erasure or destruction of the information

4.5. Disclosure

Disclosure of images from CCTV will be controlled and consistent with the purpose for which the System was established. As an organisation jointly owned by Glasgow City Council and the Scottish Police Authority, Community Safety Glasgow has an obligation to assist in the prevention of crime and will therefore supply specific images which we are asked to provide Police Scotland or other crime detection agencies, provided we are satisfied that the request is connected to an investigation and that disclosure would be lawful and proportionate.

CSG will ensure that any external agency that receives disclosed information are fully aware of and accept their responsibilities as outlined in the Data Protection Act 1998.

4.6. Responsibilities

• Community Safety Glasgow is the data controller for the data collected through the Public Space CCTV System, and operational responsibility for the System is devolved to the System Manager.

• Data Protection in the organisation is the responsibility of the Senior Information Risk Owner (SIRO) at Directorate level and the Corporate Support Manager at operational level.



4.7. Making a request for CCTV footage

Individuals whose images are recorded have a right to request access to view relevant footage and, where appropriate, to be provided with a copy of the images in a still or virtual format.

Should a data subject or his/her authorised representative believe that CSG may hold CCTV footage of them, they are entitled to request access to this data under Schedule 2 of the DPA.

To request access to CCTV footage, an individual must:

• make the request in writing

• supply appropriate information to help locate the required footage

4.8. Processing a request

In the first instance, the Customer Support Team will check whether the area of the City is covered by the Public Space CCTV in Glasgow. If the area is not covered, the requestor will be informed as soon as possible and the case will be closed.

If the area is covered by Public Space CCTV, the requestor will be provided with a Subject Access Request form. The Subject Access Request should provide evidence of who they are (e.g. driving licence, passport, birth certificate) and should also provide as much detail as possible regarding the footage they wish to access (e.g. time, date, location). A £10 administration charge will also apply.

At this stage, the requestor will also be advised that CCTV footage is held for a period of 14 days before it is considered for disposal, unless there is a specific reason to retain it for an extended period. The individual can decide whether to proceed or not, depending on the time elapsed since the incident of which footage is sought.

A fully completed Subject Access Request form, along with documentation and payment is required within 14 days of issue or the case will be closed. The Corporate Support Manager will consider extensions on a case by case basis, particularly in relation to third-party requests (e.g. a solicitor acting on behalf of a client on remand).

A search for footage will commence on receipt of all necessary documents and a response will be provided to the requestor within 40 calendar days.

The possible outcomes are:

• Footage found

• Footage not found

• Out of time (footage deleted after 14 days)

• Footage already passed to Police/Procurator Fiscal

• Camera non-functional



4.9. Providing access to footage

If footage is found, the System Manager ( will generally be the Service Manger or Operations Manager) will decide if any of the footage contains images of third parties and whether access to or release of the footage would violate the data protection rights of the third party or parties.

Where it has been deemed appropriate to allow access to the footage, the data subject, or their representative, will be invited to view the footage at Community Safety Glasgow’s Eastgate headquarters.

Where it has not been deemed appropriate to allow footage to be viewed, the data subject may be provided with a narrative of the footage content or a still photographic form, where appropriate.

If access is denied completely, the Customer Support Team will inform the data subject of the decision and the reason, in writing. They will also be informed of:

• Any process available to him/her to appeal this decision.

• How to make a complaint to the Information Commissioner’s Officer, in addition to processing an appeal.

4.10. Contact details:

Community Safety Glasgow

Address: Eastgate, 727 London Road, Glasgow, G40 3AQ

Telephone (Reception): 0141 276 7400

Facebook: CommSafetyGlasgow

Twitter: @CommSafetyGlasg

Customer Support Team (CST)

Address: 2nd Floor Eastgate, 727 London Road, Glasgow, G40 3AQ

Telephone: 0141 276 7808

Email: [email protected]

Useful Web Links

CSG Home Page: http://www.communitysafetyglasgow.org

CSG Privacy Policy: http://www.communitysafetyglasgow.org/privacy-policy/

CSG SARS Form: http://www.communitysafetyglasgow.org/privacy-policy/subject-access-request/



4.11. Freedom of information (FOI)

As a public body, CSG is subject to the Freedom of Information (Scotland) Act 2002 (FOISA).

FOI requests to CSG in relation to Public Space CCTV provision can include information on where cameras are sited, functionality, and whether they were operational over particular periods.

All FOI requests have to be in a permanent format either by letter / email or via the CSG website.

The contact details for the FOI officer are:

Freedom of Information Officer


Eastgate (2nd Floor)

727 London Road

Glasgow, G40 3AQ.


Website: http://www.communitysafetyglasgow.org/freedom-of-information/

Requests for information are processed within 20 working days from the acknowledgment of an appropriate request.

Access to CCTV images captured may be subject to an exemption under Section 38 of the Freedom of Information (Scotland) Act 2002.


Section 5 - Transparency

CSG will ensure the recording and retention of images (sensitive personal data) of people in public places shall be undertaken fairly and lawfully in accordance with Data Protection Act 1998 (DPA).

CSG will ensure that the public are aware that their image is being recorded through static and re-deployable camera and that the identity of the owner of the System (Community Safety Glasgow) is clearly visible.

The visibility of ownership and purpose of the cameras will be provided by ensuring:

• That prominent signs are placed on the cameras or zones where the CCTV cameras are in operation.

• Vehicles with mobile redeployable CCTV cameras are clearly marked as managed by CSG

• Updated information is provided to Glasgow City Council to ensure their mapping records are up to date in relation to the location of static cameras across the city.

CSG will ensure that signage and relevant information:

• Is clearly visible and readable

• Contains CSG contact information

• Is appropriate in size

• Indicates that CCTV cameras are in operation and is displayed at appropriate locations covered by the scheme to allow people entering the area to make an appropriate approximation of the CCTV camera coverage area

• If vandalised or removed the signs will be replaced as soon as reasonably possible.

The Directed/Covert use of CCTV is not subject to the above guidelines as the use of signage or disclosure of the use of cameras may seriously prejudice surveillance and prevent the detection of crime and apprehension and prosecution of offenders.

All persons operating the cameras must adhere to this Code of Practice and require-ments of the Data Protection Act 1998.

Only persons who have a SIA CCTV accreditation will operate the cameras (there will be exception for Police Scotland officers trained in the use of CCTV)

Every use of the camera will accord with the purpose and key objectives of the System and shall be in compliance of this code.

Cameras will not be used to look into private residential property.

Where the equipment permits and if required ‘privacy zones’ may be programmed into the System.

Secondary monitoring facilities will also be administered and recorded in accordance with this code. This includes the CSG Business Continuity Centre at Blochairn and the Police Scotland Control Room at Helen Street.


Section 5 - Transparency

5.1. Direct Surveillance Authority (RIP(S)A)

Regulation of Investigatory Powers (Scotland) Act 2000 (RIPSA) was put in place to regulate surveillance and the use of covert human intelligence sources. In line with the Protocol with Police Scotland we will ensure that we adhere to the relevant legislation and this Code of Practice in relation to use of PSCCTV for Directed and Covert surveillance.

General observations forms part of the duties for many law enforcement officers and other public authorities and is not usually regulated by RIP(S)A.

Directed surveillance is covert but not intrusive and undertaken for the purposes of a specific investigation or specific operation carried out in such a manner as is likely to result in obtaining private information about a person (whether or not one specifically identified for the purposes of the investigation or operation).

This Code of Practice and the legislation mainly applies to:

Direct surveillance for the purposes of the Act (defined in section1 (2) of the RIP(S)A act is carried out by means of a surveillance device in relation to anything taking place on any residential premises or in any private vehicle: but

Is carried out without the device being present on the premises or in the vehicle, is not intrusive unless the device is such that it consistently provides information of the same quality and detail as might be expected to be obtained from a device actually present on the premises or in the vehicle

CSG management will ensure that the appropriate protocols are in place with the required organisations that will look to utilise PSCCTV for surveillance purposes.

CSG will not allow any Directed/Covert surveillance operation to be delivered without the appropriate paper work being provided to PSCCTV staff. This will mainly be in the form of a redacted Directed Surveillance Authorisation (DSA).

All Surveillance requests need to be authorised by a senior officer from within that organisation who has the authority to sign off a request. This general is at Superintendent Level for Police Scotland or senior manager for a Local Authority request.

Notes.

I. The installation of a CCTV camera is considered to be overt unless it is installed in a manner whereby its presence is deliberately intended to be concealed from the view of any person likely to be within the field of view of that camera.

II. Cameras which may be placed in domes or covered to reduce the likelihood of assessing their field of view, or to protect them from weather or damage, would not be regarded as covert provide that appropriate signs are in place


Section 6 - Control and Operation of Cameras

In line with the Information Commissioners Office (ICO) Code of Practice and the Surveillance Camera Code of Practice, CSG adheres to the following core principles:

Guiding Principles.

1. Use of a surveillance camera system must always be for a specified purpose which is in pursuit of a legitimate aim and necessary to meet an identified pressing need.

2. The use of a surveillance camera system must take into account its effect on individuals and their privacy, with regular reviews to ensure its use remains justified.

3. There must be as much transparency in the use of a surveillance camera system as possible, including a published contact point for access to information and complaints.

4. There must be clear responsibility and accountability for all surveillance camera system activities including images and information collected, held and used.

5. Clear rules, policies and procedures must be in place before a surveillance camera system is used, and these must be communicated to all who need to comply with them.

6. No more images and information should be stored than that which is strictly required for the stated purpose of a surveillance camera system, and such images and information should be deleted once their purposes have been discharged.

7. Access to retained images and information should be restricted and there must be clearly defined rules on who can gain access and for what purpose such access is granted; the disclosure of images and information should only take place when it is necessary for such a purpose or for law enforcement purposes.

8. Surveillance camera system operators should consider any approved operational, technical and competency standards relevant to a system and its purpose and work to meet and maintain those standards.

9. Surveillance camera system images and information should be subject to appropriate security measures to safeguard against unauthorised access and use.

10. There should be effective review and audit mechanisms to ensure legal requirements, policies and standards are complied with in practice, and regular reports should be published.

11. When the use of a surveillance camera system is in pursuit of a legitimate aim, and there is a pressing need for its use, it should then be used in the most effective way to support public safety and law enforcement with the aim of processing images and information of evidential value.

12. Any information used to support a surveillance camera system which compares against a reference database for matching purposes should be accurate and kept up to date.



6.1. Primary Control

Only those trained and authorised members of staff with responsibility for using the CCTV equipment will have access to the operating controls, those operators have pri-macy of control at all times.

6.2. Secondary Monitoring

Secondary monitoring facilities are provided at the Police Scotland Control Room at Hel-en Street (no control is possible at this location) and Blocharin (BCC site for the Glasgow Operations Centre). The use of secondary monitoring facilities will be administered and recorded in full accordance with this Code of Practice and the Procedural Manual and does not diminish in any way the obligations imposed on any of the persons involved to comply with all current legislative requirements.

6.3. Operational Command of the System by the Police

Under rare and extreme operational circumstances, Police Scotland may make a request to command the use of The System to which this Code of Practice applies.

These circumstances may be a major incident or event that has a significant impact on the prevention and detection of crime or public safety. Such use will provide the police with a broad overview of events in order to command the incident.

Such requests will be viewed separately to the use of the Systems’ cameras with regard to the requirement for an authority for specific types of surveillance under the Regulation of Investigatory Powers Act Scotland 2000.

Applications made as at above will be considered on the written request of a police officer not below the rank of Superintendent. Any such request will only be accommodated upon the personal written permission of the most senior representative of the System owners, or designated deputy of equal standing.

In the event of such a request being permitted, the Control Room will continue to be staffed, and equipment operated by, only those personnel who are specifically trained to do so. They will then operate under the command of the police officer designated in the verbal / written request, taking into account their responsibilities under this code.

In very extreme circumstances a request may be made for the Police to take total control of The System in its entirety, including the staffing of the monitoring room and personal control of all associated equipment, to the exclusion of all representatives of the System owners. Any such request should be made to The System manager in the first instance, which will consult personally with the most senior officer of The System owners (or designated deputy of equal standing). A request for total exclusive control must be made in writing by a police officer not below the rank of Assistant Chief Constable or person of equal standing.



6.4. Maintenance of the System

To ensure compliance with the Information Commissioners Office Code of Practice and that images recorded continue to be of appropriate evidential quality, the Community Safety Glasgow CCTV System shall be maintained in accordance with the requirements of the Procedural Manual under a Service Level Agreement (SLA) with the relevant agencies.

The SLA will make provision for regular/ periodic service checks on the equipment which will include cleaning of any all-weather domes or housings, checks on the functioning of the equipment, and any minor adjustments that need to be made to the equipment settings to maintain picture quality.

The maintenance will also include regular periodic overhaul of all the equipment and replacement of equipment which is reaching the end of its serviceable life.

The SLA will also provide for ‘emergency’ attendance by a specialist CCTV engineer on site to rectify any loss or severe degradation of image or camera control.

The SLA will define the maximum periods of time permitted for attendance by the engineer and for rectification of the problem depending upon the severity of the event and the operational requirements of that element of the System.

It is the responsibility of the System Technical Managers to ensure appropriate records are maintained in respect of the functioning of the cameras and the response of the maintenance organisation.


Section 7 - Accountability and Responsibilities

7.1. Authorised Access

Only authorised personnel will operate the equipment located within the Control Room or equipment associated with the System.

7.2. Public Access

Public access to the System & Control Room will be prohibited except for lawful, proper and sufficient reasons. Any such visits will be conducted and recorded in accordance with the procedure manual.

All visits will be managed by appropriate staff and will be recorded in the visitors book within the Control Room.

7.3. Security

Authorised personnel will be present at all times when the equipment is in use. If the monitoring facility is to be left unattended for any reason it will be secured. In the event of the Control Room having to be evacuated for safety or security reasons, the provisions of the procedure manual for Business Continuity or Disaster Recovery will be complied with.

The Control Room is a secure environment and has restricted access for designated card holders only.

In accordance with the legal responsibilities, of the Data Protection Act 1998 and Regulation of Investigatory Powers (Scotland) Act 2000:

• The operation and management of the public space CCTV provision, along with the process for collection, management and securing of personal data collected through this provision is registered with the Information Commissioners Office annually.

• The CCTV System is operated in compliance with the current Code of Practice issued by the Information Commissioner in respect of the operation of CCTV in public places.

• We will erect appropriate signs to notify the public of the presence of CCTV cameras and recording equipment. These signs will carry the necessary information prescribed in the Information Commissioner’s Code of Practice.

• We will undertake an annual audit of CCTV practies to ensure compliance with the Data Protection Act 1998 and Information Commissioners Office (ICO) Code of Practice

• No data will be transferred to a country outside the European Economic Area unless such countries have in place “Safe Harbour” agreement with the UK surrounding the security of, and respect for, personal data.

• Ensure that a Privacy impact Assessment framework is put in place as a measure of best practice in accordance with the relevant ICO guidelines.



7.3. Security (Continued)

Effective management of the CCTV System requires that:

• Access to all the data held, and the CCTV equipment, should comply with specific guidelines as highlighted in this code.

• The Operational Procedure Manual and documentation required to run this scheme must be developed from, and specifically linked to, this Code of Practice.

• All incidents witnessed on the CCTV System or on review of a recording will be logged.

• Data shall be stored for a maximum of 14 days before being digitally erased unless required for a specific enquiry.

• Any request to use the PSCCTV System for any pre-planned targeted operation and/or information gathering may require a DSA.

• Where PSCCTV receive reports of areas/incidents and/or people of concern via an Observation Request Form attention may be afforded and details of any resulting incidents passed onto relevant officers to take appropriate action.

• Any recording removed from the System for viewing by PSCCTV staff will be recorded.

• Third parties, who are authorised to view recordings by virtue of their inclusion in the list of recipients notified to the Information Commissioner, will have a record made of such viewing on form.

• Any recorded data required for Police evidential purposes will be managed and downloaded by Police Scotland, any other requests from partner agencies will be recorded and the person receiving the data shall sign in receipt.

• If a video printer is used to produce printed still images from CCTV data, a form will record all relevant details.

• All video prints made will be given a Unique Reference Number (URN) and their disposal tracked on the above record.

• All CCTV equipment will be kept in good working order and be serviced according to manufacturer recommendations.

• When a fault develops on the CCTV System, it shall be recorded on the fault management system and the appropriate action taken to ensure a speedy repair is effected.

• All CCTV equipment shall be secured so as to prevent interference from unauthorised personnel. This means that recording equipment shall be kept in a secure environment, which is a controlled and secure location

• CCTV data shall be afforded a high level of security. Access to recordings shall be limited to staff authorised by the Data Controller.

• All CCTV data will be stored in a secure environment to prevent unauthorised or unlawful processing of personal data and against accidental loss, damage or destruction of personal data.



7.3. Security (Continued)

Effective management of the CCTV System requires that:

• Any data held for evidential purposes will be kept away from other personal data in a secure location.

No unauthorised copies will be made of any personal data except with the permission of the Data Controller. They shall record the reason and ensure that all copies are numbered and that they are only disclosed to authorised parties. The Data Controller shall also ensure such personal data is not kept for longer than is necessary and is destroyed as if it were an original recording.

No guarantee is given or implied that any particular premises, street, location, area or incident will be observed and recorded by the System. However, all CCTV Operators and management will endeavour to provide a level of coverage based on up to date information concerning incidents and activities commensurate within the purposes of the CCTV System.

Cameras will not be used to look into private residential property. Where the equipment permits it ‘privacy Zones’ will be programmed into the System as required in order to ensure that the interior of any private residential property within the range of the System is not surveyed by the cameras. All operators are fully trained in privacy issues and requirements.

It should also be acknowledged that constraints are placed upon every CCTV system by the limits of current technology.

7.4. System Owners

Designated officers will have unrestricted access to the Control Room and System.

Relevant officers will ensure that any issues, concerns of complaint are dealt with in an appropriate and timely manner.

Designated officers will have day to day responsibility for the management and maintenance of the System.

The System will be subject to regular reviews and audits.



7.5. Human resources

The Control Room will be staffed at all times in accordance to the service requirements.

All staff based in PSCCTV are SIA accredited along with level 1 Non Police Personnel Vetted (NPPV).

Staff are fully trained in the use of the CCTV System and must adhere to the regulations and governance in place.

A regular review of SIA licences and requirements is in place.

All engineering & technical staff are trained and qualified to maintain the systems within the centre.

All staff will be provided with copies of this code and relevant documents to ensure adherence with the code and associated procedures.

Each individual having responsibility under the terms of this code who has involvement with the system to which it refers will be subject to the organisations HR polices and procedures. Any breach of this code or any aspect of confidentiality will be dealt with in accordance with the relevant HR policy.

A member of the public wishing to register a complaint with regard to any aspect of the System may do so by contacting Community Safety Glasgow Customer Support Team.

All complaints shall be dealt with in accordance with Community Safety Glasgow’s complaints handling procedure, on the Community Safety Glasgow Website.

Contact details are provided in section 4.


Section 8 - Access and Security

8.1. Authorised Access

Only trained and authorised personnel will operate any of the equipment located within the CCTV monitoring room, (or equipment associated with the CCTV System).

8.2. Public access

Public access to the monitoring and recording facility is restricted except for lawful, proper and sufficient reasons and only then with the personal authority of the System manager. Any such visits will be conducted and recorded in accordance with the Procedural Manual.

8.3. Authorised Visits

Visits by inspectors or auditors do not fall into the scope of the above paragraph and may take place at any time, without prior warning. Any such visit should be recorded in the same way as that described above.

8.4. Declaration of Confidentiality

Regardless of their status, all visitors to the CCTV monitoring room, including inspectors and auditors, will be required to sign the visitors book and Read the Data Protection Legislation.

‘In signing this visitors book all visitors to the Glasgow Operations Centre acknowledge that the precise location of the CCTV monitoring room and personal details of those operating the System, is, and should remain confidential. They further agree not to divulge any information obtained, overheard or overseen during their visit.’

It is also best practice to display a notice at the entrance to the room to state that they are entering a restricted area, and entry is dependent upon acceptance of the need for confidentiality. If any visitors decline to sign the visitor’s book, entry will be declined.

8.5. Security

Authorised personnel will normally be present at all times when the equipment is in use. If the monitoring facility is to be left unattended for any reason it will be secured. In the event of the monitoring room having to be evacuated for safety or security reasons, the provisions of the Procedural Manual will be complied with.

The monitoring room will at all times be secured by ‘Magnetic-Locks’ which require access cards to enable entry into the Control Room. The Control Room is a restricted area and only authorised personnel will have access privileges as determined by the managers.


Appendix A

Supportive Information

1. The Information Commissioners Office (ICO)

The ICO is responsible for ensuring Data Protection Rights are observed across the United Kingdom. The contact details for the ICO are:

Information Commissioner’s Office (Scotland)

45 Melville Street, Edinburgh, EH3 7HL

Tel: 0131 244 9001

Helpline: 0303 123 1113


Web site: https://www.ico.gov.uk/

2. Use of CCTV Provisions and Data Protection

Information is available to the general public on their rights at http://www.ico.gov.uk/for_the_public/topic_specific_guides/cctv.aspx.

In addition to which there is a CCTV Code of Practice for organisations that deliver this provision and this is available to the general public on:

http://www.ico.gov.uk/for_the_public/topic_specific_guides/cctv.aspx

3. Safe Harbour Countries

The current list of such recipients is posted on the Information Commissioners official web site. The address is www.dataprotection.gov.uk


Appendix B

Data Controller


System Owners

Glasgow City Council

System Managers

Community Safety Glasgow, 727 London Road, Glasgow G40 3AQ.

System Maintenance

Cameras: Community Safety Glasgow

CCTV Systems: ACCESS LLP (contractual management of contractors)

Contact details:


Address: Eastgate, 727 London Road, Glasgow, G40 3AQ

Tel (Reception): 0141 276 7400

Facebook: CommSafetyGlasgow

Twitter: @CommSafetyGlasg

Customer Support Team (CST)

Address: 2nd Floor Eastgate, 727 London Road, Glasgow, G40 3AQ

Tel: 0141 276 7808


Useful Web Links

CSG Home Page: http://www.communitysafetyglasgow.org

CSG Privacy Policy: http://www.communitysafetyglasgow.org/privacy-policy/

CSG SARS Form: http://www.communitysafetyglasgow.org/privacy-policy/subject-access-request/

Eastgate, 727 London Road, Glasgow G40 3AQ. Tel: 0141 276 7400 Email: [email protected]

Community Safety Glasgow is a limited company incorporated in Scotland (No. 130604) and a registered charity (SCO17889). Managing Director: Phil Walker,

Community Safety Glasgow is an equal opportunities employer.

Working in partnership for a safer Glasgow

FB and Twitter Business Card.indd 1 04/06/2014 08:25

Working in partnership for a safer Glasgow

FB and Twitter Business Card.indd 2 04/06/2014 08:25

www.communitysafetyglasgow.org

Find out about all of the services we provide to support you and your community.

Visit our new website today.

Web launch info card.indd 1 25/03/2015 14:28

Date post:	28-May-2020
Category:	Documents
Upload:	others
View:	1 times
Download:	0 times

Public Space CCTV - Community Safety Glasgow · 1.1. Glasgow’s Public Space Close Circuit TV...

Documents