Use of HD CCTV in School
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Any school that uses HD CCTV for whatever purposes must comply with all statutory regulations covering its use, as enshrined in the Data Protection Act 1998, the Human Rights Act 1998 and in certain circumstances, the Regulation of Investigatory Powers Act 2000. There are specific requirements that refer chiefly, but not exhaustively, to the installation of HD CCTV equipment and its employment, as well to the collection, analysis, dissemination and storage of data collected, that the school must address and be seen to be implementing actively.
A school is required to have a detailed policy covering every aspect of the use of surveillance HD CCTV and the data collected on its premises, and must have an appointed data controlling officer, preferably from the senior management team, to oversee and control all aspects of the use of HD CCTV and data collected from it. Registration for the use of HD CCTV surveillance must be maintained with the Office of the Information Commissioner, from where a suitable code of practice on its use can also be obtained.
An impact assessment can be a very useful method of detailing important aspects of the use of HD CCTV in a school and how it will affect those present, in particular, but not exclusively, staff and students. The impact assessment needs to address the following requirements.
– The exact purpose for the use of HD CCTV in each any every area of coverage
An assessment of the suitability for the use of HD CCTV over other methods considered for achieving the same or similar outcome.
– An assessment of the proportionality of the level of coverage employed, with regard to amount of equipment in use and time periods for which it is activated
– The possible/potential ways in which the data collected could be used, affecting directly or indirectly those monitored, including any restrictions on its usage, for each and every area of coverage.
– Where any/all data is stored for later possible use, the suitability of this over other methods to achieve the same information and outcomes.
– For each and every area of coverage, the identification of personnel having immediate access to the data collected through general authorisation as part of their specific duties, including the data controlling officer and other systems’ monitors with general or limited authorisation on their behalf to view the data for whatever purpose.
– For each and every area of coverage, where data may be stored, how and by whom the data will be processed in any manner, and for what purpose.
– For each and every area of coverage, the identification of personnel who can gain access to any/all data collected, as an intrinsic part of their duties (only if requisite authorisation has been granted, permanently or temporarily) and where possible, indication of whether any authorised use can be made of the released data, as well as any restrictions placed upon its use by the third party.
– Detailed methods by which all personnel, whose images could be captured by an active HD CCTV system, will be informed of this possibility, including appropriate signs and channels through which further information can be obtained.
It is further considered desirable that for every instance where those present could possibly be captured on HD CCTV, an assessment will be made concerning the individual’s right to privacy, limited or otherwise and the impact on their ability to perform in their most effective and personally comfortable way; this including both staff and students, but not exclusively. Whilst this assessment is bound to have a significant subjective element, it should nevertheless be considered as an important part of the overall statement.
Download our Sunstone School Impact Assessment