Closed Circuit Television System (CCTV) is installed in Moyle Park College under the remit of the Board of Management.
The purpose of this policy is to regulate the use of Closed Circuit Television and its associated technology in the monitoring of the internal and external environs of premises under the remit of the B.O.M. of Moyle Park College.
CCTVs are installed internally and externally in premises for the purpose of enhancing security of the building and its associated equipment as well as creating a mindfulness among the occupants, at any one time, that a surveillance security system is in operation to deter bullying, crime, vandalism and theft as an aid to Health & Safety and to the discharge of the school’s duty of care within and/or in the external environs of the premises during both the daylight and night hours each day.
This policy applies to all personnel in and visitors to Moyle Park College and relates directly to the location and use of CCTV, the monitoring, recording and subsequent use of such recorded material.
The B.O.M. of Moyle Park College as the Corporate Body, has a statutory
responsibility for the protection of its property, equipment and other plant as
well as providing a sense of security to its employees, students and invitees
to its premises. Moyle Park College owes a duty of care under the provision of
Health & Safety and Welfare legislation and utilises CCTV systems and its
associated monitoring and recording equipment as an added mode of security and
surveillance for the purpose of enhancing the
quality of life of Moyle Park College by integrating the best practices
governing the surveillance of its premises.
The primary aim of CCTV monitoring Moyle Park College premises is to
deter crime and vandalism and to assist in the protection and safety of the
said property and its associated equipment and materials.
Monitoring for security purposes will be conducted in a professional,
ethical and legal manner and any diversion of the use of CCTV security
technologies and personnel for other purposes is prohibited by this policy e.g.
CCTV monitoring of employees and/or student evaluations would undermine the acceptability
of the resources for use regarding critical safety and security objectives and
is therefore prohibited by this policy.
Information obtained through video monitoring may only be released when
authorized by the Principal following consultation with the Chairperson of the
Board of Management.
CCTV monitoring of public areas, for security purposes, will be
conducted in a manner consistent with all existing policies adopted by the
B.O.M including Non-discrimination Policy, Bullying and Harassment in the
Workplace Policy, Sexual Harassment Policy and other relevant policies
including the provisions set down in Equality and other Education related
legislation.
The industry code of practice for video monitoring prohibits monitoring
based on the characteristics and classifications contained in Equality and
other related legislation e.g. race, gender, sexual orientation, national
origin, disability etc.
Video monitoring of public areas, for security purposes within the said
establishment is limited to uses that do not violate the reasonable expectation
to privacy as defined by law.
The Principal will periodically provide written material describing the
purpose and location of CCTV monitoring and guidelines for its use. The
location of outdoor CCTV cameras will also be indicated to the Board. Data from
CCTV system will be accessed and used in accordance with Data Protection
Regulations.
Cameras will be located in the following internal areas:
·
2 cameras outside toilet
areas on ground floor and 1 camera outside of the toilet area on the first
floor.
·
2 cameras in the study hall.
·
4 cameras covering the
entrances to the building.
·
4 cameras covering the
stairwells
·
5 cameras covering the
corridors on the first floor.
·
8 cameras covering the
corridors on the ground floor.
Cameras will be located in the following external areas:
·
4 in the senior yard, 2 of
which are on the corner of the sports pavilion and 2 on the external walls of
rooms 37 and 38.
·
3 in the junior yard, 2 of
which are on the corner of the computer room and 1 on the external wall of room
6
Signage will be erected in each location in which a
camera is located. The signage will include the name and contact detail of the
data controller as well as the specific purposes for which the CCTV camera is
in place in each location, for example:
· to
deter/detect bullying
· to
deter/detect crime, theft and vandalism
· to
ensure compliance with school’s Code of Behaviour
· as
an aid to security
· for
Health & Safety purposes
· to
enable the school to discharge its duty of care.
Staff, students and parents/guardians will be
informed of the existence and purposes of the CCTV system as outlined above.
The right of access for students and staff to images captured by CCTV cameras
shall be in accordance with the Data Protection Acts 1998 & 2003 as
outlined below.
DATA PROTECTION
All personal data recorded and stored by the CCTV
system is governed by the Data Protection Acts, 1988 & 2003. Under the Data
Protection Acts, a ‘Data Controller’ is the individual or the legal person who
controls and is responsible for the keeping and use of personal information in
manual files or in computerised form. The Data Controller in respect of images
recorded and stored by the CCTV system in the school is the Principal on behalf
of the Board of Management.
The personal data recorded and stored by the CCTV
system will only be available to the Data Controller and will be used only for
the purposes outlined on the signage. The CCTV system shall not be used to
monitor staff performance or conduct.
Individuals whose images are recorded and stored by
the CCTV system shall have the right to request and receive a copy of personal
data processed by the system. Such requests shall be made in writing to the
Data Controller and shall be complied within a maximum of 40 days.
Personal data recorded by the CCTV system shall be
retained for a maximum of 28 days. Thereafter, it will be deleted
automatically.
The recorded footage and the monitoring equipment
shall be securely stored in the Deputy Principal’s office. Unauthorised access
to that office is not permitted at any time. The office is locked when not
occupied by the Deputy Principal.
The following procedures shall be followed in the
event that An Garda Siochana seek to view or take a copy of CCTV footage from
the School’s CCTV system.
1. The
Data Controller shall satisfy himself/herself that there is an investigation
underway by telephoning the Garda Station or the requesting Garda and speaking
to the Station Sergeant or higher or to a member in the District Office.
2. A
request from An Garda Siochana must be made in writing on Garda headed
notepaper.
All CCTV systems and associated equipment will be
required to be compliant with this policy following its adoption by the B.O.M.
Responsibilities:
The Principal will:
·
Ensure that the use of CCTV systems is implemented in
accordance with the policy sent down by the B.O.M.
·
Oversee and co-ordinate the use of CCTV monitoring
for safety and security purposes within the school.
·
Ensure that all existing CCTV monitoring systems will
be evaluated for compliance with this policy
·
Ensure that the CCTV monitoring at Moyle Park College
is consistent with the highest standards and protections.
·
Review camera locations and be responsible for the
release of any information or material in compliance with this policy.
·
Maintain a record of the release of discs or any
material recorded or stored in the system.
·
Ensure that material is not duplicated for release.
·
Ensure that the perimeter view from fixed location
cameras conform to this policy both internally and externally.
·
Provide a list of the CCTV cameras and the associated
monitoring equipment and the capabilities of such equipment located in the
school to the B.O.M for formal approval.
·
Approve the location of temporary cameras to be used
during special events that have particular security requirements and ensure
their withdrawal following such events.
NOTE (Temporary cameras does not include mobile video
equipment or hidden surveillance cameras used for criminal investigations)
·
Give consideration to and refer to the B.O.M both
students and staff petitions regarding possible invasion of privacy or
confidentiality due to the location of a particular CCTV camera or associated
equipment.
·
Ensure that all areas being monitored are not in
breach of an enhanced expectation of the privacy of individuals within the
school and be mindful that no such infringement is likely to take place.
·
Advise the Board to ensure that adequate signage, at
appropriate and prominent locations is displayed and included the following in
such signage.
“This Area is subject to Video Monitoring by the
School Management Authority”
·
Ensure that external cameras are non intrusive in
terms of their positions and views of residential housing and comply with the
principle of “Reasonable Expectation of Privacy”
·
Ensure that monitors are stored in a secure place
with access by authorized personnel only.
·
Ensure that recorded material is retained for period
not longer that 28 days and will then be erased unless required as part of a
criminal investigation or court proceedings (criminal or civil) or other bona
fide use as approved by the B.O.M.
·
Ensure that camera control is solely to monitor
suspicious behaviour and not individual characteristics.
·
Ensure that camera control is not in breach of the
intrusion on intimate behaviour by persons in public areas.
· Ensure
that mobile video equipment will only be used for criminal investigations and
with the approval of the B.O.M. and the local Garda Authorities.