For the purpose of the Policy the following definitions will apply:
- ‘CCTV’ is Closed Circuit Television System.
- ‘Campus Security’ refers to University of Stirling Security Team.
- ‘Data Controller’ is the University of Stirling.
- ‘University’ refers to the University of Stirling.
This Policy is binding on all employees and students of the University of Stirling and all employees of contracted out services. It also applies to all other persons who maybe present, for whatever reason, on the University of Stirling property.
2.0 Ownership and operation
The CCTV system is operated by the University of Stirling Security whose personnel are employed directly by the University. The CCTV system, all recorded material and copyright are owned by the University.
The system is intended to provide an increased level of security in the University environment for the benefit of those who study, work, live in or visit the campus.
The following principles will govern the operation of the CCTV system:
- The CCTV system will be operated fairly and lawfully and only for the purposes authorised by the University;
- The CCTV system will be operated with due regard for privacy of the individual;
- Any changes to the purposes for which the CCTV system is operated will require the prior approval of the Director of Estates and Campus Services.
4.0 Purpose of the CCTV system
The system is intended to provide an increased level of security within the University environment for the benefit of those who study, work, live in or visit the campus.
The CCTV system will be used to respond to the following key objectives:
- Detect, prevent or reduce the incidence of crime.
- Assist with the apprehension and prosecution of offenders.
- Prevent and respond effectively to all forms of harassment and public disorder.
- Improve communications and the operational response of security patrols.
- Reduce the fear of crime and create a safer community.
- Gather evidence by a fair and accountable method.
- Provide emergency services assistance.
- Assist with health and safety issues by detecting potential incidents.
- Investigate suspected breaches of the University Regulations.
- Protecting the physical environment.
As community confidence in the system is essential, all cameras will be operational taking into account short periods for maintenance and repair. An appropriate maintenance programme is in place. All operators of the system will receive appropriate training.
5.0 System details
The CCTV system consists of centrally controlled and monitored cameras situated on University property that monitor and record activities within key areas. The security control room is staffed 24 hours-a-day by members of campus security. All access to the Control Room for whatever purpose will be routinely monitored and recorded.
6.0 Installation and signage
Cameras shall be installed in such a manner as not to overlook private domestic areas. Cameras shall not be hidden from view and signs will be prominently displayed at main entrances to the University and other key locations. The signs will indicate:
- The presence of monitoring and recording
- That images are being monitored and recorded for the purposes of crime prevention and public safety
- Ownership of the system
- Contact details for Campus Security - 01786 467003 / email@example.com
If at any time mobile cameras are employed, their use will also be governed by this Policy and appropriate temporary signage or announcements will be made.
7.0 General data protection regulations
Where images of living, identifiable individuals are deliberately recorded, this is likely to comprise those individuals’ personal data. The collection, use and storage of personal data are governed by the General Data Protection Regulations (GDPR) and the Data Protection Act 2018. The University is registered with the Information Commissioner as a Data Controller.
The University uses CCTV for the purposes detailed above. The legal basis for this processing is that it is in the legitimate interests of both the University, its staff and students and members of the public visiting campus to maintain a safe environment.
Given that any particular sequence of CCTV recording may include personal data, all such recordings will be treated in accordance with the Data Protection legislation.
Data subjects’ rights, including a right of access to their personal data, (in accordance with Article 15 of the GDPR), will be respected where recordings are confirmed to comprise personal data. Get more information about data subject rights. Where an individual requests access to recordings believed to be their personal data, the matter shall be referred to the University’s Data Protection Officer (firstname.lastname@example.org).
8.0 Access to live footage and recordings including personal data
Access to live footage
Images captured by the system will be monitored in the Security Control Room which is a self-contained secure room. For operational purposes, and in accordance with the stated purposes of the system, the live CCTV footage is only monitored by designated security staff, trained in their duties.
Non-essential access to the CCTV Control Room is controlled.
Live images may be viewed at any time by the police, however the police do not have the power to record the images or to re-position or focus the cameras directly.
Access to recordings
For operational purposes and in accordance with the stated purposes of the system, only designated security staff shall have primary access to CCTV recordings. Access may be granted to the police if appropriate and the requisite data release form is completed.
The Security Operations Manager or nominee may permit the viewing of the CCTV recorded materials by other University staff where this is necessary in connection with the purposes detailed above such as prevention of crime, assisting in the apprehension and prosecution of offenders, enforcing University regulations or matters of national security.
Where University staff or any other person requires access to CCTV recorded materials that contain identifiable individuals for any other purpose, the matter shall be referred to the Security Operations Manager and the Data Protection Officer.
Disclosure of Recorded Material - as the main purpose of the CCTV system is to prevent crime and assist in the apprehension and prosecution of offenders, designated security staff may release CCTV recorded materials to the police where the University has initiated contact with the police and there is a reasonable belief that the CCTV recorded materials will be of assistance.
Where the police or other official body with prosecuting powers approach the University and request access to CCTV recorded materials they shall be asked to provide appropriate documentation confirming that the information is necessary for either the prevention of crime or the apprehension or prosecution of offenders, matters of national security or is necessary in connection with legal proceedings.
In all cases where recorded materials are disclosed outside the University, the appropriate security officer shall ensure that the disclosure is logged and duly signed for.
Where recordings contain no identifiable individuals or other personal data such as visible registration numbers, footage may be releasable under the Freedom of Information (Scotland) Act 2002 (FOISA). Requests received under FOISA will be dealt with by the Freedom of Information Unit.
9.0 Retention of recorded materials and disposal
CCTV recordings and other materials produced from them shall be retained for a maximum of 30 days unless an incident is recorded which requires further investigation either by Campus Security/a University Officer, the police or another external body with prosecuting powers.
In the latter case, recordings shall be kept for a longer period as determined by the nature of the investigation.
All media that are no longer required, on which recordings were made will be securely and permanently destroyed and the appropriate details entered in the Destruction Records.
10.0 Breaches of code
A copy of this Policy will be made available to anyone requesting it. Any complaint concerning misuse of the system will be treated seriously and dealt with in accordance with the University’s Complaints Handling Procedures. In the first instance complaints will normally be investigated by the Security Operations Manager or nominee with advice from the Data Protection Officer when appropriate.
Any member of staff found to be in breach of this Policy shall be dealt with in accordance with the University’s staff disciplinary procedure as set out in Ordinance 68. Where appropriate, the police will be asked to investigate any matter relating to the CCTV system which is deemed to be of a criminal nature.
11.0 Contact details
If you have any questions about the operation of the CCTV system you should contact Campus Security in the first instance:
The University’s Data Protection Officer, is the University Deputy Secretary. If you have any questions relating to data protection these can be addressed to: email@example.com in the first instance.
You have the right to lodge a complaint against the University regarding data protection issues with the Information Commissioner’s Office.