CCTV Policy

The Company operates Closed Circuit Television (CCTV) systems installed on its premises, to assist with the better management of the premises. There will be no covert operation of this system, all camera sites are clearly visible. Staff should note that the system will be closely monitored and any attempt to interfere with the system will be treated as a potential act of Gross Misconduct.

The CCTV installations listed in ISMS record SC-Z_CCTV Systems, and used by Curtins, may be used for prevention, investigation and detection of crime, public and employee safety, security of premises and for monitoring all movement of people and vehicles around the premises.

This CCTV system and the images produced by it are controlled by Sian Peters (IT Manager), who is responsible for how the system is used and for notifying, or instructing the notification of the Information Commissioner about the CCTV system and its purpose (which is a legal requirement of the Data Protection Act 1998).

1 . Quality of Images

1.1 Digital images are recorded onto computer hard drives, located in a secure location within the protected premises. The recorded images are automatically overwritten, on average, every 30 days.

1.2 The computer hard drives identify the location of the recorded images and stamp them with the time and date of the recording, either within the image stream, or as metadata stored alongside the image stream, which enables images to be readily identified.

1.3 The CCTV cameras are set up by a specialist external contractor. They will ensure that the images are as clear as possible so they are effective for the Purpose described in paragraph 2.

1.4 The CCTV equipment should perform properly at all times. Cameras must be properly maintained and serviced to ensure that clear images are recorded. Maintenance logs should be kept and procedures put in place by the IT Manager.

2. Processing of Images

2.1 To ensure that images are not retained for any longer than is necessary the images are automatically overwritten every 30 days. The recordings will be kept in the location detailed in record SC-Z_CCTV Systems.

2.2 Images and video may be automatically sent to a backup location over the Internet when an event is detected by the system. The backup location may store event images indefinitely.

2.3 Access to recorded images is detailed in SC-Z_CCTV Systems.

2.4 Access to recorded images is restricted to employees and third parties listed in SC-Z_CCTV Systems. The CCTV roles of those who can access the system are: Duty Managers, Security Managers, System Administrators and External Maintenance Contractors.

2.5 The only direct access to the system automatically granted to an external party will be granted to the External Maintenance Contractor assigned to the system, and that access is only to be used for the purpose of maintaining the system.

2.6 Security Managers may, after considering each request on its merits and ensuing that the request is valid, approve valid requests for access by other third parties. A record of the request will be placed in SC-Z_CCTV Systems and the third party either invited to review footage on premises, or where appropriate, to access it remotely or have footage forwarded to them.

2.7 Viewing of recorded images must only take place in a private and secure office ensuring access to staff and other third parties who are not entitled to view the footage is prevented.

2.8 Security Managers will keep a log of all requests for recordings and where footage has been viewed SC-Z_CCTV Systems.

Where CCTV cameras are in operation clear signs will be visible to inform employees of the Company, visitors and the public that they are entering an area covered by CCTV.

Individuals whose images are recorded have a right to view the images of themselves (a Subject Access Request) and, unless they agree otherwise, to be provided with a copy of the images. This will be provided within 30 calendar days of receiving a request and an administration fee of £10 will apply.

Subject Access Requests must be forwarded to the appropriate system’s security manager(s) who can arrange this for them.  Subject Access requests can be made:

By telephone on 0151 726 2000

By email at cctv-enquiries@curtins.com

In writing to: CCTV Enquiries, Curtins, 51-55 Tithebarn Street, Liverpool, L2 2SB

Any CCTV images must be adequate for the purpose for which they are being collected. It is essential that camera equipment and locations which achieve the purposes for which the company is using CCTV. Both permanent and movable cameras should be sited and image capture restricted to ensure that they do not view areas that are not of interest and are not intended to be the subject of surveillance. The cameras must be sited and the system must have the necessary technical specification to ensure that images are of the appropriate quality.

The cameras been installed so they are not directed specifically to capture images of Employees in their regular work location (e.g. at their desk), but for security purposes i.e. preventing and detecting crime. Where the recording of employees is unavoidable in this context, the employees affected must be notified and agree to the recording taking place.  If they do not agree to it, the system must be altered to their satisfaction, or that element of the system disabled.

Any complaints about the operation of any of the Company’s CCTV systems should be made:

By telephone on 0151 726 2000

By email at cctv-enquiries@curtins.com

In writing to: CCTV Enquiries, Curtins, 51-55 Tithebarn Street, Liverpool, L2 2SB