Video Surveillance Systems Policy
This policy covers Video Surveillance Systems in place at the Guild of Students. These currently include Close Circuit Television (CCTV) and Body Worn Video (BWV).
The Guild of Students is committed to ensuring that all our surveillance systems are compliant with data protection law including the EU General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA). Images captured can be personal data and are covered by these laws. The Guild will also comply with its Privacy Statement in operating surveillance systems in the Guild.
It is essential therefore, that:
- Those capturing images of individuals comply with the GDPR and DPA and the Guild’s Privacy Statement;
- Captured images are usable; and
- Those whose images are captured are reassured that their rights are properly protected.
Failure to comply with Data Protection requirements will also affect the police’s ability to use the images to investigate a crime and may hamper the prosecution of offenders.
The Guild as Data Controller is responsible for the overall control of the footage and recorded images as part of the Guild’s Data Protection Policy. Managers responsible for the day to day operation of the surveillance system include:
- Venues Management
- Facilities Management
- IT Services
The Guild’s surveillance system is primarily established to prevent and detect crime. Therefore, the Guild’s surveillance images and footage will be disclosed to law enforcement agencies where a crime needs to be investigated.
Judgments relating to the disclosure of images to those other than law enforcement agencies, are made by the Guild of Students Data Protection Officer or CEO. The Guild retains the right to refuse any request for information unless there is an overriding legal obligation.
The Guild will also use surveillance footage as necessary in the investigation of complaints and potential disciplinary investigations, subject to the approval of the Data Protection Officer/CEO.
Guild surveillance footage is retained automatically for one calendar month unless a request is made for longer retention with good reason, for example because a crime or complaint is still being investigated, and the DPO and/or CEO agree to such request. If this is the case it will have to be saved to a disc and this will be completed by the Facilities or Venue Management and stored securely.
4. Subject Access Requests
Subject Access Requests should be made to the Guild of Students HR & Administration Manager/Data Protection Officer directly and will be responded to within 1 month. Once a request is made, efforts will be made to identify and retain any relevant images beyond the usual calendar month so that they can be disclosed if required, even if it takes up to 1 month to respond to the subject access request.
Adequate signage is displayed throughout the building, to ensure Guild’s members and customers are aware that surveillance systems are in operation throughout the Guild building.
The Guild conducts annual reviews to help to ensure that the surveillance system remains compliant with the requirements of the Act and that the system is working properly and producing high quality images.
7. Further Information
For further information about your rights in relation to CCTV at the Guild, including how to raise any concerns you may have and how to make a subject access request, please see the Guild of Students Privacy Statement, which can be found at https://www.guildofstudents.com/privacy-policy/