CCTV Policy

This policy supports the Rights Respecting principles adopted by Lady Margaret Primary School and is particularly relevant to the following articles:

UNICEF – Convention on the Rights of the Child (CRC)

Article 3
The best interests of the child must be a top priority in all things that affect children.

Article 19
Governments must do all they can to ensure that children are protected from all forms of violence, abuse, neglect and bad treatment by their parents or anyone else who looks after them.

UNICEF – Convention on the Rights of the Child (CRC) Article 3 The best interests of the child must be a top priority in all things that affect children. Article 19 Governments must do all they can to ensure that children are protected from all forms of violence, abuse, neglect and bad treatment by their parents or anyone else who looks after them.

Introduction 

The school recognises that CCTV systems can be privacy intrusive.  This policy aims to set out the school’s approach to the operation, management and usage of surveillance and closed-circuit television (CCTV) systems on federation property 

Objectives 

Review of this policy shall be repeated regularly and whenever new equipment is introduced, a review will be conducted and a risk assessment put in place. We aim to conduct reviews no later than every two years.   

The purpose of the CCTV system is to assist the federation in reaching the following objectives: 

  • To protect pupils, staff and visitors against harm to their person and/or property; 
  • To increase a sense of personal safety and reduce the fear of crime; 
  • To protect the school buildings and assets; 
  • To support the police in preventing and detecting crime; 
  • To assist in identifying, apprehending and prosecuting offenders; 
  • To assist in establishing cause of accidents and other adverse incidents and prevent reoccurrence; and  
  • To assist in managing the schools within the federation 

Purpose of this policy 

The purpose of this policy is to regulate the management, operation and use of the CCTV systems (closed circuit television) at the schools in the federation. The CCTV system used by the federation comprises of: 

Camera 1Main office reception
Camera 2Main staff car park
Camera 3South staff car park
Camera 4Vehicle gate
Camera 5Upper hall
Camera 6Nursery entrance
Camera 7Year 2/3 corridor
Camera 8Playground access gate
Camera 9North pedestrian gate
Camera 10Year 1 corridor
Camera 11Dining hall
Camera 12First floor south corridor
Camera 13First floor north corridor
Camera 14Lower hall corridor
Camera 15Quiet playground equipment
Camera 16Main playground
Camera 17Main playground north
Camera 18Reception outdoor learning space
Camera 19EYFS corridor
Camera 20North playground
Camera 21North playground exit
Camera 22Quiet playground
Camera 23School office corridor
Camera 24Nursery corridor
Camera 25Quad playhouse
Camera 26Nursery outdoor learning space
Camera 27Staff room corridor
Camera 28Library
Camera 29Year one playground
Mobile cameraLower hall corridor north

CCTV cameras are not installed in areas in which individuals would have an expectation of privacy such as toilets, changing facilities, etc

System management 

Access to the CCTV systems and data shall be password protected and will be kept in a secure area. 

The CCTV systems will be administered and managed by Amanda Hancock – Head of Business who will act as System Manager for the federation and take responsibility for restricting access, in accordance with the principles and objectives expressed in this policy. In the absence of the Systems Manager, the system will be managed by; 

Amanda Hancock – Head of Business

Liane Simpson – Headteacher

Tomek Semczuk – Facilities Manager

The systems and the data collected will only be available to the Systems Manager, his/her replacement and appropriate members of the senior leadership team as determined by the Executive Headteacher   

Statement of Intent 

CCTV cameras are installed in such a way that they are not hidden from view. Signs are predominantly displayed where relevant so that staff, students, visitors and members of the public are made aware that they are entering an area covered by CCTV. The signs also contain contact details as well as a statement of purposes for which CCTV is used.  

The CCTV system will seek to comply with the requirements both of the Data Protection Act and the most recent Commissioner’s Code of Practice. 

The federation will treat the systems, all information, documents and recordings (both those obtained and those subsequently used) as data protected under the Act. 

The system has been designed so far as possible to deny observation on adjacent private homes, gardens and other areas of private property. 

Materials or knowledge secured as a result of CCTV will not be used for any commercial purpose. 

Images will only be released to the media for use in the investigation of a specific crime with the written authority of the police. Images will never be released to the media for purposes of entertainment. 

The planning and design has endeavoured to ensure that the system will give maximum effectiveness and efficiency but it is not possible to guarantee that the system will cover or detect every single incident taking place in the areas of coverage. 

Warning signs, as required by the Code of Practice of the Information Commissioner will be clearly visible on the site and make clear who is responsible for the equipment.  

Where wireless communication takes place between cameras and a receiver, signals shall be encrypted to prevent interception.   

CCTV images are not retained for longer than necessary, taking into account the purposes for which they are processed. Data storage is automatically overwritten by the systems after a period of 30 days.  

Recorded images will only be retained long enough for any incident to come to light (e.g., for a theft to be noticed) and the incident to be investigated. In the absence of a compelling need to retain images for longer (such as an ongoing investigation or legal action), data will be retained for no longer than 6 months. 

Operation of the CCTV system

The CCTV systems are designed to be in operation 24 hours each day, every day of the year, though the federation does not guarantee that it will be working during these hours. 

The System Manager will check and confirm the efficiency of the systems regularly and in particular that the equipment is properly recording and that cameras are functional. 

Cameras have been selected and positioned so as to best achieve the objectives set out in this policy in particular by proving clear, usable images.   

Unless an immediate response to events is required, cameras will not be directed at an individual, their property or a specific group of individuals, without authorisation in accordance with the Regulation of Investigatory Power Act 2000. 

Where a person other than those mentioned above, requests access to the CCTV data or system, the System Manager must satisfy him/herself of the identity and legitimacy of purpose of any person making such request. Where any doubt exists, access will be refused. 

Details of all visits and visitors will be recorded in a system log book including time/data of access and details of images viewed and the purpose for so doing. 

Downloading captured data on to other media 

In order to maintain and preserve the integrity of the data (and to ensure their admissibility in any legal proceedings), any downloaded media used to record events from the hard drive must be prepared in accordance with the following procedures: – 

  • Each downloaded media must be identified by a unique mark. 
  • Before use, each downloaded media must be cleaned of any previous recording. 
  • The System Manager will register the date and time of downloaded media insertion, including its reference. 
  • Downloaded media required for evidential purposes must be sealed, witnessed and signed by the System Manager, then dated and stored in a separate secure evidence store. If a downloaded media is not copied for the police before it is sealed, a copy may be made at a later date providing that it is then resealed, witnessed and signed by the System Manager, then dated and returned to the evidence store. 
  • If downloaded media is archived, the reference must be noted. 
  • If downloaded media is put onto a device, the device will be encrypted and password protected.  

Images may be viewed by the police for the prevention and detection of crime and by the Systems Manager, his/her replacement and the Executive Headteacher and other authorised senior leaders. However, where one of these people may be later called as a witness to an offence and where the data content may be used as evidence, it shall be preferable if possible, for that person to withhold viewing of the data until asked to do so by the police. 

A record will be maintained of the viewing or release of any downloaded media to the police or other authorised applicants.  

Should images be required as evidence, a copy may be released to the police under the procedures described in this policy. Images will only be released to the police on the clear understanding that the downloaded media (and any images contained thereon) remains the property of the federation and downloaded media (and any images contained thereon) are to be treated in accordance with Data Protection legislation. The federation also retains the right to refuse permission for the police to pass the downloaded media (and any images contained thereon) to any other person. On occasions when a Court requires the release of a downloaded media, this will be produced from the secure evidence store, complete in its sealed bag. 

The police may require the federation to retain the downloaded media for possible use as evidence in the future. Such downloaded media will be properly indexed and securely stored until needed by the police. 

Applications received from outside bodies (e.g., solicitors or parents) to view or release images will be referred to the federation’s Data Protection Officer and a decision made by a senior leader of the school in consultation with the school’s Data Protection Officer. 

Complaints about the use of CCTV 

Any complaints in relation to the school’s CCTV systems should be addressed to the Executive Headteacher. 

Requests for access by the data subject 

The Data Protection Act provides data subjects – those whose image has been captured by the CCTV systems and can be identified – with a right to access data held about themselves, including those obtained by CCTV. Requests for such data should be made to Amanda Hancock – Head of Business 

Links to other policies

  • Data protection policy
  • Privacy notices for parents, pupils, staff, governors and suppliers
  • Safeguarding policy
  • Site security and visitor management policy

Approved by the:
Data Protection Officer

Date:
1st September 2025

Last Review Date:
August 2025

Next Review Date by:
August 2026

Part of Ealing Bridges Federation