Policy on CCTV Systems and Data Management

The Closed Circuit Television System (CCTV) is installed in Coláiste Phádraig CBS under the remit of the Board of Management.

Purpose of the Policy

The purpose of this policy is to regulate the use of CCTV and its associated technology in the monitoring of the environs of premises under the remit of the Board of Management of Coláiste Phádraig CBS.

Purpose of the CCTV System

The CCTV system is 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 and Safety and to the discharge of the school’s duty of care within and/or in the external environs of the premises at all times.

Scope of this policy

This applies to all personnel in and visitors to Coláiste Phádraig CBS.  It relates directly to the location and use of CCTV, the monitoring, recording and subsequent use of such recorded material.

General Principles

The Board of Management of Coláiste Phádraig CBS, as the corporate body, has a statutory responsibility for the protection of the school property and equipment as well as providing a sense of security to its employees, students and invitees to its premises.  Coláiste Phádraig CBS 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 in Coláiste Phádraig CBS by integrating the best practices governing the surveillance of its premises.

The primary aim of the CCTV monitoring of Coláiste Phádraig CBS 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.  For example CCTV monitoring of political or religious activities, or employee 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 authorised 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 Board of Management 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 classifications contained in Equality and other related legislation e.g. gender, marital status, family status, sexual orientation, religion, age, disability, race or membership of the Traveller community.

Video monitoring of public areas, for security purposes, within the said establishment, is limited to areas that do not violate the reasonable expectation to privacy as defined by law.

Data from the CCTV system will be accessed and used in accordance with Data Protection Regulations.

Cameras will be located in the following areas:

Internal

• The Reception and Student Entrances
• All Corridor & Locker Areas
• Student Resource Areas
• Study Hall
• Canteen
• Careers Library.

External

• The Reception and Student Entrance
• Path along Pitch Side of School
• Staff Car Park Area
• Main School Entrance
• Senior Yard Area
• Bike Racks between Main School & Sports Hall.

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 purpose for which the CCTV camera is in place in each location.

Staff, students and parents/guardians will be informed of the location and purpose of the CCTV system as outlined above.  The right to access images captured by CCTV cameras shall be in accordance with the Data Protection Acts of 1998 and 2003.

Data Protection

All personal data recorded and stored by the CCTV system is governed by the Data Protection Acts of 1998 and 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 a 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.

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 with 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 Principals and Deputy Principals office .  Unauthorised access to these offices is not permitted at any time.

The following procedures shall be followed in the event that An Garda Síochána seeks to view or take a copy of CCTV footage from the school’s CCTV systems:

1. The data controller shall satisfy himself/herself that there is an investigation underway.
2. A request from An Garda Síochána must be made in writing on Garda headed notepaper.

All CCTV systems and associated equipment will be required to be compliant with this policy.

Responsibilities:

The Board of Management will:

• Ensure that a policy is in place, compliant with relevant legislation, to govern the use of CCTV in the school.
• Ensure this policy is reviewed regularly by the Board of Management.

The Principal will:

• Act as Data Controller on behalf of the Board of Management.
• Ensure that the use of the CCTV system is used in accordance with the policy set down by the Board of Management.
• Oversee and co-ordinate the use of CCTV monitoring for safety and security purposes within the school.
• Ensure that all CCTV monitoring systems are compliant with this policy.
• Be responsible for the release of any information or material in compliance with this policy.
• Maintain a record of the release of any material recorded or stored on this system.
• Provide a list of the CCTV cameras, their locations and the associated monitoring equipment and the capabilities of such equipment to the Board of Management 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.
• Ensure that all areas being monitored are not in breach of a reasonable expectation of the privacy of individuals within the school.
• Advise the Board of Management to ensure that adequate signage, at appropriate and prominent locations, is displayed.
• Ensure that external cameras are not intrusive in terms of their positions and views of residential housing and comply with the principle of “reasonable expectation of privacy”.
• Ensure that recorded material is retained for a period not longer than 28 days and will 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 Board of Management.
• Ensure that monitors are stored in a secure place with access by authorised personnel only.