CCTV code of practice

Purpose statement

It is important that everyone affected by the Norwich public space CCTV system, and those operating the service, understand exactly why the system has been introduced and what it will and will not be used for.

This code of practice sets out the aims of the CCTV system and how it will be used.

The system will not be used for any other purpose than those set out in this document.

The key objectives are:

• Reducing fear of crime, antisocial behaviour and aggression.
• Help to police the city centre effectively and maintain public order.
• Providing high quality evidence which may assist in the detection of crime and the apprehension and prosecution of offenders.
• Protecting areas and premises used by staff and the public.
• Protecting property.
• Maintaining and enhancing the commercial viability of the city and encouraging continued investment.
• Providing help with civil claims
• Providing help with issues relating to public safety and health
• Providing help and reassurance to the public in emergency situations.

Privacy

We respect and support the individual's entitlement to go about their lawful business and this is a primary consideration in the operation of the system.

The cameras are generally sited where they will not be capable of viewing any residential properties. If it is found there is a possibility that cameras would intrude in private areas, privacy zones will be programmed into the cameras where possible to prevent intrusion. CCTV operators are trained to recognise privacy issues.

A privacy notice is available on our website which explains how CCTV data is processed.

Cameras

The system consists of static and re-deployable, fully functional (pan, tilt and zoom) cameras.

All cameras are sited so that they are clearly visible, although some are mounted within protective domes. No hidden cameras will be used within this scheme, nor will the scheme use dummy cameras.

A full list of public space cameras, their location and the areas of view is available on the council’s website. There is also an interactive map pinpointing camera locations.

Remote deployable CCTV cameras are designed to be deployed into other areas of the city on a temporary basis for pre-determined periods of time. The use of these cameras is governed in the same way as the fixed position cameras. They will be operated in accordance with this code of practice and relevant legislation.

The remote deployable CCTV cameras will only be used to support wider community safety initiatives as part of a multi-agency problem solving approach. There will be a clear indication of expected and measurable outcomes to make sure the problem does not continue once the cameras are removed. A data protection impact assessment will be completed each time a camera is deployed in a new location.

Fixed cameras are recording simultaneously throughout 24-hour periods, 365 days each year. The remote deployable cameras are recording throughout 24-hour periods for the duration of the deployment.

Signage

Areas covered by CCTV will be indicated by the presence of signs. The signs are placed so that the public are aware that they are entering a zone which is covered by surveillance cameras.

This will ensure that the maximum deterrent value is achieved and the public are clearly aware when they are in a monitored area.

The signs will state that Norwich City Council is responsible for the system and include a contact telephone number.

Legislation

Norwich City Council is registered with the Information Commissioner’s Office and will follow the guidelines of the General Data Protection Regulations (GDPR), Data Protection Act 2018, and the principles of good practice identified by the Biometrics and Surveillance camera commissioner.

In addition, the operation of the system will comply with the Human Rights Act 1998, the Freedom of Information Act 2000, the Protection of Freedoms Act 2012, and the Regulation of Investigatory Powers Act (RIPA) 2000.

The council has a separate policy that covers RIPA. Separate procedures are in place to respond to requests and authorisations for covert surveillance. RIPA does not cover the normal, everyday use of overt CCTV surveillance cameras and schemes.

Further information regarding this legislation is available at www.gov.uk.

Accountability

The executive director of community services is responsible for all functions of the council relating to CCTV provision and management.

This code of practice will be available on the CCTV pages of the council’s website.

The council has a formal complaints procedure which can be used to raise concerns about the use and operation of CCTV.

Control room operation and administration

Staff

• The control room will be staffed during peak times. Operators employed by the council are trained to a proficient level and licensed by the Security Industry Authority.
• Training includes:
• Use of equipment
• Observation techniques
• Council procedures and record keeping
• Reporting procedures and action on incidents
• Evidence handling
• Actions in the event of an emergency
• Legislation and crime prevention
• Operational exercises.

All operators have a responsibility of confidentiality and have responsibility for their own actions to protect information and data given in accordance with the council’s corporate policies.

Staff may be required to provide the police with statements if required for evidential purposes.

Operating Efficiency

The first duty operator on shift will carry out a check to confirm the operational efficiency of the system and the link to the Police. Any defects will be reported to the maintenance contractor’s service desk. They will be logged, and remedial action will be taken.

All use of the cameras shall accord with the purposes and key objectives of the scheme and shall comply with the code of practice. CCTV monitoring operators will maintain a log of all incidents monitored. It will detail relevant actions taken by the operator and the reasons why, in accordance with legislation and this code.

Access

The control room has a secure entrance lobby for added privacy and this will always remain secured. Routine access to the control room will be limited through an electronic door entry system to:

• Duty CCTV staff
• Designated officers of the council

Arrangements will apply to visitors and contractors as outlined below.

Visitors

Organised visits for viewing the operation of the system will be arranged from time to time. These visits may be subject to change or termination at short notice to meet operational requirements. Operation of equipment will only be carried out by the duty operator. Visitors may be asked to make their request in writing specifying the reasons for that request.

It is important that operations are managed with minimal disruption. Casual visits will not be permitted. All visitors will sign a log detailing their name, organisation, purpose of visit and their arrival and departure times. This log will be subject to regular audit and assessed to ensure compliance with the code of practice.

Contractors

Access for contractors will be necessary from time to time for the purpose of maintaining the control room and its equipment. This will be strictly limited to the work they are there to carry out.

Police

The Police should not require access to the control room unless specifically designated or authorised. Police officers attending unexpectedly shall only be admitted after the purpose of the visit has been approved by contact with the acting community safety manager, early intervention or community safety officer. Their attendance will be logged.

Communications

A monitor is installed in the police control centre to enable live viewing of images. Pictures from any of the cameras may be relayed to this monitor at the instigation of the CCTV operator or at the request of the duty police officer. The police have no direct control of any cameras nor images relayed to their monitor. They do have access to recorded footage and access is strictly controlled and subject to a separate joint protocol.

A dedicated radio link with the police control room is provided for communication.

Operators are also able to communicate via separate radio link with users of Norwich BIDs Alert radio scheme.

Control of cameras

Control over the cameras is limited to the council’s trained officers only.

The monitoring operators must only use the cameras to view public areas and not to look in the interior of any private premises or any other area where an infringement of privacy of individuals may occur. The only exceptions to this rule are:

• if an authorised operation is mounted under the Regulation of Investigatory Powers Act (see separate policy)
• an immediate response to a police or other enforcement agencies’ request for assistance following a crime being committed
• if an operator, whilst operating the cameras in accordance with this code of practice, happens to observe something which they believe indicates that a serious crime is being or is about to be committed in a non-public area.

Any event where an operator takes a decision positively to view or continue viewing a private area must be entered into the incident log. The details must include location, time, date, camera number and the reason for the observation. Operators will be required to justify their actions. Any breach of this condition of employment will result in disciplinary proceedings and may lead to the dismissal of the operator.

Police role

The Police may request assistance and access to images to:

• Assist with the deployment of resources
• Monitor potential public disorder or other major security situations
• Assist in the detection of crime
• Facilitate the apprehension and prosecution of offenders in relation to crime and public order
• Assist with the detection of moving traffic offences where public safety is at risk.

In these circumstances the police duty operator may request the duty CCTV monitoring operator to take further action. Where problems are anticipated or during large scale public events, arrangements can be made with the acting community safety manager for a police officer to be present within the CCTV control centre for liaison purposes.

Trained police officers have access to the council’s CCTV system for the purpose of reviewing recorded footage. There is a separate protocol covering this to make sure this is conducted within guidelines and only as part of a current ongoing legitimate investigation or operation.

Major incidents and events

Use of the CCTV system will be integrated into the council's emergency planning procedures during major civil emergencies and events. If required, the chief executive officer or their designated deputy will authorise the deployment of a liaison officer into the CCTV control room.

The duty CCTV monitoring operator will maintain control of the cameras. They will give assistance as required in all matters concerning the deployment and use of the facilities within the CCTV control room.

A police officer may also be deployed in the CCTV control room during major incidents and events. This will only be where prior arrangement has been made and agreed by the acting community safety manager.

Control of images and recording media

Recording

Recordings may need to be submitted as evidence in criminal proceedings and therefore must be of good quality and be accurate in content. All material will be treated in accordance with strictly defined procedures to provide continuity of evidence and to avoid contamination of the evidence. Recorded material will not be sold or used for commercial purposes or the provision of entertainment.

The showing of recorded material to the public is only permitted if it complies with the needs of the police in connection with the investigation of a crime, or other circumstances provided by law.

Routine recordings are automatically retained for 31 days and then overwritten and deleted by the system. This is considered a reasonable length of time to allow any access requests for footage to be made.

In certain circumstances images may be retained in the system locker to prevent automatic deletion. This will be where there is the possibility for them to be used for evidential purposes or an access request is being processed. Images will not be retained in the system locker for longer than is necessary.

Control of Media

All images reproduced on any media will remain the property of the council. The council retains copyright of all images.

Each new downloaded recording must be clearly and uniquely marked before it is brought into operation.

At each use the identification number of the media, date, time of insertion, and time of removal shall be noted in the media log.

The release of media containing images from the control room must be strictly controlled under all circumstances. All media should be erased where possible prior to secure disposal.

Access to Images

The main source of requests for access to images is expected to be from the police or other enforcement agencies.

Data protection legislation and GDPR allows individuals to see or be informed about any data held about them. Since data is only stored for a maximum of 31 days, requests must be made via the appropriate online application form within 21 days to allow the relevant data to be saved.

There may be circumstances in which the council is required to release images in connection with civil disputes. Requests involving civil disputes are subject to a £100 fee payable in advance of the footage being released.

Access to media containing the images or video print image evidence for lawyers acting for defendants or victims in connection with criminal proceedings will be provided under the Disclosure of Evidence Act. This is provided by the police, crown prosecution service, or enforcement agency dealing with the case.

No other access will be allowed unless approved by the council’s Information Governance Manager.

Evidential media

Media required for evidence will be dealt with in accordance with The Police and Criminal Evidence Act 1984 (PACE). Only authorised officers may remove these media recordings from the control centre to a secure store.

Media containing images provided to the police or other agencies shall at no time be used for anything other than the purposes for which they were originally released.

Review and evaluation

Revision and change to the code of practice will inevitably occur during the life of the CCTV scheme. It will be reviewed annually to ensure it is up to date.

CCTV operations will be subject to regular review against the objectives of the scheme. Improvements to operating procedures will be made as soon as they are identified.

Comments and complaints

Comments or enquiries regarding the system can be made via our contact us page or by emailing CCTVrequests@norwich.gov.uk.

Further information about the system and application forms to request footage are available through the CCTV pages of our website.

Complaints about the operation of the system should be made as soon as possible after the incident or the CCTV action causing the complaint. They will be dealt with in accordance with the council’s formal complaints procedure.

Contact addresses

Norwich City Council
City Hall
St Peters Street
Norwich NR2 1NH
Tel: 0344 980 3333

Information Commissioner‘s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Tel: 0303 123 1113 (local rate)
Tel: 01625 545 745 (national rate)

Biometrics and Surveillance Camera Commissioner
Po Box 29105
London SW1V 1ZU
Tel: 0171 825 3421