CCTV Policy

Purpose:

  • To ensure the continuing security of the premises.

  • To prevent or take action, relating to crime against the building or those using it

  • To allow us to monitor and deal with any breach of compliance with building use agreements.

 

Policy maintenance and review:

  • To be reviewed every two years or when the law changes.

  • The Elders as Trustees act as Data Controller and are responsible for approving and reviewing this policy.

 

Associated policies:

System control:

  1. The system will be controlled by Martin Morris (‘Manager’) and two named deputies.

  2. Images and sound will be recorded only if movement is detected (not on continuous loop).

  3. The system cameras will be positioned in three main areas: Octagon Entrance, Allotment Entrance, and the Kings Lane Entrance. Whilst the system cannot be timed to be active outside of meeting times, any activation will be ignored that takes place during known organisation/church meetings.

  4. If unauthorised movement has been detected by the Manager, the police will be called to investigate if deemed appropriate.

  5. Images may be viewed by the Manager or two named deputies if they consider that this is necessary related to our purpose stated above. Images will not be stored in any cloud-based format nor on computer or mobile device on a day-to-day basis.

  6. Images will only be recorded to the data card within each camera. These are positioned out of general reach. Should access be required to any card images, the Manager will be accompanied by one deputy for this purpose and the appropriate recorded images downloaded onto the church laptop and encrypted.

  7. Images may be viewed and passed to the police if a crime is thought to have been committed.

  8. Data will be kept for up to a maximum of 30 days, after which it will be overwritten, unless it is subject to a police investigation. However, images used as evidence which result in a conviction are required by law to be kept securely for the duration of the sentence, which could be more than 20 years. Such images will be securely locked away.

  9. Recorded images should have the time and date superimposed on them.

  10. The system will not be used to provide images to any online platform or disclose images to the media.

 

Subject Access Requests

To be made to the Elders via the Manager (manager@grangeurc.org.uk). Such requests will be dealt with within 30 days and an administration charge of £10 will be applied. CCTV image extracts for a Subject Access Request will be encrypted onto an MP4 file format to be accessed by the data subject on his/her personal computer. Once the data subject confirms the safe receipt of the MP4 file, the Manager will disclose the password used to access the file. Requests for access to CCTV images must include (a) The date and time the images were recorded, (b) Information to identify the individual, if necessary and (c) Proof of Identity.

 

Access to images by third parties

Third parties who wish to have a copy of CCTV images (i.e., images not of the person making the request) do not have a right of access to images under the General Data Protection Regulation (GDPR). Care must be taken when complying with such requests to ensure that neither the GDPR, Human Rights Act nor the CCTV Policy are breached. Requests from third parties will only be granted if the requestor falls within the following categories:

  • Law enforcement agencies (where the images recorded would assist in a specific criminal enquiry)

  • Prosecution agencies

  • Grange URC Management Committee or Eldership for any legitimate purpose to assist with the safe operation of the church premises.

 

 

The Elders, Grange United Reformed Church, Kings Road, Bebington CH63 8LX

First approved by the Church Meeting xxxx