This policy was adopted on 30 August 2022 and is reviewed annually
The nursery CCTV surveillance is intended for the purposes of:
- promoting the health and safety of children, staff and visitors
- protecting the farm/ nursery building and resources.
The system comprises of 5 fixed cameras. These are placed around the nursery outside, but not in the toilets or changing areas. This is to ensure the dignity of children is maintained.
The use of CCTV to control the perimeter of the nursery for security purposes has been deemed to be justified by the nursery management. The system is intended to capture images of intruders or of individuals damaging property or removing goods without authorisation or of antisocial behaviour.
The CCTV is monitored centrally from the nursery office and is registered with the Information Commissioner under the terms of the Data Protection Act. This policy outlines the nursery’s use of CCTV and how it complies with the Act. The nursery complies with Information Commissioner’s Office (ICO) CCTV Code of Practice to ensure it is used responsibly.
All authorised operators and employees with access to images are aware of the procedures that need to be followed when accessing the recorded images. All operators are trained to understand their responsibilities under the CCTV Code of Practice. All employees are aware of the restrictions in relation to access to, and disclosure of, recorded images. A copy of this CCTV Policy will be provided on request to staff, parents and visitors to the nursery and will be made available on the website.
Storage and retention
The images captured by the CCTV system will be retained for a maximum of 30 days, except where the image identifies an issue and is retained specifically in the context of an investigation/prosecution of that issue. The images/recordings will be stored in a secure environment with a log of access kept. Access will be restricted to authorised personnel.
Supervising the access and maintenance of the CCTV System is the responsibility of the register. In certain circumstances, the recordings may also be viewed by other individuals. When CCTV recordings are being viewed, access will be limited to authorised individuals on a need-to-know basis. Files will be stored in a secure environment with a log of access to recordings kept.
When accessing images two authorised members of staff must be present. A written record of access will be made. A record of the date of any disclosure request along with details of who the information has been provided to (the name of the person and the organisation they represent), why they required it and how the request was dealt with will be made and kept, in case of challenge.
Subject Access Requests (SAR)
Individuals have the right to request access to CCTV footage relating to themselves under the Data Protection Activity / GDPR. Individuals submitting requests for access will be asked to provide sufficient information to enable the footage relating to them to be identified. For example, date, time and location.
The nursery will respond to requests within 14 calendar days of receiving the request. The nursery reserves the right to refuse access to CCTV footage where this would prejudice the legal rights of other individuals or jeopardise an on-going investigation.
A record of the date of the disclosure along with details of who the information has been provided to (the name of the person and the organisation they represent) and why they required it will be made.
Where footage contains images relating to 3rd parties, the nursery will take appropriate steps to mask and protect the identities of those individuals.
Complaints and enquiries about the operation of CCTV within the nursery should be directed to the manager of the nursery in the first instance.
The Owner will ensure:
- That the use of CCTV systems is implemented in accordance with this policy
- They oversee and co-ordinate the use of CCTV monitoring for safety and security purposes
- That all CCTV monitoring systems will be evaluated for compliance with this policy
- That the CCTV monitoring is consistent with the highest standards and protections
- They review camera locations and be responsible for the release of any information or recorded CCTV materials stored in compliance with this policy
- They maintain a record of access (e.g. an access log) to or the release of files or any material recorded or stored in the system
- That the perimeter of view from fixed location cameras conforms to this policy both internally and externally
- That all areas being monitored are not in breach of an enhanced expectation of the privacy of individuals
- That external cameras are non-intrusive in terms of their positions and views of neighbouring residential housing and comply with the principle of “Reasonable Expectation of Privacy”
- That monitoring footage are stored in a secure place with access by authorised personnel only
- That images recorded are stored for a period not longer than 30 days and are then erased unless required as part of a criminal investigation or court proceedings (criminal or civil).
- That camera control is solely to monitor suspicious behaviour, criminal damage etc. and not to monitor individual characteristics
- That under certain circumstances, the CCTV footage may be used for training purposes (including staff supervisions) or for parents/carers to view child transitions.