22/09/2024
CCTV INCLUDING THE RING DOOR BELL Policy & Procedure
Introduction
The Company is fully committed to maintaining the safety and wellbeing of our young people, any other children; their families and significant others; employees; visitors and contractors while they are with us.
This policy has been devised to ensure that clear and effective direction is provided around the use of CCTV INCLUDING THE RING DOOR BELL, where such systems are used.
To effectively balance the use of such systems with the rights to privacy of all concerned, the Company has considered, and fully recognises, its duties and obligations under both statutory and non-statutory guidance and legislation.
Rationale behind the use of CCTV AND RING DOORBELL systems
Where present, systems such as CCTV AND RING DOORBELL will be used solely for:
• Maintaining the security of the home, children, employees and visitors by acting as a visual deterrent; and
• For the prevention, reduction, detection, and investigation of crime and other incidents.
As a Company dedicated to taking all reasonably practical steps to maintain the safety of children, employees, and visitors whilst respecting their legal rights to privacy, we understand the impact that recording devices can have on feelings of individual and group dignity.
As such, any CCTV AND RING DOORBELL will only be employed to monitor the external areas of the buildings and, where possible, avoid monitoring access and exit points, as well as areas not belonging to the Company (such as other residential properties, nearby businesses, and public rights of way).
Such use will only be used to support and improve the safety of children and young people safety, with a view to reducing any restrictions that may otherwise be necessary.
If such systems are used, the purpose and nature of their use will be clearly documented in our home’s Statement of Purpose, which placing authorities will be provided a copy of prior to any placement at the home.
The use of any kind of surveillance or monitoring equipment will not be used as a default approach to monitoring children’s behaviour, neither will groups of children be subject to indiscriminate monitoring.
Procedure
The manager is responsible for the overall management and operation of any CCTV INCLUDING THE RING DOOR BELL, including activities relating to installations, recording, reviewing, monitoring and ensuring compliance with this policy.
The manager will ensure:
• The Manager will be the named person who is responsible for the operation of the systems;
• That placing authorities are made aware of any systems used and their purpose.
• Children and young people are informed of any systems used, their purpose, and how this may impact the child;
• Children and young people are afforded opportunities to ask questions throughout their placement, being encouraged to communicate any concerns they may have regarding their impact on their privacy, with the home taking these views into account.
• The installation of any external CCTV AND RING DOORBELL will be incorporated into the Statement of Purpose and Children's Guide;
• All visitors will be informed of the use of CCTV AND RING DOORBELL through the signage located at the front door.
• CCTV AND RING DOORBELL systems are used solely to maintain the safety of children, employees, and visitors. They will not be used to intentionally monitor or survey children and employees;
• Images and data captured by any systems will be stored securely and accessible only to named individuals for the purposes outlined above;
• That recorded images are retained for 14 days in order to allow time for any incident to come to light, and for this to be investigated (please see below);
• That recorded images will only be accessed should there be an incident in which their use may support maintaining the safety and well-being of children, employees and visitors. As such, their use will be reactive and so not impact on the quality of support provided in the home and/or school; and
• Regular reviews are undertaken to ensure that the use of CCTV AND RING DOORBELL remains appropriate and justified.
Unless required for evidential purposes, the investigation of an offence or as required by law, CCTV AND RING DOORBELL images will be retained for no longer than 14 days from the date of recording, after which the images will be overwritten.
Should there be an incident that requires information from the CCTV AND RING DOORBELL, this will be requested by relevant personnel and provided as needed using secure means.
How Children and Young People Will be Informed of the Use of CCTV AND RING DOORBELL Systems
The use of any monitoring or surveillance systems is recorded in the Children’s Guide which is provided to children prior to arrival or, if this is not possible and/or appropriate, on arrival.
In addition to this, children and young people will be informed on arrival at the home of any such systems, including the rationale behind their placement and use; and be provided with an opportunity to ask questions about their rights around images and data stored.
Should there be an opportunity to discuss the use of any monitoring or surveillance systems prior to a child’s stay in the home, such as a visit to the home for example, they will be informed then.
This will be followed up with future opportunities for children and young people to ask any questions they may have about the systems, and/or raise any concerns regarding their use.
How Others Will be Informed of the Use of CCTV and Ring Doorbell
During induction, employees are informed of the use of CCTV and Ring Doorbell within their place of work if this is the case.
If a system has been installed after they have joined the Company, they will be informed prior to its installation.
In all cases, employees will be provided with information around the rationale behind camera placement and use; and opportunities to ask questions about their rights around images and data stored.
Visitors will be informed prior to visiting if able, and when signing into the setting, as well as provided with information around the rationale behind camera placement and use; and given opportunities to ask questions about their rights around images and data stored.
Whilst efforts will be made to ensure viewing areas do not infringe upon public rights of way and/or neighbouring buildings and properties, where this is not possible or impractical, the home will endeavour to make individuals aware.
Where there are neighbouring properties that may be affected, or where neighbours may feel as if they are at risk of being monitored, the home will discuss with them what safeguards they have taken place to prevent this from occurring.
Where a camera may infringe upon a right of way or to entrance and/or exit points for a setting, a visible sign will be placed in an area where it is visible to visitors and passers-by alerting them of its presence.
Subject Access Requests
Requests, questions or complaints about data protection and how personal information is handled, should be submitted in writing to the Head of Service.
Requests by individual data subjects for images relating to themselves should be submitted to the Head of Service in writing along with proof of identification.
In order to locate the images on the CCTV INCLUDING THE RING DOOR BELL system, sufficient details must be provided by the data subject in order to allow the relevant images to be located and the data subject to be identified.
Where the Company is unable to comply with a Subject Access Request without disclosing the personal data of another individual who is identified or identifiable from that information, the Company is not obliged to comply with the request unless satisfied that the individual has provided their express consent to the disclosure, or if it is reasonable, having regard to the circumstances, to comply without the consent of the individual.
Compliance with Data Protection Legislation
The Company is registered with ICO and complies with the UK General Data Protection Regulations (GDPR), specifically Article 5, which provides that personal data shall be:
• Processed lawfully, fairly and in a transparent manner.
• Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
• Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
• Accurate and, where necessary, kept up to date.
• Kept in a form which permits identification of the data subjects for no longer than is necessary for the purposes for which the personal data are processed; and
• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
Training
All staff will be made aware of this policy and any involved in the operation of any CCTV and Ring Doorbell will be provided with further advice and guidance around handling information gathered by surveillance, including:
• What to do when people ask for access to recordings;
• How and when to share information;
• What to do if there are complaints about surveillance; and
• What to do if children or parental responsibility holders withdraw their consent to surveillance.
All staff with responsibility for accessing, recording, disclosing or otherwise processing CCTV INCLUDING THE RING DOOR BELL images will be required to undertake training on GDPR
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