CCTV policy

Publication date: July 2024

1.  Introduction

1.1    The Royal College of Radiologists operates a closed-circuit television (CCTV) system to provide a safe and secure environment for staff and visitors to the RCR’s building, and to protect RCR property. The CCTV recordings assist the prevention and detection of crime in order to recognise and identify individuals with a view to taking appropriate action where necessary.

2.    Policy position and purpose

2.1    This policy sets out the accepted use and management of the CCTV equipment and images to ensure that RCR complies with UK GDPR, the Data Protection Act 2018 and the ICO CCTV Code of Practice.
2.2    The RCR’s CCTV equipment records images and audio.
2.3    The RCR positions the cameras to cover high risk or vulnerable areas of the property including the entrances, internal areas open to the public, areas accessible via fire escapes.
2.4    The purposes of the RCR installing and using CCTV systems include:
•    To assist in the prevention or detection of crime or equivalent malpractice
•    To assist in the identification and prosecution of offenders
•    To monitor the security of the RCR’s building and assets
•    To ensure that health and safety rules and RCR procedures are being complied with
•    To assist with the detection of illegal or unsafe working practices that might result in disciplinary proceedings against staff
2.5    The purpose of this policy is to establish what CCTV the RCR will use, how it will be used and managed.

3.    Responsibility for the management of the system

3.1    The Facilities Team has overall responsibility for the maintenance of the system. They will periodically check the equipment and arrange for the suppliers to carry out periodic maintenance checks.
3.2    Members of the Facilities team will be trained in the operation of the CCTV system and will be aware of the data protection compliance requirements in line with the Code of Practice. The Facilities Team will ensure that images are deleted in accordance with the retention policy.
3.3    Members of the Facilities Team will monitor live feeds and will have access to the recorded images during the maintenance of the systems. They will not routinely view, disclose or retain copies of the recorded images.

4.    Access to and disclosure of recordings

4.1    The Facilities Manager or a member of the Facilities Team and the Director of Business and Resources are responsible for viewing images when investigating an incident or suspected incident.
 
4.2    Images may also be accessed by the responsible line managers, Investigating Officers and the HR team, if necessary, as part of a disciplinary investigation. Images may then be disclosed as part of the evidence assembled in the event of a disciplinary hearing.
4.3    The Data Protection Officer will be responsible for dealing with and responding to any requests for access to images made by individuals under the Data Protection Act 2018.

5.    Secure storage and retention of recordings

5.1    All materials including recordings will be securely protected with restricted access.
5.2    The Facilities Team have responsibility for ensuring that the equipment and the routinely recorded images have the necessary security. Recordings are routinely retained for one month but may be retained longer in the event that they are required as part of an investigation.
5.3    Where images have been retained for an investigation, the Facilities Team will take responsibility for the secure storage of those recordings. This will be done in liaison with the HR team where necessary for staff disciplinary purposes.

6.    Related policies

6.1    Secure Development policy
6.2    Subject Access Request procedure
6.3    Incident log procedure

7.    Compliance

7.1    Any individual that is suspected of or found to not be complying with the policy requirements will be managed under the RCR's Disciplinary Procedure.