Key Principles These operating procedures contain the overall standards in accordance with which Mosman Council’s CCTV system will be operated. These are based on eight key principles: Principle 1 Mosman Council’s CCTV system will be operated fairly, within applicable law, and only for the purposes for which it is established or which are subsequently agreed on in accordance with these guidelines. Principle 5 Regular monitoring and evaluation of the system will be undertaken to identify whether the purposes of the system are being complied with and objectives are being achieved. The objectives of Mosman Council’s CCTV system are as follows: To reduce crime levels by deterring potential offenders. The state guidelines, NSW Government Policy Statement and Guidelines for the Establishment and Implementation of Closed Circuit Television in Public Places, have also been considered in the development and implementation of Council’s CCTV system.
Information regarding the CCTV system will be made available on an ongoing basis to the public via Council’s website. Council staff will be informed of the operation of the CCTV system through the existence of signs at the entrance to the respective administration buildings. Access to the CCTV system will only be for authorised Council staff and contractors. The following table demonstrates the level of delegation for the staff as nominated to access the CCTV system: Delegation Title Level 1 System administration and authorisation to view / retrieve / copy footage General Manager Director Corporate Services Manager Governance Administration Officer – Insurance Manager Assets and Services Property Supervisor Manager Ranger Services Director Environment and Planning Team Leader Open Space & Asset Management Team Leader Rangers x 2 Level 2 Authorisation to view footage. Council does not have a control room for the purpose of operating the CCTV system.
Contact related to the CCTV system between Council and the Police will be conducted strictly in accordance with these guidelines. The CCTV system operating procedures will address the interests of all who may be affected by it, and not be confined to the interests of Mosman Council or the needs of the criminal justice system.
The purpose of this policy is to regulate the use of Closed Circuit Television to monitor and record on campus for the purposes of safety and security. General Principles Campus Safety and Security is committed to enhancing the quality of life of the campus community by integrating the best practices of the campus safety with the state of the art technology. A critical component of a comprehensive security program is the use of CCTV. CCTV monitoring is used in public areas by Security and Campus Safety to deter crime and to assist in protecting the college community and property. Information obtained via CCTV monitoring will be used exclusively for security and law enforcement purposes.
Information obtained by CCTV monitoring will only be released when authorized by both the Director of Security and Campus Safety and the Dean of Students or the President of the College. CCTV monitoring of public areas for security purposes will be conducted in a manner consistent with existing College policies, including Non-Discrimination Policy, the Sexual Harassment Policy, and other relevant policies. CCTV monitoring of public areas for security purposes at Bates College is limited to uses that do not violate the reasonable expectation of privacy as defined by the law. Responsibilities The Director of Security and Campus Safety has the responsibility to authorize all CCTV monitoring for the safety and security purposes at Bates College in consultation with the Vice President for Information and Library Services and the Dean of Students. The Department of Security and Campus Safety is authorized to oversee and coordinate the use of CCTV monitoring equipment at the College.
Security and Campus Safety has the primary responsibility for disseminating and implementing policy and procedures. Procedures All operators and supervisors involved in CCTV monitoring of public areas will perform their duties consistent with the policy developed by the Department of Security and Campus Safety. Recording video media will be stored for a period not to exceed 14 days and will then be erased, unless retained as part of a criminal investigation or court proceedings, or other bona fide use as approved by the Director of Security and Campus Safety.
Data Protection Commission
A data controller needs to be able to justify the obtaining and use of personal data by means of a CCTV system. The use of CCTV systems in other circumstances – for example, to constantly monitor employees, customers or students – can be more difficult to justify and could involve a breach of the Data Protection Acts. Section 2D of the Acts requires that certain essential information is supplied to a data subject before any personal data are recorded. In general, An Garda Síochána making a request to simply view footage on the premises of a data controller or processor would not raise any specific concerns from a data protection perspective. Where images of parties other than the requesting data subject appear on the CCTV footage the onus lies on the data controller to pixelate or otherwise redact or darken out the images of those other parties before supplying a copy of the footage or stills from the footage to the requestor.
Where a data controller chooses to use technology to process personal data, such as a CCTV system to capture and record images of living individuals, they are obliged to shoulder the data protection obligations which the law places on them for such data processing. In short, where a data controller uses a CCTV system to process personal data, its takes on and is obliged to comply with all associated data protection obligations. As data processors, they operate under the instruction of data controllers. Sections 2(2) and 2C of the Data Protection Acts place a number of obligations on data processors. Section 16 of the Data Protection Acts 1988 & 2003 requires that certain data processors must have an entry in the public register maintained by the Data Protection Commissioner.
It should be noted that recording of a public space, even partially, or when recording is directed outwards from the private setting, it may not be regarded as a ‘personal or household’ activity for the purposes of the Data Protection Acts, and this may have immediate and particular interest to drone operators and data controllers. CASE STUDY 3/07- Inappropriate use of CCTV footage by Leisure Club.CASE STUDY 6/07- Data Controller breaches Data Protection Law in regard to covert use of CCTV footage.