GDPR & our CCTV system in independent leisure centre

[MkII]

Tricky situation here that I'd like any input on please..

 

We now have a privately run leisure centre physically attached to our school, to which the school have exclusive use during school hours, and is a local community resource outside those hours.

 

We've just installed CCTV cameras in the whole school including 12 cameras in the leisure centre. The leisure centre want the CCTV camera images to be displayed in a grid permanently in their reception office for staff to monitor. Out of public sight.

 

Our staff that use our system have just done training. What should we be expecting of the leisure centre employees, if it's ok to set it up like this?

 

The leisure centre manager says that there is often a member of staff lone working in the evenings, and they need to keep an eye on activities to monitor for injuries and damage to facilities. They don't want the ability to view recorded footage and would come to the school to request that.

 

We're just about to go live with this whole system having attempted to get everything in order. Both the school and the leisure centre had independent CCTV systems in operation previously.

[GrumbleDook]

Would they only have access to live feeds of the cameras in the leisure centre? Do the leisure centre still have the PIA they did for their own system, so that you could review and set up a data sharing agreement?

Have you informed pupils and parents, and are both you and the leisure centre following the CCTV code of conduct?

 

Just a few things to consider.

[MkII]

Many thanks Tony

 

Yes it's possible to just give them access to view the leisure centre cameras

Yes they still have the PIA for their own system

Yes parents have been informed

As far as I know, we're following the CCTV CoCo.. We'd need proof that the leisure centre are.

[enjay]

Is there any way of limited the leisure centre's access to the CCTV, so they can only view during the evenings?

[GrumbleDook]

The leisure centre can be said to have a duty of care under H&S during the daytime too, so may need live access all the time.

[PotNoodleTech]

Interesting one as we've got the same thing (though with only one camera over there) given that our teachers are not allowed to access / view our own cctv systems I would assume that leisure centre staff who are not even employed by the school definitely wouldn't be allowed??

[MkII]

Is there any way of limited the leisure centre's access to the CCTV, so they can only view during the evenings?

 

The only way we've thought of is to have a switch on a timer. I'm thinking that Tony is right that the sports centre staff are helping with H&S monitoring.

[MkII]

Interesting one as we've got the same thing (though with only one camera over there) given that our teachers are not allowed to access / view our own cctv systems I would assume that leisure centre staff who are not even employed by the school definitely wouldn't be allowed??

 

The leisure centre staff would have to be vetted in the same way that we are. Currently we only have 2 people allowed to view.

[adhutton]

I've been told that under GDPR any CCTV images which are used for evidence purposes must be redacted and only show the faces of the suspects/victims and anyone else in the footage must have their face blurred out.

 

Does anyone know if this is correct?

 

If it is, any schools using CCTV will need to obtain the relevant software to allow this to be done.

 

Andrew

[MkII]

I've heard that you can't show any other faces than those you have a right to view, which in a LOT of cases would mean you couldn't show unedited footage.

[DJ-1701]

I've heard that you can't show any other faces than those you have a right to view, which in a LOT of cases would mean you couldn't show unedited footage.

 

Hands up those who's software covers up subjects that are not part of an enquiry?... No? No one?

I would hate to have to edit every single frame... wonder how others do it... and how much time it takes.

[PotNoodleTech]

From what I can understand, the people you have identified as being CCTV users (e.g. site manager, business manager) can use it internally without blanking faces off. You also do not have to blank any faces if giving the footage to the police, I think!

 

Only if you wish to show the footage to someone else (this includes school staff who are not nominated CCTV users!!!) do the above rules about blanking faces off go into place. Or in the case of a parent/member of the public asking for footage you can refuse as it identifies other people.

 

One thing you do need to do, is none of your cameras should record anything outside the school boundries, not in the street next door, not in the house over the road, or the mountain in the distance, you should use your CCTV software to black all external views out - modern CCTV software can do this on each camera, older CCTV software may fall fowl.

 

That's what I gather, I may be wrong! I aint no lawyer!!

[forkies]

From what I can understand, the people you have identified as being CCTV users (e.g. site manager, business manager) can use it internally without blanking faces off. You also do not have to blank any faces if giving the footage to the police, I think!

 

Only if you wish to show the footage to someone else (this includes school staff who are not nominated CCTV users!!!) do the above rules about blanking faces off go into place. Or in the case of a parent/member of the public asking for footage you can refuse as it identifies other people.

 

One thing you do need to do, is none of your cameras should record anything outside the school boundries, not in the street next door, not in the house over the road, or the mountain in the distance, you should use your CCTV software to black all external views out - modern CCTV software can do this on each camera, older CCTV software may fall fowl.

 

That's what I gather, I may be wrong! I aint no lawyer!!

 

Police would usually seize the cctv footage as evidence so you wouldn’t need to redact anything anyway.