CODE OF PRACTICE
For The Operation Of
Northampton Borough Council CCTV System
In Partnership with
Northamptonshire Police
Wellingborough Borough Council
Northamptonshire County Council
Northampton Borough Council carries out the management and operation of the CCTV system.
Code of practice for the Northampton System
based upon The CCTV User Group model
code of practice © Copyright
Code of Practice Index
Page 3 Section 1 - Introduction and objectives – Procedural manual
Page 5 Section 2 - Statement of Purpose and Principles – Copyright-camera &areas covered
Page 8 Section 3 - Privacy and Data Protection – exemptions to the provision of information- Criminal procedures and investigations act 1996.
Page 10 Section 4 - Accountability and public information – system owner – system managers.
Page 12 Section 5 - Assessments of the System and this Code. - Evaluation –monitoring-Audit – Inspection.
Page 13 Section 6 - Human Resources. Discipline -Declaration of Confidentiality.
Page 15 Section 7 - Control and Operation of Cameras – Guiding Principles- Operation of the system by Police – Maintenance of the system.
Page 17 Section 8 - Access to, Security of, Control room and associated equipment. Public Access – Authorised Visits – Declaration of Confidentiality.
Page 19 Section 9 - Management of recorded material – Digital Recorders – Image retention – DVR Register – Recording Policy
Page 22 Section10 - Video Prints – Guiding Principles.
Page 23 Appendix A Key Personnel – Responsibilities
Page 26 Appendix B Extracts from the Data Protection Act 1998 – Sections 7 & 8
Page 29 Appendix C National Standard for the release of Data to third parties – secondary requests to view – Individual Subject access req under the data protection legislation – Media Disclosure.
Page 34 Appendix D Restricted Access Notice
Page 35 Appendix E Declaration of Confidentiality
Page 36 Appendix G Subject Access Request form
Page 37 Appendix H RIPA – Guiding Principles
Page 39 Appendix I Formulation, Application, and liability for the CCTV User Group Model Code of Practice and Procedural Manual.
Section 1 Introduction and Objectives
1.1 Introduction
A Closed Circuit Television (CCTV) system has been introduced to various locations in Northampton and its surrounding areas. The system comprises a number of cameras installed at strategic locations. Some of the cameras are fully operational with pan, tilt and zoom facilities. Others are fixed cameras, images from which are presented in the same room. Secondary monitoring facilities are located at Northants police force headquarters. All recordings are held / stored with in the CCTV control room.
The Northampton CCTV system has evolved from the formation of a partnership between, Borough of Wellingborough Council, Northamptonshire County Council and Northamptonshire Police. All have certified on the previous form their acceptance of the requirements of this code.
For the purpose of the document the owner of the system is Northampton Borough Council.
For the purpose of the Data Protection Act the ‘data controller’ is Northampton Borough Council.
The ‘System Manger’ is NBC Community Safety Manager.
The Northampton CCTV system has been notified to the Information commissioner.
Note 1. The Data Controller is the person who (either alone or jointly or in common with other persons) determine the purpose for which and the manner in which any personal data are to be processed., It must be a legal entity e.g. person, organisation or corporate body and in the case of partnership all partners may be considered to bear the responsibility.
The following is for public authorities or those organisations performing services of a public nature to who the requirements of the Human Rights Act apply.
1.2 Objectives of the system
1.2.1 The objectives of the Northampton system as determined by the partnership, which form the lawful basis for the processing of data.
§ To help reduce the fear of crime
§ To prevent or mitigate interruptions to traffic flow (not to enforce breaches to traffic law)
§ To facilitate the apprehension and prosecution of offenders in relation to crime and public order.
§ To help detect crime and provide evidential material for court proceedings.
§ To assist in the overall management of the town centre and the surrounding areas.
§ To assist the local Authority in its enforcement and regulatory functions with in the Northamptonshire area.
§ To tackle the threat caused by serious organised crime and terrorism.
§ To provide safe areas for the benefit of those who live, work, trade, visit serve and enjoy the facilities and environment of the areas covered by CCTV.
1.3 Procedural manual
This Code of Practice (hereafter referred as ‘the Code’) is supplemented by a separate ‘Procedural Manual’, which offers instructions on all aspects of the day-to-day operation of the system. To ensure the Purpose and Principles (see section 2) of the system are realised, the procedural manual is based and expands upon the contents of this Code of Practice.
Section 2 Statement of Purpose and Principles
2.1 Purpose
The purpose of this document is to state the intention of the owners and the managers, on behalf of the partnership as a whole and as far as is reasonably practicable, to support the objectives of the Northampton CCTV system, (hereafter referred to as ‘The System’) and to outline how it is intended to do so.
2.1.1 The ‘purpose’ of the system, and the process adopted in determining the ‘reasons’ for implementing ‘The System’ are as previously defined in order to achieve the objectives detailed within section 1.
2.1.2 Whilst Northampton Borough Council owns ‘The System’, except the elements owned by Borough of Wellingborough Council. Representatives from a private security company, who is the contractor, staff the control room.
2.2 General Principles of Operation
2.2.1 The system will be operated in accordance with all the requirements and the principles of the Human Rights Act 1998.
2.2.2 The operation of the system will also recognise the need for formal authorisation of any covert ‘Directed’ surveillance of crime – trend (hotspot) surveillance as required by the Regulation of Investigatory Powers Act 2000 and the police force policy.
2.2.3 The system will be operated in accordance with the Data Protection Act 1998 at all times.
2.2.4 The system will be operated fairly, within the law, and only for the purposes for which it was established and are identified within this code, or which are subsequently agreed in accordance with this Code of Practice.
2.2.5 The system will be operated with due regard to the principle that everyone has the right to respect for his her private and family life and their home.
2.2.6 The public interest in the operation of the system will be recognised by ensuring the security and integrity of operational procedures.
2.2.7 Throughout this code of practice it is intended, as far a reasonably possible, to balance the objectives of the CCTV system with the need to safeguard the individuals rights. Every effort has been made throughout this Code to indicate that a formal structure has been put in place, including a complaints procedure, by which it can be identified that the system is not only accountable, but it is seen to be accountable.
2.2.8 Participation in the system by any organisation, individual or authority assumes an agreement by all such participants to comply fully with this code and to be accountable under the code of practice.
2.3 Copyright
Copyright and ownership of all material recorded by virtue of the system will remain with the data controller. In cases were footage has been downloaded, master copies are the responsibility of Northamptonshire Police.
2.4 Camera and Area Coverage
2.4.1 The areas covered by CCTV to which this Code of practice refers are the public areas within the responsibility of the operating partners and cover Northampton and its surrounding area, which are as follows:
§ Northampton Town Centre public areas
§ Northampton Town Centre car parks
§ Greyfriars Bus Station
§ Wellingborough Road
§ Kettering Road
§ St James Retail Park
§ Sixfields Leisure Complex
§ NCC traffic control (Netcom centre)
§ Wellingborough town centre public areas
§ NBC Leisure Centers
§ NBC Guildhall
§ NBC Single Persons accommodations, Paget House /Overslade House/ Woodstock House and Dover Court.
§ Abington Park Museum.
§ Local Centers. Blackthorn/Bellinge/Rectory Farm/Lings/Thorplands/Southfields/Goldings/Limehurst Square/Briar Hill/Kingsheath.
§ Kingsthorpe Shopping Centre
§ Brackmills Industrial Estate
2.4.2 From time to time transportable or mobile cameras may be temporarily sited with-in the area. The use of such cameras, and the data production by virtue of their use, will always accord with the objectives of the CCTV system and be governed by these Codes and Procedures.
2.4.3 Some of the cameras offer full colour, pan tilt zoom (PTZ) capability, some of which may switch to monochrome in low light levels.
2.4.4 None of the cameras forming part of the system will be installed in a covert manner. Some cameras may be enclosed within all weather domes for aesthetic or operational reasons, but appropriate signage will identify the presence of all the cameras.
2.5 Monitoring and Recording Facilities
2.5.1 The CCTV control room is operated and manned by Contracted security personnel.
2.5.2 Secondary monitoring equipment is located at Police Force Headquarters based at Wooton Hall. No equipment other than that housed at the CCTV control room will be used for recording images from any of the cameras owned and operated by Northampton Borough Council, Borough of Wellingborough Council.
2.5.3 In cases of serious emergency or large events live CCTV footage may be streamed over a police laptop. On all such occasions, any police officer accessing live footage must contact the CCTV control room to advise and on all occasions provide name and collar number.
2.5.4 CCTV operators are able to record images from selected cameras, produce hard copies of recorded images, replay or copy any pre-recorded data, as long as it is in line with this Code of Practice and the Procedural Manual.
2.5.5 There is a dedicated room called the Image Capture Unit, which is manned by police personnel. All Police viewing requests and image retention requests, will be carried out by the Image Capture Unit and in line with their procedures.
2.5.6 Any requests from the police to carry out a review of recorded footage must be made via the completion of Northamptonshire Police E- form 1007. ICU officers will carry out the reviews and complete the necessary logs with the outcome, times dates viewed and DVR accessed. These logs are subject to inspection by the CCTV manager or System Owner.
2.5.7 If any recorded material is removed from the system by the police as part of their investigations the Image capture unit officers will undertake this and relevant documents must be completed. CCTV Operators will issue an Identification number starting with N for footage removed from the Northampton system, W for any removed from the Wellingborough system and make ref to the release on the footage release database.
2.5.8 Requests to review or release images under the freedom of information or Data Protection Act from local authorities / third party requests will be carried out by the CCTV operators. The relevant procedures to carry out the review or release of the footage will be followed at all times.
2.5.9 Requests may be made in writing to. Information Management, Northampton Borough Council, St Giles Square, Northampton, NN1 1DE. Or by email to Consideration must be made to all requests whether they may be subject to a criminal investigation.
2.6 Human Resources
2.6.1 Unauthorised Persons will not have access without an authorised member of staff being present.
2.6.2 Specifically selected and trained operators in accordance with the strategy contained within the procedural manual shall staff the Monitoring room. All Operators of CCTV cameras must be SIA licensed.
2.6.3 All operators shall receive training relevant to their role in the requirements of the Human Rights Act 1998, Data Protection Act 1998, Regulatory of Investigatory Powers Act 2000, Freedom of Information Act 2000 and the Code of Practice and Procedures. The security contractor will provide further training as necessary.
2.7 Processing and Handling of Recorded Material
2.7.1 All recorded material, whether recorded digitally, in analogue format or as a hard copy video print, will be processed and handled strictly in accordance with this Code of Practice and the Procedural Manual.
2.8 Operators Instructions
2.8.1 Technical instruction on the use of equipment housed within the control room is contained in a separate manual provided by the equipment suppliers. Other operator instructions are contained within the security contractors Assignment Instruction known as AI’S.
2.9 Changes to the Code or Procedural Manual
2.9.1. Any major changes to either the Code of Practice or Procedural Manual, (i.e. such as will have a significant impact upon the Code of Practice or upon the operation of the system) will take place only after consultation with Northants Police, Northampton Borough Council, Borough of Wellingborough Council, and Northamptonshire County Council.
2.9.2. A minor change (i.e. such as may be required for clarification and will not have such a significant impact) may be agreed between the Manager and the owners of the system.
3.1 Public Concern
3.1.1 Although a large majority of the public may have become accustomed to being monitored by CCTV, those who do express concerns do so mainly over matters pertaining to the processing of the information, (or data) i.e. What happens to the material that is obtained.
3.1.2 All personal data obtained by virtue of the system, shall be processed fairly and lawfully and, in particular, shall only be processed in the exercise of achieving the stated objectives of the system and its Code. In processing personal data there will be respect for everyone’s right to respect his / her private and family life and their home.
3.2 Data Protection Legislation