Reasons for carrying out the inspections.
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gva.co.uk
CCTV surveillance has become a common feature of modern living, with each of us caught on numerous cameras everyday. As such, CCTV necessarily involves intrusion into the lives of ordinary individuals as they go about their day to day business.
The Information Commissioner’s office (ICO) is the UK’s independent public authority set up to uphold information rights. It enforces & oversees the following legislation for England, Scotland, Wales and Northern Ireland:
· Data Protection Act 1998
· Freedom of Information Act 2000
· Privacy & Electronic Communications Regulations 2003
· Environmental Information Regulations 2004
Images of & information relating to individuals which is viewed or recorded by the use of CCTV constitutes personal data under the Data Protection Act 1998 (DPA) & therefore places a number of legal obligations on the system operator. It also gives individuals rights, such as the right to gain access to their details & to claim compensation when they suffer damage.
In order to help CCTV operators comply, the ICO produced the ‘CCTV Codes of Practise (Revised edition 2008’ setting out the Information Commissioner’s recommendations on how the legal requirements of the DPA can be met. An approved code of practice (ACOP) is a quasi-legal document which sets out the best practise procedure in order to meet the full legal responsibilities; organisations may use alternative methods to meet these requirements, but if they do nothing then they are at risk of breaking the law.
The code makes a number of recommendations, which are all based on the legally enforceable data protection principles, designed to take into account the life cycle & practical operation of the CCTV. It states that,
‘Establishing a clear basis for the handling of any personal information is essential & the handling of images relating to individuals is no different. It is important to establish who has responsibility for the control of the images, for example, deciding what is to be recorded, how the images should be used and to whom they may be disclosed.’
The body or individual which makes these decisions is called the data controller and is legally responsible for compliance with the Data Protection Act & for notifying the ICO annually that CCTV is in use at the premises for which they are responsible. They must also ensure there are clear procedures to determine how the system is used in practice & review regularly whether the use of CCTV continues to be justified. As part of this requirement the Code of Practice suggests,
‘You will have to renew your notification yearly, so this would be an appropriate time to consider the ongoing use of CCTV.’
“GVA FM National Inspection Team (NIT) Inspectors hold BTEC in CCTV Legislation & are therefore fully qualified to assist the data controller in identifying & meeting the responsibilities placed on them by the DPA. The audit which has been undertaken considers both the practical operation of CCTV Systems and the wider procedural framework under which it is being operated. It poses questions that must be positively addressed to help ensure that the good practice recommendations are being achieved, the findings of which are set out in the following report.”
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gva.co.uk
CCTV Inspection Client Details
Client: / CTB WakefieldProperty Name: / Office Three, St Pauls Place
Property Type: / Purpose built nine storey office block
Address: / Office Three, St Pauls Place, Sheffield
Post Code: / S1 2JL
Date of the Inspection: / 11th October 2016
Scope of CCTV Coverage: / Commercial X / Residential ¨ / Public ¨
CCTV Auditor: / Helen Ewles
No. / Specification / Comments
1. / Number of monitors / 1
2. / Number of Cameras / 9 – 5 external 4 internal
3. / System Make / Concept Pro
4. / Are there any Additional Features added to the system such as Time Specific Recording, Wireless Transmission, Facial Recognition.
If a Wireless Transmission is being used are sufficient safeguards in place to protect it from being intercepted by an external source? / No
5. / Is a sound recording facility installed on the system?
If so, is it switched off or disabled as this is highly intrusive and unlikely to be justified? / No
6. / Number of Operators / 4 GVA staff weekdays plus weekend cover
7. / Operators Shift pattern / 7.00-19.00 Monday-Friday, 4 on, 4 nights, 4 off
8. / Operators rotation / NA
9. / Approximate Age of system / Less than 1 year – March 2016
10. / Image / Black & White ¨ Colour X
11. / Image quality / Excellent X
Good ¨
Poor ¨
No. / Registration / Installation / Yes / No / Comments
12. / During the installation was the CCTV system fully tested and commissioned in the presence of a representative of the client (Building Mgr / Centre Mgr) to determine cameras cover the required areas and if they are capable of providing images to the required standard?
Is there a signed installation certificate available? / X / The system was installed by Protech and Imtech and there is no documentation held on site
13. / What is the primary function of the CCTV system (e.g. Crime prevention)
As a result of this, what quality of image is required such as Monitoring, Detecting, Recognising or Identifying? / The system is primarily for monitoring
14. / Does the site have an ‘Operational Requirement Analysis’ in place to ensure the CCTV System is fair and lawful and that the correct quality of image is being collected? / X
15. / Is there a site specific CCTV policy in place for staff use? / X / The BE policy is held on site in the site folder but not site specific
16. / Have CCTV operators been fully trained to operate the CCTV system and are training records kept up to date? / X / Staff were trained on installation by Protech
17. / Are, staff aware that notification of the system to the Information Commissioner is necessary and must be renewed annually? / X / Have advised that the system should be registered by the client and registration renewed on an annual basis
18. / Has Notification been submitted to the information Commissioner and the next renewal date recorded? / X / GVA and BE certificates have been sent along with this report, copies to be held on file
19. / Is there an asset register for the CCTV installation equipment? / X
20. / Does your site routinely contact the police to deal with criminal incidents? If so, what is your police reference number?
No. / Camera Positioning / Recording / Yes / No / Comments
21. / Have Cameras been positioned to avoid capturing the images of persons not visiting the Premises or in residential areas around the site? / X
22. / Are the cameras positioned so that they record good quality images? / X
23. / Is the type of camera being used suitable for its location taking into account the levels of light and the size of the area it is covering? / X
24. / Have the cameras been positioned in such a way as to avoid being vandalized? / X
25. / Have live feed monitors been positioned to restrict the viewing of areas not in plain sight of the monitor by the general public? / X / The monitor is located to the main reception desk and could be viewed by members of the public
26. / Do the cameras film constantly or only when problems are most likely to occur such as out of office hours or motion triggered? / Constant filming
27. / Are signs positioned around the site showing that a CCTV system is in operation and are the signs visible to people visiting the site with contact details displayed on the sign where it is not obvious who is responsible for the system?
28. / How are the images recorded? (Hard disk / drive, Video, CD or Cassette) / HDD
29. / Are the recorded images from this CCTV system securely stored, where only a limited number of authorised persons have access to them? / X
30. / Are staff aware that recorded images will only be retained long enough for any incidents to come to light (e.g. for theft to be noticed)? / X / Images are automatically updated after 30 days
31. / Are, staff aware that recordings will only be made available to law enforcement agencies involved in the prevention and detection of crime? / X
32. / Are copies of images easy to produce and in what format are the recordings produced in? (Video, CD, Memory Stick or Cassette)
Is this a secure method? / X / USB or CD
33. / When recording footage for a third party are you aware of how to obscure images of third parties to avoid any breaches of the Data Protection Act? / X / No facility for this
No / Picture Presentation / Yes / No / Comments
34. / Is a spot monitor used for consistent primary monitoring tasks? / X
35. / Where multiple images are being presented, is the size of the monitor appropriate for the number of split images presented? / X
No / On-Screen Information / Yes / No / Comments
36. / Is unique camera identification information presented on the screen? / X
37. / Is a consistent format used at all times for the on-screen information? / X
38. / Is the overall area of screen occupied by on-screen information reasonable? / X
No. / Procedures / Yes / No / Comments
39. / Is there a named individual on site responsible for ensuring that procedures have been set and followed? / X / Bev Swift
40. / Have the CCTV Operators signed a declaration of confidentiality form? / X / BE forms have been signed and held on file. Two of the operators also have SIA CCTV badge
41. / Is there a procedure in place for requested image information to be released to police such as a CCTV Image Release form? / X / Copies of all procedural forms are held on file
42. / Are Staff aware of how to respond to requests from individuals for access to images relating to that individual? / X / Copies of all procedural forms are held on file
43. / How are requests denied? / Copies of all procedural forms are held on file
44. / How are complaints recorded? / None have been received to date
45. / Is there a CCTV Incident log sheet? / X / Copies of all procedural forms are held on file
46. / Is there a CCTV visitor’s log book? / X / Copies of all procedural forms are held on file
47. / Is there a Tape / CD log, tape input and tape disposal form? / NA system is digital
48. / Is the operating equipment regularly serviced by a qualified CCTV operative to maintain the quality of images and to ensure the features on the equipment such as the date and time stamp are correctly set at all times? / X / Contract is with Protech
49. / Are there records kept of all the faults on the system? / X
No / Architectural Considerations / Yes / No / Comments
50. / Does the size of the room allow people to easily access the workstation and move around with ease? / X
51. / Does the control room allow for future expansion? / X
52. / Is there a view of the outside provided via a window? / X
No / Workstation Arrangement / Yes / No / Comments
53. / Is there enough room for operator on-the-job training to be carried out? / X
54. / Are the workstations positioned such that windows are not within the same visual field of view? / X
55. / Does the layout take full account of maintenance requirements and access space for technicians? / X
56. / Are luminaries positioned away from the direct line of sight? / X
57. / Are blinds provided for control of daylight from the windows? / X / Glass is tinted
58. / Are all trailing cables maintained in a safe place? / X
No / Workstation Design / Yes / No / Comments
59. / Is the workstation sufficiently large to accommodate tasks, equipment and documents? / X
60. / Are work materials and frequently used equipment or controls positioned within easy reach without undue bending and stretching? / X
61. / Does the layout of the workstation take account of future requirements likely within the planned life span of the system? / X
62. / Is there adequate clearance for the thighs, knees, lower legs and feet under the work surface and between the furniture components? / X
63. / Is the height of the work station within the 27 – 31 inch range? / X
64. / Is the workstation surface low reflectance? / X
No / Workstation Mounted Monitors / Yes / No / Comments
65. / Is the selected monitor size appropriate to the visual task? / X
66. / Is the viewing distance to the monitor(s) appropriate to the visual task, and monitor size? / X
67. / Are operators required to raise their eyes more than 15 degrees when viewing monitors regularly? / X
No / Off-Workstation Monitors / Yes / No / Comments
68. / Are all Off-station mounted monitors equally visible without extreme postural changes? / NA
69. / Is the number of monitors provided appropriate for the visual task being carried out? / NA
70. / Is the viewing distance to the monitor(s) appropriate to the visual task, and monitor size? / NA
No / Seating / Yes / No / Comments
71. / Is the chair stable and allow for freedom of movement and comfortable? / X
72. / Does the chair have an adjustable height facility? / X
73. / Is the chair back adjustable in both height and tilt? / X
74. / Is the chair fitted with castors? / X
No / Control Panel / Yes / No / Comments
75. / Does the design of the workstation take account of the importance, order and frequency of use of controls? / Operated by computer mouse
76. / Are the controls designed in such a way that unintentional button pressing is avoided? / Operated by computer mouse
77. / Are the button sizes appropriate for the user population? / Operated by computer mouse
78. / Are the labels and numbers on the controls sufficient in size? / Operated by computer mouse
79. / Are the control panels designed in a consistent format? / Operated by computer mouse
80. / Is the speed and operation of the system dictated by the operated? / Operated by computer mouse
81. / Where joysticks are used, is adequate hand support provided? / NA
82. / Does the design of the joystick on the control panel take account of the needs of both left and right handed operators? / NA
83. / Are flexible methods of operation available? / NA
84. / Are control panels finished with a non – reflective coating? / NA
No / Noise, Temperature & Ventilation / Yes / No / Comments
85. / Are the noise levels within the control room detrimental to the task? / X
86. / Is the temperature controllable by the operator? / X
87. / Is effective and suitable provision made to ensure that the room is ventilated by a sufficient supply of fresh or purified air? / X
Additional Notes: