GDPR - Use of CCTV

CCTV Policy

1. Introduction

Deverell Hall is fitted with closed circuit television (CCTV). The purpose of the CCTV System is for the security of the premises, the prevention, detection and investigation of criminal activity, trespass and vandalism and the safety of all persons using our building. This includes vulnerable persons, persons with disabilities, children, staff and visitors to the building, nursery groups or any other group/hall user who has permission to be using our premises.

This is an internal system which is not shared online except via remote access if required by our Data Controller.

Deverell Hall and the authorised data controller of your personal data, are fully committed to comply with the requirements of the Data Protection Act 2018, and the Guiding Principles of the Surveillance Camera Code of Practice as published by the Home Office and updated in 2021. Our Policy will:

1.1 Inform all who come into the building that CCTV is in use, by way of signs and/or window stickers;
1.2 Keep images from CCTV secure and controlled by authorised personnel;
1.3 Our CCTV system and equipment will be maintained and kept in good working order;
1.4 Comply with the 'Freedom of Information Act 2000'.

1.5 For the purposes of the General Data Protection Regulation (GDPR) our Data Controller is:

Name: Mr Douglas McPhail
Phone: 0330 223 2953
Email: SEND EMAIL

1.6 If you are a regular hirer, or a casual hirer who has confirmed and paid for your booking with Deverell Hall, then at your request we can send you the Registration Certificate of our Data Controller if requested, who is registered with the Information Commissioner's Office (ICO).

2. About the System

2.1 The CCTV System in place can record sound/audio but this has never been enabled. There is no need for us to record any audio.
2.2 The CCTV is not monitored centrally, but can be accessed by the data controller if an issue has occurred which needs investigating.
2.3 All cameras are static cameras and have been sited so they only capture images relevant to the purposes for which they have been installed, and care will be taken to ensure that reasonable privacy expectations are not violated.
2.4 None of the CCTV cameras are hidden or concealed. They are clearly visible as cameras and not just some device.
2.5 Images that are recorded will be stored in a secure location and can only be accessed by those authorised to do so.
2.6 Within the purpose of the CCTV system such images may be shared with the Police if deemed necessary by the Data Controller, or the Trustees of Deverell Hall.
2.7 The images will be digitally recorded on a rolling programme of 28 days. Unless required for evidence purpose, this retention will automatically overwrite the oldest images and recordings.
2.8 Access to stored images whether that be locally, or remotely are all password protected and currently restricted to the data controller.
2.9 All staff are aware that they could be committing a criminal offence if they misuse the CCTV system and CCTV images.

3. Remote Access to the System

3.1 The system is connected to the internet in order to enable it to be accessed remotely and/or to provide alerts when movement is detected in key areas at unexpected times. Remote Access is only accessible via an encrypted app on a secure device. It requires specific data and passwords to be entered before remote viewing will take place. The system does not capture any audio data because that has never been enabled.
3.2 This facility is activated only for use by the CCTV Manager (otherwise known as the Data Controller) to facilitate viewing if needed, when certain conditions are met. This is called Live Video Feed or may be used to Playback recordings if required for criminal investigations, damage to the property that has not been reported, or risk to person or persons using the hall. We only use this surveillance technology in a justifiable and proportionate manner.

3.3 Remote access may be used for example to:
3.3.1 Ensure casual hirers access the building only at their appointed start time, and have left the building at their appointed end time;
3.3.2 To make sure that the building is secure, and gates have been closed;
3.3.3 To investigate specific events when it is reasonably believed that there might have been criminal activity, antisocial behaviour and/or a breach of the hall's terms and conditions of hire or parking regulations;
3.3.4 When we have been alerted to an incident taking place at the hall, or the property/land it resides on;
3.3.5 At the request of the police as part of a criminal investigation.

3.4 Remote access is not routinely used. We would not use it for example during:
3.4.1 Preschool attendance start to end times when they are governed by their own safeguarding policies;
3.4.2 During normal regular hire periods involving other regular hirers, or groups where children might be involved.

3.5 When Remote Access may be used, generally speaking this will be checking of the external cameras of the building, or the camera covering the MAIN SIDE DOOR entrance.

3.6 If, or when Remote Access is used this will be in the presence of the Data Controller and a Trustee of Deverell Hall (normally the Secretary for Deverell Hall), and entry logs will be kept to show what day, time and reason remote access was used.

4. Subject Access Requests

4.1 Individuals have the right to request access to CCTV footage relating to themselves under the Data Protection Act.
4.2 All requests should be made in writing to the Secretary for Deverell Hall.
4.3 Individuals submitting requests for access will be asked to provide sufficient information to enable the footage relating to them to be identified, for example date, time, location, photo evidence of who they are, and a valid reason for wishing to have access to the footage.
4.4 Deverell Hall will respond to requests within 28 calendar days of receiving the written request and associated fee.
4.5 A fee of £20 will be charged per request.
4.6 The person or persons requesting the footage are required to supply their own USB Stick for the data to be put onto it.
4.7 Deverell Hall reserves the right to refuse access to CCTV footage where this would prejudice the legal rights of other individuals or jeopardise an on-going investigation.

5. Access to and Disclosure of Images to Third Parties

5.1 There will be no disclosure of recorded data to third parties other than to authorised personnel such as the Police and service providers to the Deverell Hall where these would reasonably need access to the data.
5.2 The data may be used within the Deverell Hall's discipline and grievance procedures as required, and will be subject to the usual confidentiality requirements of those procedures. Any complaints and enquiries about the operation of CCTV within the Deverell Hall should be directed to the Bookings Secretary in the first instance.

6. Variation or Changes to this policy

6.1 Deverell Hall reserves the right to add, delete, or modify any provision of these 'Terms and Conditions' at any time, and without notice. Failure to receive notification of a change does not make those changes invalid, and the revised terms and conditions will be considered to be in effect from the date of publication of the revision made on this page, or within the website.

We may also notify you of any changes by email.

Please check this page regularly to ensure that you are familiar with the current terms and conditions of our CCTV Policy.

7. Change of Assignment

7.1 We may transfer, sub-contract or otherwise deal with our rights and/or obligations under these terms and conditions without notifying you or obtaining your consent. You may NOT transfer, sub-contract or otherwise deal with your rights and/or obligations under these terms and conditions to anyone else.

8. Severability

8.1 If a provision of these terms and conditions is determined by any court or other competent authority to be unlawful and/or unenforceable, the other provisions will continue in effect. If any unlawful and/or unenforceable provision would be lawful or enforceable if part of it were deleted, that part will be deemed to be deleted, and the rest of the provision will continue in effect.

9. The entire agreement

9.1 These terms and conditions, including our Privacy Policy, and/or any other prescribed terms as outlined anywhere else within this website, constitute the entire agreement between you and us in relation to your use of our website, and supersedes all previous agreements in respect of your use of this website.

10. Applicable Law and Dispute

10.1 This Agreement and all matters arising from it are governed by and construed in accordance with the laws of England and Wales whose courts shall have exclusive jurisdiction over all disputes arising in connection with this Agreement and the place of performance of this Agreement is agreed by you to be England.

11. Our business details

11.1 Our contact and business details can be found on the Contact Options Page.

What's Happening

At Deverell Hall in Purbrook we host a wide range of regular groups who use the facilities. Here are just a selection of just a few of them.