Introduction

CCTV cameras are in operation within Phoenix Counselling for the protection of our therapists and clients. The purpose of this policy is to regulate the use of CCTV and its associated technology when monitoring the internal environment of the premises. A copy of this policy will be made on the Phoenix Counselling website and provided to all team members.

Scope

This policy applies to all personnel and visitors to Phoenix Counselling, 129 Pottery Road, Oldbury, B68 9HE. Moreover, it relates directly to the location and use of CCTV, and the monitoring, recording and subsequent use of such recordings. This policy prohibits CCTV monitoring based on characteristics and classifications contained in the Equality Act 2010. Furthermore, CCTV monitoring is limited to uses that do not violate the reasonable expectation of privacy as defined by law.

The CCTV cameras will be used to protect Phoenix Counselling’s building and assets, both during and outside of operational hours. The system is in operation 24 hours a day every day, promote health and safety of all personnel and visitors, supports the police in a bid to deter and detect crime, and assists in identifying, apprehending and prosecuting offenders. The personal data recorded and stored by the CCTV system will be used only for the purposes outlined in this policy. Collection, storage and the use of CCTV footage shall comply with Data Protection and GDPR.

Data Controller

The data controller with respect to images recorded and stored by the CCTV system at Phoenix Counselling’s premises. The Data processor is Ian Burman, responsible for monitoring the implementation and compliance with CCTV policy.

Fair Obtaining

The fair obtaining principles inherent in the Data Protection Acts require that those people captured on camera are also informed. Accordingly, Phoenix Counselling’s Data Protection Officer will provide a copy of this policy to all team members. Adequate signage will be placed at each location where CCTV is in operation e.g Reception area/front of building.

The name and contact details of the Data Controller, as well as the specific purpose for which CCTV is in place, can be provided on request.

Location of Cameras

The CCTV network for Phoenix Counselling extends to the following areas:

Reception area - Directly facing the front door
Corridor

There are 2 cameras with the objective of protecting the safety and wellbeing of Phoenix Counselling and our clients.

Operation of the System

The recording system is a digital system that records video data. The system can only be accessed by the directors of Phoenix Counselling.

Data Protection, Storage and Retention

The data captured from the CCTV cameras is securely stored as electronic data and securely password-protected within Phoenix Counselling. Typically, the data is recorded within a loop and will be retained for 7 days until it is overwritten on the hard drive. Phoenix Counselling will retain data longer if it is notified that events have occurred that may give rise to court proceedings.

There is no access to CCTV other than the directors; unauthorised access to CCTV is not permitted. Supervising access is carried out by the directors. Unauthorised access will be considered a data breach, if such a breach occurs, Phoenix Counselling will follow its Data Breach Management Policy.

Access Requests

Access to the CCTV system will be restricted to authorised personnel only. In relevant circumstances footage may be accessed by the police, when Phoenix Counselling are required by law. Access request can be made to Ian Burman and Lisa Smith, Phoenix Counselling, 129 Pottery Road, Oldbury, B68 9HE.

Requests from the police to download footage will only be released if requested by the Courts. The Data Protection Commissioner recommends that the requests for copies of CCTV footage should be granted when a formal written request is made to Phoenix Counselling stating the police are investigating a criminal matter. For practical purposes and to expedite a request speedily in urgent situations a verbal request can be sufficient to allow the release of the footage sought. However, any such verbal request must be followed up with a formal written request.

It is up to Phoenix Counselling to be satisfied that there is a genuine investigation underway. For practical purposes a phonecall to the requesting Police station may be sufficient. A log of the requests will be maintained by Phoenix Counselling.

CCTV Policy