The university is under the strict surveillance of CCTV cameras to provide perfect security to university staff and students.

1. Introduction

1.1 The University of West London is committed to providing a safe and secure learning environment across its campuses and buildings. The University therefore operates close circuit television cameras (CCTV) across its campuses and buildings for the security and safety of its staff and students.

1.2 Closed Circuit Television (CCTV) cameras are installed to view and record the activities of individuals overtly at selected locations on University premises. The deployment of these cameras are a strategic component of the University commitment to staff and student safety, security and crime prevention.

1.3 The University’s use of CCTV is covered by the General Data Protection Regulation (GDPR). Identifiable imagery is considered as personal data under the GDPR and, therefore, this policy is committed to the protection of individuals’ rights and privacy. The processing of personal data such as the collection, recording, use, and storage of personal information through the CCTV system will be dealt with lawfully and correctly in accordance with the University’s Data Protection Policy.

2. CCTV system

2.1 The CCTV system adopted includes internal / external; static colour / black

and white; full pan, tilt and zoom cameras. Pan, tilt and zoom (PTZ) function is employed only on playback but not in real time live recording mode and area viewed is pre-set and static, especially for all external cameras.

2.2 The vast majority of CCTV cameras are IP based and connected to the UWL IT network. The system records CCTV data in real time to specific Networked Video Recorders (NVR) in secure locations across the university estate. For buildings were analogue CCTV system is in use, the camera output is cabled to Video Camera Recorders (VCR’s) with real time recording available on motion sensors. The output of the cameras can be relayed between the VCR’s and authorised desk top computers via web links on the Universities computer network.

2.3 All CCTV cameras are set to motion detection, which means real time recording will be automated only when there are activities, that is, movement in the area. This ensures the system does not record when there are no activities taking place and guarantee sufficient disk recording space, maximise digital deletion or the recorded data ascribed retention period.

2.4 The Executive member responsible for the system is the Director of Property Services and the manager is the Head of Security. The University of West London is the owner of all recorded CCTV data.

3. Purpose of the CCTV system

3.1 The purpose of the CCTV system is as follows:

To enhance ‘safety, security and crime prevention on University premises’

Safety of staff, students, contractors and visitors

Provide an effective means by which to prevent and reduce crime in the monitored areas through an increased fear of detection and the prevention of offenders

Assist in the factual, accurate and speedy reconstruction of the circumstances of incidents

To assist the University and police in providing a swift response to criminal activity and provide evidential material for court and disciplinary proceedings

Protect the University assets

To assist in traffic management within University car parks

To assist in supporting University health and safety policies

To assist in the event of an emergency or disaster

4. Scope

4.1 The CCTV system is intended to view, monitor and record activities within University premises. It will focus primarily, but not limited to, key entry and exits points to premises, building perimeters, certain communal areas and others parts where CCTV is recommended to mitigate against risks to safety and security.

4.2 Every possible effort has been made in the planning and design of the CCTV system to give it maximum effectiveness. However it is not possible to guarantee that the system will see every single incident taking place in the areas of coverage.

4.3 The CCTV system must strike an appropriate balance between the personal privacy of individuals using the campuses/buildings and the objective of recording incidents.

4.4 The system will be operated fairly to ensure that all CCTV data is processed in accordance with GDPR, the Data Protection Act 2018 and the University data protection policy and only for the purposes to which it is established.

4.5 The system is not intended to invade the privacy of any individual in residential, business or other private premises, buildings or land not belonging to the University.

4.6 No sound will be recorded in public places and CCTV is not used to record conversations.

4.7 No images will be captured in areas where individuals would have an expectation of privacy (for example toilets, showers, changing facilities etc).

5. Signage

5.1 Strategically placed CCTV camera notices at key entry points to University premises will advise individuals that they are entering an area which is covered by CCTV cameras.

5.2 The CCTV notice at entrances to University of West London and in adjacent areas will contain:

The name of the data controller (ie University of West London)

The purpose(s) of the scheme

A contact name and telephone number for enquiries

6. Camera locations

6.1 The CCTV systems installed in and around the University estate comprises a mixture of fixed and pan/tilt/zoom cameras. These cameras provide fields of view encompassing approaches to building entrances, building property lines and internal communal and secure areas.

6.2 Covert cameras are not installed anywhere on the University premises. However, the University reserves the right to deploy covert cameras in exceptional circumstances affecting public safety, prevention and apprehension of nefarious and criminal activities within the premises. Any deployment of covert cameras will require written approval by the University Secretary or law enforcement agencies.

7. Data protection

7.1 This policy document will be implemented to ensure that the deployment and control of CCTV resources is proportionate and lawful under the terms of the General Data Protection Regulations (GDPR 2018), the Data Protection Act 2018 and the CCTV Codes of Practice issued by the Information Commissioner Office (ICO).

7.2 In summary, personal data should be processed in a manner that ensures its security. This includes protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. It requires that appropriate technical or organisational measures are used.

7.3 The lawful basis identified for processing the personal data as part of the CCTV system is legitimate interests.

7.4 This CCTV policy should be read in conjunction with the following policy documents:

University of West London data protection policy

Privacy statement

Property services records retention schedule

8. Responsibilities

8.1 University of West London as owner has responsibility for compliance with the purposes and objectives of the system including operational guidance and the protection of the interests of the University users and privacy of the individuals whose images are captured on the system. This responsibility is undertaken by the following members of staff:

8.2 Data Protection Officer: The University Secretary and Chief Compliance Officer is the appointed Data Protection Officer responsible for the management of data protection matters and for the development of specific guidance and practice on data protection issues for the University.

8.3 Director of Property Services: The Director of property services shall have responsibility for the CCTV infrastructure, ensuring there is an adequate maintenance regime, upgrades to CCTV hardware and software, so they are fit for purpose. The Director will support the Head of Security in developing and maintaining good CCTV data processing and handling practice within the University in accordance with the data protection policy and the information security policy.

8.4 Head of Security: The University Head of Security is responsible for the day to day management and control of the CCTV system on behalf of the University. Where management of the CCTV system is part of an outsourced contract to a TFM provider, he will work closely with the TFM partner to ensure service and maintenance agreements are carried out as dictated by the TFM contract or industry standard. Only security officers fully trained and who hold any relevant licenses required by regulatory authorities will be permitted to process data from the CCTV system. The Head of Security will work with the TFM provider of security services and CCTV contracts, to create an awareness of data protection "dos and don'ts" to security staff.

8.5 Chief Information Officer and/or Director of IT: The Chief Information Officer is responsible for protecting all data on the University’s IT systems and will ensure there are appropriate technical and organisational security measures in place to protect CCTV data on the system.

9. Assessment of the policy

9.1 The Head of Security will evaluate the system periodically to consider the following:

The assessment of impact upon crime

Assessment of areas without CCTV

The views of the users

Operation of the policy

Whether the purposes for which the scheme was established still exist

Future functioning, management and operation of the system

10. Management of the system

10.1 The Head of Security is responsible for the management of the University's CCTV system. This includes the maintenance and operation of the system as well as the protection of the privacy interests of individual members of the University and the public from intrusive monitoring.

10.2 The Head of Security will ensure that all Security staff involved in the recording, observation and capture of images are informed, through training on operating the CCTV system or through other means, of their responsibility to act in an ethical and lawful manner in line with relevant legislation and industry standards.

10.3 For the purpose of viewing CCTV images, an authorised person is defined as an employee or appointed person acting on behalf of University of West London who has an operational responsibility for either the prevention, investigation or detection of crime and/or the monitoring of the security and safety of the premises at University of West London.

10.4 All reported abuse or inappropriate use of the CCTV system will be investigated and if proven, the University will take appropriate measures to eliminate or minimise the risk of reoccurrence. Inappropriate use of the CCTV system will be considered a breach of University policy and will be handled accordingly.