CCTV Policy

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Policy Overview #

The Norfolk Childcare Company is securely monitored by a CCTV surveillance system the system used is a motion activated system both internally and Externally.

While the use is generally accepted, operators have a responsibility to those whose images are caught on camera. The business complies with the Information Commissioner’s CCTV Code of Practice; this is to ensure it is used responsibly and safeguards both trust and confidence.

CCTV is a closed-circuit television system on a private network. The footage is monitored mainly for surveillance and security purposes. The system uses strategically placed cameras that send the images to monitors placed elsewhere.

The Norfolk Childcare Company processes CCTV data based on its legitimate interest to ensure the safety and security of children, staff, and visitors. This is in line with GDPR Article 6, which allows data processing when necessary for legitimate interests, provided these interests do not override individuals’ rights and freedoms.

The intention of this Policy is to: #

• Ensure the safety and security of children, staff, and visitors through monitored CCTV surveillance.
• Comply with data protection laws, ensuring responsible use and safeguarding individuals’ privacy.
• Support safeguarding and child protection, aiding in the prevention and detection of incidents like theft or abduction.
• Limit access to CCTV footage to authorised personnel only, with clear protocols for storage, viewing, and retention.

Who is this policy aimed at? #

This policy applies to all The Norfolk Childcare Company LTD employees, Volunteers, students, temporary staff, or anyone working for or on behalf of The Norfolk Childcare Company LTD.

Where does this Policy Apply? #

• Any location The Norfolk Childcare Company LTD operates

Our CCTV System #

The system consists of multiple fixed-position cameras, a monitor, a digital hard drive, and cloud-based storage. Cameras are strategically placed throughout the premises, and the main entrance to the nursery may feature an IP-based door entry system.

No cameras are concealed, and they are all positioned to avoid capturing private areas, such as toilets.

Prominent signage is displayed at both the entry and exit points to inform staff, children, parents, and visitors of the presence of CCTV.

Due to the limitations of the digital recorder and the system itself, it cannot be guaranteed that every incident on the premises will be captured.

The system may include ‘real-time’ CCTV recording in communal areas to monitor restraint use and support safeguarding and child protection decisions. However, CCTV is not continuously monitored. While CCTV may cover car park areas, it does not guarantee protection against damage or loss in public areas. The Norfolk Childcare Company accepts no responsibility for any loss, damage, or theft of private property, and we cannot ensure that our CCTV system will capture every act of damage or theft on our premises or public property.

Purpose of the CCTV System #

The CCTV system has been installed by the nursery with the primary objectives of:

• Preventing damage to the building and deterring theft.
• Assisting in the prevention and detection of crime.
• Enhancing the safety of all users, including staff, children, parents, and visitors, while respecting individuals’ privacy.
• Deterring individuals with criminal intent.
• Monitoring staff interactions with children to ensure appropriate care is provided.
• Supporting the identification of activities or incidents that may require disciplinary action and providing evidence to the Nursery Manager.
• Reducing the risk of child abduction.
• Monitoring collection times of children
• Ensuring children are protected and receiving the correct care both in our care and in others’ care whilst on nursery property.
• Reviewing accidents and incidents.

The system will not be used to broadcast images over the internet.

CCTV Location #

Our cameras are positioned both externally and internally throughout all nursery settings, with their placement designed solely for the purposes identified in this policy, primarily safeguarding and security.

Each setting displays clear signage near the entrance indicating that CCTV is in operation. However, for security reasons, the exact locations of the cameras are not disclosed to the public. All staff members are aware of the camera locations to ensure transparency and compliance within the team.

The nursery does not use CCTV for covert monitoring, and all recordings are conducted openly and visibly, in line with our commitment to transparent and ethical monitoring practices.

In some cases, the car park may have an Automatic Number Plate Recognition (ANPR) CCTV system for enhanced security. Additionally, there may be an IP-based doorbell camera at the main entrance, as well as other CCTV cameras both inside and outside the nursery premises.

Recording #

All CCTV footage is recorded directly to a Network Video Recorder (NVR) for our CCTV cameras. For doorbell systems, footage may be uploaded to a secure cloud storage system.

Recordings are retained for a maximum of 30 days. After this period, our system will automatically delete footage. If storage capacity is reached before the 30-day limit, the system may overwrite the oldest recordings. As such, while we aim to store footage for up to 30 days, actual storage time may vary and may be shorter depending on capacity limitations.

Our cameras operate 24 hours a day, 7 days a week. Recordings may or may not include audio, depending on the device and settings.

Audio Recording #

Our CCTV cameras are equipped with audio recording capabilities; however, we enable this function only on select cameras in areas where we consider it necessary for safety and security purposes.

We adhere to a “reasonable expectation of privacy” approach, meaning that audio recording is only activated in areas where individuals would not reasonably expect complete privacy. Examples of such areas include communal hallways, outdoor gardens where conversations may be audible from outside the nursery (e.g., over a fence), car parks, and lobby areas.

Conversely, audio recording is not enabled in areas where privacy is expected, such as children’s playrooms or other private indoor spaces where one would not anticipate conversations to be overheard.

The only exception to this privacy guideline is any area where children are sleeping unattended. Due to the risks associated with sleep time and the importance of monitoring for any signs of distress, audio recording may be enabled in these specific areas. In this case, safeguarding considerations outweigh the need for audio privacy to ensure the well-being and safety of children while they sleep.

Please note that, outside of nursery operating hours, audio recording is enabled in all areas to enhance security monitoring of the premises.

Additionally, video recording is active in all designated areas at all times, regardless of whether audio recording is enabled.

Areas without Cameras #

We recognise the importance of privacy in certain areas for both staff and children.

To uphold privacy, no cameras are installed in any toilet facilities for staff or children. Cameras are positioned strategically to avoid capturing footage of these areas. In cases where a camera view may partially cover a children’s changing facility, a privacy mask will be applied to the camera feed to prevent recording in these areas, provided it does not compromise the overall security of the premises.

Additionally, there are no cameras placed inside staff rooms or office spaces to respect the privacy of our team members.

CCTV Storage, Viewing, and Retention #

Viewing of recorded CCTV footage is restricted to the Nursery Directors within the office and, when necessary, to authorised staff who require access in line with the system’s intended purpose. Access is strictly limited to those who need it to support the safety and security of the premises and the individuals within.

For the doorbell system, setting managers and designated staff have access to this footage specifically to verify the identity of individuals collecting children and to monitor collection times. This is done in accordance with our late collection policy to ensure timely and safe handovers. Access to this footage is limited to authorised personnel only, and it is used solely for child safeguarding and compliance with our nursery policies.

Outside of nursery operating hours, the company directors may access CCTV footage remotely via secure, password-protected access to ensure the security of the premises. This access is strictly controlled and does not operate as a “webcam” service; parents or any unauthorised individuals do not have access to view recordings.

CCTV monitoring screens are located in secure areas, such as a designated staff office, and are only visible to staff members who need to monitor them in real-time. Viewing is conducted with appropriate privacy to ensure security and confidentiality.

All recordings are stored securely and are only accessible to authorised personnel. Accessing stored footage requires password protection and is restricted to designated devices within the nursery office to maintain the privacy and integrity of the footage.

Administration #

The nursery conducts regular audits to ensure the ongoing justification for the use of CCTV and compliance with data protection regulations. Each audit includes a comprehensive review of:

• The stated purpose of CCTV usage, ensuring it remains relevant and necessary.
• The locations of CCTV cameras, verifying they are appropriate and only placed in required areas.
• The nature of the images recorded, ensuring they align with the intended purpose of safeguarding and security.
• The storage duration of recorded images, confirming it does not exceed the necessary retention period.
• The deletion process, ensuring timely and secure removal of footage after the designated retention period.

These audits help maintain compliance with data protection laws, including GDPR, and ensure the CCTV system remains suitable for its intended safeguarding purposes.

Requests to Access CCTV Footage #

The nursery is committed to respecting the rights of individuals to access personal data, in line with GDPR requirements. Requests to access CCTV footage are handled with care and are subject to strict privacy and data protection protocols.

Parent Requests: Parents may request access to footage if it involves their child. Requests must be submitted in writing to the Nursery Directors and specify the date, time, and location of the footage in question. Each request will be reviewed to ensure compliance with data protection regulations, particularly to protect the privacy of other children, staff, and any individuals who may appear in the footage.

If a request for footage involves identifiable third parties, the nursery will provide a transcript or redacted footage where possible. If fulfilling the request would compromise the privacy of other individuals or is not technically feasible, the nursery may deny the request in compliance with GDPR. A written explanation will be provided if a request is denied.

Access Rights: #

Only Nursery Directors and authorised staff involved in processing the request will view or handle the footage. No footage will be shared with unauthorised parties.

Retention and Response Time: #

The nursery retains footage for up to 30 days, and requests for access must be made within this period. We aim to respond to access requests within one month, as per GDPR guidelines.

Additional Information for Parents: #

CCTV footage is used solely for safeguarding and security purposes, and the nursery does not routinely provide access to parents or external individuals. Access will be granted only when legally justified, with privacy and data protection as our priority.

Breach of Policy #

Any member of staff, student or volunteer found to be in breach of this policy will be subject to disciplinary action as a breach of this policy and our safeguarding policy. Any breach could result in termination of employment.

Any unauthorised access, misuse, or loss of CCTV footage will be treated as a data breach, subject to immediate investigation. The nursery will report and document all data breaches in compliance with GDPR.

Policy Commencement and Review #

Date Commencement	Review Terms	Signed By
07/11/2024	Yearly	Jonathan Tricks, Operations Director