This policy has been prepared for the guidance of operators of the CCTV system and for the information of all users of Purley United Reformed Church (PURC). It seeks to ensure that its operation is consistent with the obligations on PURC imposed by the Data Protection Act 1988, the Human Rights Act 1999 and the good practice guidance issued by the Information Commissioner.
PURC has installed an image-only CCTV system for the following purposes:
- To assist in the prevention and detection of crime
- To facilitate the identification, apprehension and prosecution of offenders in relation to crime and public order
- The protection of the church caretakers and evening duty officers and all other persons whilst on the premises
- The protection of the premises including:
- monitoring of the entry and exit to the church premises, including the use of the rising bollards for the purposes of providing evidence of incidents in the event of disputes over responsibility for damage caused to and by the bollards in relation to vehicles entering and leaving the premises.
- monitoring the operation of the security lighting
- monitoring any acts of abuse or damage to the premises such as vandalism and fly tipping
The CCTV system has five cameras and a recorder. Two cameras are located internally in the foyer and three on the exterior, one at the exterior corner of the lounge facing the Pampisford Road steps and two facing the entrance and the exit to the church’s driveway.
The CCTV system operates throughout the year for 24 hours a day.
Church Members, all users of the building, visitors and the public are made aware of the presence of the CCTV system by appropriate signage.
To respect privacy the cameras are fixed and focused only on the areas described in section 3.1 above.
3.5 Recorder, storage and physical access
Images captured on camera are recorded on a digital hard drive. Only those approved by PURC Trustees/Elders listed in 4.2 below will be allowed access to the recorder, which is kept in a secure place.
For the purposes of the Data Protection Act 1988, the PURC Trustees’/Elders’ Meeting is the data controller and is legally responsible for the management and maintenance of the CCTV system. The senior responsible officer is the Church Secretary
4. Recording, handling and retention
4.1 Monitoring images
Images captured by the system will be monitored by those approved by the PURC Trustees’/Elders’ Meeting, with access to other individuals only given where essential for one of the purposes listed in section 2 of this policy.
4,2 Authorised access
Except in emergencies, only those people on the list below are authorised to have access to the CCTV system or its recordings:
- Purley URC Minister
- Purley URC Church Secretary
- Convener of the PURC Management Committee
- Nominated member of the PURC Management Committee
- Other individuals to access their personal data as set out in section 4.9
The PURC Trustees’/Elders’ Meeting will ensure that all authorised users receive guidance in all relevant aspects of the CCTV system.
4.4 Identifying and recording images
Images recorded digitally will have retrieval dates and times recorded in a logbook.
Unless required for evidential purposes or the investigation of crime all images on the hard drive will be retained for four months before being automatically overwritten.
Images required for evidential purposes, or the investigation of crime will be copied on to a USB stick by an authorised person while witnessed by a second person. The USB stick will be placed in a sealed envelope and kept locked in the church safe until required for use. The envelope should clearly describe the content and be dated.
4.6 Requests to view or copy images
Requests to view or copy CCTV images will be considered on a case-by-case basis by a designated subgroup designated by the PURC Trustees/Elders’ Meeting. If access is denied the reasons will be reported to the next Trustees’/Elders’ Meeting and recorded in the minutes
4.7 Copies of recorded images
Copies of digital images will only be made when required by law, requested in connection with potential legal action, including insurance claims, in response to subject access requests under 4.8 below or for assisting in diagnosing faults in the system.
4.8 Requests from the police, law enforcement agencies, including solicitors
Requests from the police or other law enforcement agencies may arise for several purposes, including:
- For the prevention of crime
- For the apprehension or prosecution of offenders
- For the purposes of, or in connection with, any legal proceedings (including prospective legal proceedings) and insurance claims
- Is otherwise necessary for the purpose of establishing, exercising or defending legal rights.
All such requests should be directed to the Church Secretary and the Convener of the Management Committee who will consider and determine the request on behalf of the PURC Trustees’/Elders’ Meeting.
4.9 Rights of individuals
The PURC Trustees’/Elders’ Meeting is obliged to supply individuals (Data Subjects) with their personal data under the Data Protection Act 1988 unless the request is manifestly unfounded or excessive. Individuals wishing to access their personal information contained within CCTV images should contact the PURC Church Secretary.
5. Complaints and contacts
The PURC Trustees’/Elders’ Meeting are responsible for the operation of the CCTV system. Any concerns in respect of the system’s use or in relation to alleged breaches of compliance with this policy should be sent to the Church Secretary.
Church Secretary, Purley United Reformed Church, 906 Brighton Road, Purley, Surrey, CR8 2LN; [email protected]
Convener, PURC Management Committee, 906 Brighton Road, Purley, Surrey, CR8 2LN; [email protected]
This policy will be reviewed annually by the PURC Trustees’/Elders’ Meeting.
Approved by the PURC Trustees’/Elders’ Meeting on 12 May 2022