Public Spaces CCTV Policy

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1. Statement of Policy

Closed-Circuit Television (CCTV) is technology which provides an effective means of identifying people, vehicles or incidents that may result in action being required by the Police or partner organisations.

Dyfed-Powys Police have implemented a Public Space CCTV system in 25 towns across the force area consisting of over 155 cameras.

It is a proactive policing tool for response policing and investigations, which can prevent criminality by targeting criminals and areas which are subject to higher levels of crime.

CCTV technology will be used within Dyfed-Powys Police to help detect, deter and disrupt criminal activity at local, regional and national level, including tackling travelling criminals, Organised Crime Groups and terrorists.

Dyfed-Powys Police will use the CCTV system to assist operational officers and staff in gathering evidence in the investigation of crime and to provide public reassurance. The CCTV cameras will be monitored by dedicated staff and all officers and operational staff will have the ability to access CCTV images as required and in line with their roles and responsibilities.

The purpose of this policy is to identify the procedures and protocols required for the application, deployment, and use of CCTV cameras by police officers/staff, taking into consideration national guidelines and legislation. This policy will outline and achieve the following:

Provide clear and unambiguous information on the use of CCTV viewing and recording equipment.
Provide a framework of instructions for the use, retention and analysis of CCTV recording.
Meet the requirements of the Data Protection Act 2018
Meet the requirements of UK General Data Protection Regulation (UK GDPR).
Meet the requirements of the Health and Safety at Work Act 1974.
Promote a safer working environment for staff and any other individual who may come into contact with the CCTV recording system.
Meet the requirements of the Surveillance Camera Commissioner’s Codes of Practice and guiding principles.
Effectively use CCTV system to obtain the best value from this asset.
Bring more offenders to justice through producing quality CCTV evidence.

The policy and associated guidance establish the legal basis and guidance for the use of Dyfed-Powys Police Public Space CCTV.

Applies (but not limited) to: All categories of Dyfed-Powys Police officers and staff whether full-time, part-time, permanent, fixed term, temporary (including agency staff, associates and contractors), seconded staff and volunteers. Police Officers, staff and volunteers accessing and using Force assets and property must have due regard to the contents of this policy.

2. Policy Scope

This policy and associated guidance, namely the CCTV Operating Procedure, is intended to enable officers to comply with legislation and guidance to capture evidence for use in court proceedings and in the investigation and detection of crime.

Overarching principles for the operational use of CCTV:

Public Space CCTV has an essential role to play in keeping people safe, whilst at the same time people need to be confident that their right to privacy remains.

CCTV cameras will:

conform to industry standards
be situated in locations where it is justifiably most needed and will most benefit the public interest
be lawfully and transparently operated by competent individuals with the privacy of the individual citizen at the heart of system and procedural decisions
be used overtly and should not be used covertly except in exceptional circumstances and where the necessary authorities have been granted
provide real time information about ongoing incidents
assist in reducing crime and disorder
assist with missing person enquiries
assist the conducting of investigations
provide intelligence
reduce the fear of crime and help communities feel safer
increase public perception of safety
increase guilty pleas of offenders and bring offenders to justice
ensure users can justify their use of the system and have a legal and objective basis for taking the footage. This must be proportionate to the incident/activity in question.

3. Powers and Policy/Legal Requirements

This CCTV system will be owned and funded by Dyfed-Powys Police.

System ownership will lie with the force Operations Department with the Superintendent in charge of Specialist Operations being the designated Senior Responsible Owner (SRO).

A Single Point of Contact, namely the CCTV Co-Ordinator, is the formal designation at a more tactical level and will be the recognised expert source of advice and a co-ordinator of all overt surveillance camera activity and capability within the organisation. The CCTV Co-Ordinator will also have first line management responsibility for the CCTV Operators.

The Chief Constable will act as the Data Controller for CCTV images recorded and stored on police systems.

The system has been installed, operated and managed in accordance with The Surveillance Camera Code of Practice and the SRO will hold responsibility for demonstrating the integrity of processes and for having regard to the Surveillance Camera Commissioner’s Code of Practice. This enables the Force to demonstrate to communities that we are operating best practices which are transparent and proportionate.

CCTV images are retained for a period of 31 days following which they are auto-deleted day-on-day, unless downloaded for evidential purposes whereby images are retained in line with the Managements of Police Information.

An Operating Procedure has been produced outlining and defining the operational use of the CCTV system to ensure compliance with the appropriate legislation, Code of Practice and force policies.

The system has the support of the respective County Councils, Town Councils, Welsh Government and Trunk Road Agencies. Memorandums of Understanding have been agreed with the relevant parties outlining specific roles and responsibilities.

4. Options and Contingencies

A Crime Pattern Analysis including crime data, anti-social behaviour and hate crime incidents, and calls for service, along with local policing knowledge informs decision making in relation to camera locations.

The CCTV Co-ordinator will undertake annual reviews of camera locations. Overall responsibility will sit with the Superintendent in charge of Specialist Operations being the designated Senior Responsible Owner (SRO).

Privacy Impact Assessments will be completed for all camera locations and published on the Dyfed-Powys Police website.

In line with the Surveillance Camera Commissioner’s Code of Practice all camera sites will be reviewed annually, and updated Privacy Impact Assessments issued as required. Where a decision is made to remove and/or relocate a camera site a new Privacy Impact Assessment will be issued/updated as necessary.

As a minimum, annual reviews of camera sites will include a review of the privacy masks applied to each camera to ensure that windows and/or doors of any private dwellings are appropriately masked to minimise intrusion.

The CCTV Co-Ordinator will be responsible for providing operational users with assistance on the use of the CCTV system.

The CCTV Co-Ordinator will be responsible for undertaking monthly ad-hoc audit reviews and providing management information as required and as outlined in the Performance Framework

The CCTV system will be monitored by a dedicated team of CCTV Operators based in the Force Communication Centre (FCC) at Police Headquarters where access is restricted and only permitted for authorised personnel. All CCTV images will be recorded 24 hours a day, 365 days a year and will also be viewable locally.

Any breach of the CCTV Policy or misuse of the CCTV system by Dyfed-Powys Police officers, staff and volunteers or other authorised users will initially be investigated by the CCTV Co-Ordinator to assess and ascertain if a breach has occurred. Any serious breach of the CCTV Policy or misuse of the system will be immediately investigated and an independent investigation by the Professional Standard Department (PSD) undertaken to make recommendations on how the breach should be remedied.

The CCTV Operators, under the supervision of the CCTV Co-Ordinator, are responsible for raising all faults with the cameras or related equipment with the Contractor.

All operational police officers and investigative police staff and volunteers will have access to the HikCentral system, which is managed via the electronic System Access process.

Baydale Control Systems Ltd are responsible for annual maintenance of cameras and for producing the required documentation.

Users must be in a position to justify their use of the system, which must relate to a policing purpose, in line with the Data Protection Act 2018 and Computer Misuse Act 1990.

Users are responsible for the sharing of footage with the CPS as required.

5. Take action and review

The policy will be applied alongside an Operating Procedure outlining the intended purpose and use of the Public Space CCTV system and associated software.

Compliance of the policy and related Operating procedure will be monitored through:

System administrators reviewing all system access requests
System access controlled through System Administrators
Ad-hoc audit checks
Preparation of monthly / quarterly / annual statistical and usage reports

Application of the policy and the Surveillance Camera Commissioner’s Code of Practice is re-enforced through the publication of the Privacy Impact Assessments on the force website. This policy will be reviewed biennially by the CCTV Co-ordinator.

A CCTV page on the force Intranet site exists and provides officers, staff and volunteers with information in relation to the use and functionality of the system, as well as all camera locations.

Public Space CCTV reporting will be as approved by the Superintendent, Specialist Operations.

CODE OF ETHICS CERTIFICATE OF COMPLIANCE

This policy has been drafted in accordance with the Code of Ethics and has been reviewed on the basis of its content and the supporting evidence and it is deemed compliant with that Code and the principles underpinning it.

HUMAN RIGHTS ACT CERTIFICATE OF COMPLIANCE

This policy has been drafted in accordance with the Human Rights Act and has been reviewed on the basis of its content and the supporting evidence and it is deemed compliant with that Act and the principles underpinning it.

EQUALITY IMPACT ASSESSMENT

Section 4 of the Equality Act 2010 sets out the protected characteristics that qualify for protection under the Act as follows: Age; Disability; Gender Reassignment; Marriage and Civil Partnership; Pregnancy and Maternity; Race; Religion or Belief; Sex; Sexual Orientation.

The public sector equality duty places a proactive legal requirement on public bodies to have regard, in the exercise of their functions, to the need to:

eliminate discrimination, harassment, victimisation, and any other conduct that is unlawful under the Act;
advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it;
foster good relations between persons who share a relevant protected characteristic and persons who do not share it.

The equality duty applies to all protected characteristics with the exception of Marriage and Civil Partnership, to which only the duty to have regard to the need to eliminate discrimination applies.

Carrying out an equality impact assessment involves systematically assessing the likely or actual effects of policies on people in respect of all the protected characteristics set out above. An equality impact assessment should be carried out on any policy that is relevant to the public sector equality duty.

EQUALITY IMPACT ASSESSMENT COMPLETED: November 2023