Download CCTV Policy - Cumbria Police

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Policy
This policy is under review. Whilst the full review is awaited this document
remains in place with the exception of the deployment processes, which will
now be in accordance with the Incident Management and Deployment
Procedures.
Policy:
CCTV Policy
Approved by which
Operations Board
board (or Chief officer)
and date :
Owner:
Chief Inspector Communications Centre
For release under Freedom of Information?
Supporting procedures
Yes
Review date
1) CCTV Procedures
2) (College of policing)- APP Website http://www.app.college.police.uk/?s=cctv
3) Data Protection Act
4) RIPA – (Regulation of Investigatory Powers Act)
5) ACPO Practical advice on Police Use of Digital Images)
Digital Media Unit (Police HQ)
Chief Inspector Communications Centre
October 2017
Amendments made
Date and version number
New policy
October 2014 - version 1
Contact for advice:
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1. Equality Analysis
What is the potential impact in relation to the General Duty of this proposal on each of the protected groups below?
Protected
characteristics
Positive Impact - The positive aspects of CCTV lie in the ability to build a picture of an incident or
person’s movements whether that is in terms of those sought by police or those who may need of
assistance in some way. In addition it gives a further crime prevention tool to the police in helping
identifying vehicles, victims and witnesses. It further assists police in terms of helping to prove /
disprove allegations.
Does the proposal:
eliminate unlawful
discrimination
(provide details)
Age
The majority of
offenders within
Cumbria are between 18
– 30 years of age but
this policy will apply to
all ages and therefore
will eliminate
discrimination as will be
applied to all.
CCTV will focus on any
group or individual that
the operator feels are
most likely to cause
trouble. E.g. at night
time the operator may
focus on groups of
young people rather
than elderly people,
which comes down to
the operators discretion.
This cannot be based on
bias factors and must be
a common sense
approach therefore
advance equality of
opportunity
(provide details)
Foster good relations
(provide details)
Other positive impact
(provide details)
This project does not
focus on advancing
equality of opportunity,
however if the
opportunities are
identified, they may be
investigated further to
provide a better CCTV
service.
For those in vulnerable
categories may feel
further protected by the
use of CCTV camera’s
e.g. the elderly.
Before any cameras are
installed full
consultation will be
completed with the
communities concerned.
Older people are also
less likely than younger
people to feel safe
outside after dark and
are also over
represented in the
percentage of people
who report that there
life is greatly affected by
fear of crime. They also
may experience
difficulty in accessing
services and
information, therefore
Will help towards
positive identification of
the correct person
therefore will not
discriminate against any
of the protected
characteristics.
Vulnerable groups can
be subject to more
antisocial behaviour and
crime than other
members of the
community.
National evidence
highlights that there is
under reporting of
antisocial behaviour,
domestic abuse, hate
crime (all strands),
serious acquisitive crime
by vulnerable members
of the community.
Negative Impact (provide details and
mitigating actions taken or proposed)
No
Impact
(√)
√
Nothing identified
√
Potentially this could
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eliminating unlawful
discrimination
Disability
The signage for CCTV
may be difficult for
people with learning
difficulties, visual
impairments which it
may make it harder to
read. Reasonable
adjustment should be
made so that signs
follow an easy read form
and also are produced in
braille, this will
eliminate unlawful
discrimination.
This project does not
focus on advancing
equality of opportunity.
However if the
opportunities are
identified, they may be
investigated further to
provide a better CCTV
service.
Equality of opportunity
would be advanced by
reasonable adjustment
and the use of signs in
the appropriate format.
by installing CCTV and
actively promoting it this
could improve
confidence within this
community.
contribute to efficiency
savings by contributing
to and enhancing
community safety and
identify those vulnerable
groups who maybe
targets of crime.
Those in vulnerable
categories may feel
further protected by the
use of CCTV camera’s.
Before any cameras are
installed full
consultation will be
completed with the
communities concerned
Vulnerable groups can
be subject to more
antisocial behaviour and
crime than other
members of the
community.
Disabled people are
significantly less likely
than able bodied people
to feel safe after dark.
Approx 90% of people
with learning disabilities
have experienced
harassment and bullying
and on-going low level
incidents are wide
spread and may go
undetected but can
escalate (Pilkington).
They also may
experience difficulty in
accessing services and
information, therefore
by installing CCTV and
actively promoting it this
could improve
Nothing identified
√
National evidence
highlights that there is
under reporting of
antisocial behaviour,
domestic abuse, hate
crime (all strands),
serious acquisitive crime
by vulnerable members
of the community.
Potentially this could
contribute to efficiency
savings by contributing
to and enhancing
community safety and
identify those vulnerable
groups who maybe
targets of crime.
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Sex
Sexual
orientation
The policy in itself is not
gender specific and
therefore will comply
with the general and
specific duties of the
equality act
CCTV is there to make
everyone in the
community feel safer
and this is especially
important for women
out at night, who have
reported that they feel
comforted knowing they
can be seen by CCTV.
The policy in itself is not
gender specific
and therefore will
comply with the general
and specific duties of the
equality act
This does not focus on
advancing equality of
opportunity, however if
the opportunities are
identified, they may be
investigated further to
provide a better CCTV
service.
This is not applicable to
CCTV as a person’s
sexuality would not be
obvious from images on
a camera and under
strict codes of conduct,
operators would not be
able to monitor
someone on this basis
anyway.
This is a generic policy
and has no bearing on
this aspect of equality
under this protected
characteristic.
confidence within this
community.
The policy in itself is not
gender specific
and therefore will
comply with the general
and specific duties of the
equality act.
Homophobic crime estimated that 90% goes
unreported because
victims are too
frightened or
embarrassed to report
it, therefore by installing
CCTV and actively
promoting it this could
improve confidence
within this community.
Vulnerable groups can
be subject to more
antisocial behaviour and
crime than other
members of the
community.
National evidence
highlights that there is
under reporting of
antisocial behaviour,
domestic abuse, hate
crime (all strands),
serious acquisitive crime
by vulnerable members
of the community.
Potentially this could
contribute to efficiency
savings by contributing
to and enhancing
community safety and
identify those vulnerable
groups who maybe a
target of crime.
Vulnerable groups can
be subject to more
antisocial behaviour and
crime than other
members of the
community.
National evidence
highlights that there is
under reporting of
antisocial behaviour,
domestic abuse, hate
crime (all strands),
serious acquisitive crime
Nothing identified
√
Nothing identified
√
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Gender
reassignment
The policy in itself is not
gender specific and
therefore will comply
with the general and
specific duties of the
equality act
There is evidence to
suggest that transgender
people experience more
hate incidents and
crime, therefore by
providing CCTV coverage
confidence within this
community would
increase.
The policy in itself is not
gender specific
and therefore will
comply with the general
and specific duties of the
equality act
As per gender.
The policy in itself is not
gender specific
and therefore will
comply with the general
and specific duties of the
equality act
As per gender. Tran’s
people appear to
experience more hate
incidents and crime,
therefore by providing
CCTV coverage
confidence within this
community.
Marriage and
civil partnership
This is a generic policy
and has no bearing on
this aspect of equality
under this protected
characteristic.
This is a generic policy
and has no bearing on
this aspect of equality
under this protected
characteristic.
This is a generic policy
and has no bearing on
this aspect of equality
under this protected
characteristic.
by vulnerable members
of the community.
Potentially this could
contribute to efficiency
savings by contributing
to and enhancing
community safety and
identify those vulnerable
groups who maybe
targets of crime.
Vulnerable groups can
be subject to more
antisocial behaviour and
crime than other
members of the
community.
National evidence
highlights that there is
under reporting of
antisocial behaviour,
domestic abuse, hate
crime (all strands),
serious acquisitive crime
by vulnerable members
of the community.
Potentially this could
contribute to efficiency
savings by contributing
to and enhancing
community safety and
identify those vulnerable
groups who maybe
targets of crime.
Vulnerable groups can
be subject to more
antisocial behaviour and
crime than other
members of the
Nothing identified
√
Nothing identified
√
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Pregnancy and
maternity
CCTV is there to make
everyone in the
community feel safer
and this is especially
important for women
out at night, who have
reported that they feel
comforted knowing they
can be seen by CCTV.
This does not focus on
advancing equality of
opportunity, however if
the opportunities are
identified, they may be
investigated further to
provide a better CCTV
service.
This is a generic policy
and has no bearing on
this aspect of equality
under this protected
characteristic.
community.
National evidence
highlights that there is
under reporting of
antisocial behaviour,
domestic abuse, hate
crime (all strands),
serious acquisitive crime
by vulnerable members
of the community.
Potentially this could
contribute to efficiency
savings by contributing
to and enhancing
community safety and
identify those vulnerable
groups who maybe
targets of crime.
Vulnerable groups can
be subject to more
antisocial behaviour and
crime than other
members of the
community.
National evidence
highlights that there is
under reporting of
antisocial behaviour,
domestic abuse, hate
crime (all strands),
serious acquisitive crime
by vulnerable members
of the community.
Potentially this could
contribute to efficiency
savings by contributing
to and enhancing
community safety and
Nothing identified
√
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Race
Religion and
belief including
non-belief
If the detainee is unable
speak or read English
the document will be
made available to
interpreters who will be
asked to read the
document to the
detainee in the
appropriate language.
Images captured on
CCTV will not reveal the
person’s face if they are
wearing a hijab. As this
dress is mostly
associated with the
Muslim faith, this could
be problematic. This
does not impact on
religion however, as this
potential issue only
concerns the CCTV
image itself and does
not affect the actual
beliefs or faith of any
group.
Religion is however not
usually obvious and
would not impact in any
way how a person is
monitored by CCTV, as
this would be a clear
breach of the strict
codes of conduct.
Images captured on
CCTV will not reveal the
This project does not
focus on advancing
equality of opportunity,
however if the
opportunities are
identified, they may be
investigated further to
provide a better CCTV
service.
This shows an equality in
that this opportunity is
available to all
For those in vulnerable
categories may feel
further protected by the
use of CCTV camera’s
Before any cameras are
installed full
consultation will be
completed with the
communities concerned
There is evidence to
suggest that take away
owners are unlikely to
report Hate Incidents
and crime as this could
affect the economic
night time income.
This project does not
focus on advancing
People who do not
speak English or English
is a second language
may experience
difficulty in accessing
services and
information, therefore
by installing CCTV and
actively promoting it this
could improve
confidence within this
community.
For those in vulnerable
categories may feel
identify those vulnerable
groups who maybe
targets of crime.
Vulnerable groups can
be subject to more
antisocial behaviour and
crime than other
members of the
community.
Nothing identified
√
National evidence
highlights that there is
under reporting of
antisocial behaviour,
domestic abuse, hate
crime (all strands),
serious acquisitive crime
by vulnerable members
of the community.
Potentially this could
contribute to efficiency
savings by contributing
to and enhancing
community safety and
identify those vulnerable
groups who maybe
targets of crime.
Vulnerable groups can
be subject to more
Nothing identified
√
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person’s face if they are
wearing a hijab. As this
dress is mostly
associated with the
Muslim faith, this could
be problematic. This
does not impact on
religion however, as this
potential issue only
concerns the CCTV
image itself and does
not affect the actual
beliefs or faith of any
group.
Religion is however not
usually obvious and
would not impact in any
way how a person is
monitored by CCTV, as
this would be a clear
breach of the strict
codes of conduct.
equality of opportunity,
however if the
opportunities are
identified, they may be
investigated further to
provide a better CCTV
service.
further protected by the
use of CCTV camera’s
Before any cameras are
installed full
consultation will be
completed with the
communities concerned
Take away owners are
unlikely to report Hate
Incidents and crime as
this could affect the
economic night time
income.
People who do not
speak English or English
is a second language
may experience
difficulty in accessing
services and
information, therefore
by installing CCTV and
actively promoting it this
could improve
confidence within this
community.
antisocial behaviour and
crime than other
members of the
community.
National evidence
highlights that there is
under reporting of
antisocial behaviour,
domestic abuse, hate
crime (all strands),
serious acquisitive crime
by vulnerable members
of the community.
Potentially this could
contribute to efficiency
savings by contributing
to and enhancing
community safety and
identify those vulnerable
groups who maybe
targets of crime.
If there is no potential impact (positive or negative) please provide a brief explanation why this is the case, e.g. the data utilised in
arriving at the decision, summary of responses to consultation etc.
Brief explanation of the ‘no impact’ decisions above
There is no impact upon any protected characteristic associated with this policy as it is unreasonable to make any
assumptions in relation to this area of business. The persons who are likely to fall into this field will come from
information provided or those whom are missing or wanted, these areas could potentially cut across any of the
protected characteristics however the processes and procedures that are in place do not discriminate in any way
against any of the characteristics as detailed.
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2. Aim
This policy explains how Cumbria Constabulary will use CCTV, taking into consideration national guidance
and recommendations outlined in APP.
The aim of the policy is to ensure Cumbria Constabulary 






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

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Provide clear and unambiguous information on the use of CCTV recording equipment.
Provide a framework of instructions for the use, retention and analysis of CCTV recording.
Meet the requirements of the Data Protection Act.
Meet the requirements of the Health and Safety at Work Act.
Promote a safer working environment for staff, detainee’s visitors and any other persons who may
come into contact with the CCTV recording system.
Meet the requirements of the Home Office Surveillance Camera Code of Practice (June 2013)
Signpost user to the national standards which Cumbria Constabulary adhere to.
Effectively use CCTV systems to obtain the best value from this asset.
Bring more offenders to justice by production of evidence.
Reduce repeat offending.
Reduce complaints.
The Chief Inspector Communications Centre is responsible for ensuring that the policy is delivered to all
officers / staff within the Constabulary.
The Chief Constable is the data controller for the CCTV system operated within Cumbria Constabulary. The
designated deputy is the Chief Superintendent of Territorial policing.
3. Terms and Definitions
What is CCTV?
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 Police or partner organisations.
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 and anti-social behaviour.
CCTV technology is used within Cumbria Constabulary to help detect, deter and disrupt criminality at a
local, force, regional and national level, including tackling travelling criminals, Organised Crime Groups and
terrorists. CCTV provides lines of enquiry and evidence in the investigation of crime and is used by forces
throughout England, Wales, Scotland and Northern Ireland.
Acronyms 
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
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

ANPR – Automatic Number Plate Recognition.
APP – Authorised Professional Practice.
CoP - College of Policing.
DPA – Data Protection Act.
HO – Home Office.
PNC – Police National Computer.
RIPA – Regulation of Investigatory Powers Act 2000.
BWV – Body worn video also known as Bodycam / Headcam.
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4. The Policy
This policy details how Cumbria Constabulary will maintain and operate closed circuit television (CCTV)
cameras within designated police facilities throughout Cumbria.
Cumbria Constabulary has an estate of mixed-use facilities including police stations, police custody suites,
vulnerable witness investigation suites, and other buildings, some or all of which allow or include
access/admission of members of the public as well as Cumbria Constabulary Officers and support staff. In
addition, other persons may come into contact with the Constabulary’s CCTV systems such as employees of
companies either directly or indirectly dealing with, or trading with, Cumbria Constabulary.
This policy is to enable all persons who use, or come into contact with, CCTV recording equipment, to be
reassured that it is being used in the correct manner and in adherence with national guidance
requirements.
CCTV has become a part of every-day life for the vast majority of the population of Great Britain.
Cumbria Constabulary has implemented a countywide public space CCTV system which is currently 53
cameras (with a maximum of 80) which are spread throughout Cumbria particularly targeting those areas
which have been identified as higher risk areas. The system is monitored by a dedicated unit, but all officers
and operational staff will have the ability to access CCTV footage.
The use of CCTV generally within Cumbria Police reflects the usage of CCTV systems throughout the
country. General use will fulfil two main criteria: to deter criminal and anti-social behaviour at sites where
CCTV is operating; to reassure both members of the public and members of staff via the overt use of such
CCTV systems.
Overt use of CCTV will fall under the remit of Regulation of Investigatory Powers Act and as such will be
documented accordingly in line with national guidance.
The Constabulary, like so many other organisations also employs the use of CCTV in many of its buildings
both for security purposes and, in the case of custody suites, as a further measure to safeguard both
detainees and custody staff.
As well as providing important safeguards, the use of CCTV also enhances public confidence in the provision
of policing, and allows for the recording, storing and retrieval of information over an extended period of
time.
It is now well accepted that CCTV in police custody suites, particularly in police cells and detention rooms,
can be a useful tool to assist in the monitoring of vulnerable detainees and thereby help reduce the
instances of self-harm. However, the use of cameras in what might normally be regarded as an area where
a detainee can expect an element of privacy raises some human rights issues. It is vital therefore that any
invasion of the right to privacy is balanced appropriately and sensitively with the need for police officers to
effectively discharge their duty of care to persons who are in custody and who are at increased risk of
harm.
The safe and secure detention of persons in custody is a core area of business for Cumbria Police. It is
imperative that individuals in custody receive a high level of care and that they (and the staff who are
responsible for them) can expect to be safe and well during their time in the custody suite. The use of CCTV
within custody suites will:
• Provide a reliable record of the initial reception, booking-in and detention of detainees.
• Record the condition and demeanour of the detainee.
• To act as a deterrent against violence or disorderly behaviour by detainees or others in the custody suite.
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• Discourage malicious complaints and allegations. (It should be noted that CCTV images would be seized as
evidence where there have been any complaint or allegation of misconduct).
• To provide, where appropriate, images and/or sound evidence to support any
prosecution, where activity within the custody suite will be of relevance to a court case.
• Enhance the security and safety of custody staff, detainees and others.
• Provide the visual monitoring of detainees in cells equipped with CCTV.
The impact of this Policy upon Crime and Disorder has been considered in accordance with the Crime and
Disorder Act 1998. Adherence to this Policy will help reduce crime and disorder.
The Constabulary will comply with the Information Commissioner's Code of Practice.
Requests for disclosure of CCTV images must be processed in accordance with the requirements of the
Criminal Procedures and Investigation Act 1996 and its Codes of Practice. Retention periods for images
served under these circumstances will be as for all viewed material.
This Policy should be read in conjunction with the Constabularies Automatic Number Plate Recognition
Policy owing to the potential links that can be made if the current cameras are utilised for ANPR
5. Supporting Information
(College of Policing) – APP Website http://www.app.college.police.uk/?s=cctv
This policy is compliant with the Health and Safety at Work Act, Data Protection Act, Police and Criminal
Evidence Act 1984 Codes of Practice, The Human Rights Act 1998, The Data Protection Act 1998, the Home
Office Surveillance Camera Code of Practice (June 2013) and the Regulation of Investigatory Powers Act
2000. It also takes into consideration the ACPO document Practical Advice on Police Use of Digital Images.
Legal Basis
The legal basis for custody and dealing with individuals held in police detention comes from the Police and
Criminal Evidence Act 1984 and the subsequent Codes of Practice for the Detention, Treatment and
Questioning of Detained Persons.
Human Rights Considerations/Articles Engaged
As this policy is fundamental to rights of individuals in respect of the powers and duties of the police in
relation to persons in police detention, consideration has been given to the compatibility of this policy and
related procedures with the Human Rights Act 1998; with particular reference to the legal basis of its
precepts; the legitimacy of its aims; the justification and proportionality of the actions intended by it; that it
is the least intrusive and damaging option necessary to achieve the aims; and that it defines the need to
document the relevant decision making processes and outcomes of that action.
Other supporting information is
•
Freedom of Information – The general right to access to all types of recorded information held by
public authorities.
•
RIPA – Regulation of Investigatory Powers Act 2000.
•
Surveillance Camera Codes of Practice, June 2013.
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6. Monitoring and Reviewing
The Policy will be reviewed every 3 years unless there is a change in legislation after being agreed at the
Constabulary Operations Board. Chief inspector Communications Centre will be responsible for reviewing
the policy. The review will consider relevant statistics and comments as necessary and where available, in
order to identify any trends, issues or concerns.
The Policy will also be reviewed whenever new legislation / guidance which may have an impact is
introduced.
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