Self-assessment tool - South Ayrshire Council

 
Self-assessment tool

How well does your organisation comply with the 12 guiding
principles of the surveillance camera code of practice? Complete
this easy to use self-assessment tool to find out if you do.

This self-assessment tool will help you and your organisation identify if you’re complying with
the principles in the code. It should be completed in conjunction with the surveillance camera
code of practice. The tool will help you show how well you comply with each principle. It is
possible to be largely compliant with some principles and to fall short against others. As a
result you will note that at the end of the questions against each principle there is a space to
include an action plan. This is to enable you to put actions in place over the next year to
improve your compliance to that principle. These boxes can also be used to make a note of
what evidence you could produce if required to show your compliance to that principle.
The document contains a combination of open and closed questions. For the open questions
there is a limit on how much you can write, so please feel free to include any additional notes
as an annex to the document – there are additional blank pages at the end of the tool.
We do not want you to send the self-assessment response to us. However, in the interest of
transparency we encourage you to publish the self-assessment on your website.
The self-assessment is for you to satisfy yourself and those that you surveil that you meet the
principles and identify any additional work to show compliance.
We would like you to let us know that you have completed this document as this will enable
us to understand the level of uptake. Also please let us know if you will be interested in
working towards certification against the surveillance camera code of practice in the near
future or just be added to our mailing list.
This is the first edition of the self-assessment tool which will evolve over time. Please forward
any feedback to scc@sccommissioner.gsi.gov.uk
Principle 1

Use of a surveillance camera system must always be for a specified purpose which is in
pursuit of a legitimate aim and necessary to meet an identified pressing need.

    1.   Have you translated principle 1 into clear objectives?                      Yes         No

If yes, what are they?

The purpose of South Ayrshire's public space CCTV operation is to:

- prevent crime
- provide protection for the general public

    2.   Do you regularly review the system and assess against objectives?           Yes         No

    3.   Have you considered the requirement of the end user?                        Yes         No

    4.    Is the system being used for any other purpose other than those            Yes         No
         specified?

If yes, please explain?

Access to the system is given to the Ayrshire Roads Alliance, who use the system to assist with
elements of traffic related safety. The Ayrshire Roads Alliance can monitor a selection of town-centre
cameras and can operate the cameras PTZ (pan, tilt and zoom) functionality. Whilst we feel the over-
arching ‘provide protection’ objective covers the ARA’s use of CCTV, it may not be clear to the public
that the cameras are used to assist with traffic related safety, and this will form part of our planned
public consultation in 2018.

Currently a key camera (Whitletts Roundabout) is owned by Traffic Scotland, but images are relayed
to SAC’s Control room as well as Transport Scotland. Traffic Scotland have indicated the image feed
to the SAC control will cease shortly, but where the arrangement continues then further clarity is
required on who the data owner is, and steps taken to ensure any informal ‘agreement’ is made
formal.

    5. Have you identified any areas where further action is required more           Yes         No
       fully conform with the requirements of Principle 1?

Action Plan

Public space CCTV can also be used by services such as Environmental Health and Waste
Management to assist with enforcement duties in areas such as dog-fouling and fly-tipping. Whilst it
is likely that these duties fall under the objectives of reducing crime, it may be the public perception
that CCTV is not actively used in these areas.

In a similar vein to traffic safety, the Council will need to highlight to those under surveillance (through
consultation and revised privacy notices) that the current objectives of CCTV also encompass
enforcement duties.
Principle 2

Use of a surveillance camera system must take into account its effect on individuals and their
privacy, with regular reviews to ensure its use remains justified.

    1. Do you review your system annually?                                    Yes        No

    2. Have you conducted a privacy impact assessment?                        Yes        No

    3.   Do you publish your privacy impact assessment and annual review?     Yes        No

    4.   Have you identified any areas where further action is required to
         more fully conform with the requirements of Principle 2?             Yes        No

Action Plan

South Ayrshire Council understands its obligations under the Data Protection Act, and therefore has
always developed processes to ensure the cameras are operated in a compliant manner. However,
the Council recognises that its public space CCTV operation has been in place for over 20 years
without significant review and that a clearer public space CCTV strategy needs developed.

South Ayrshire Council will voluntarily adopt the guidance set out by the CCTV Commissioner for
England and Wales, which in its view represents the best approach to operating public space CCTV
and will ensure ongoing compliance with the Data Protection Act and the forthcoming General Data
Protection Regulations. The guidance is used by many other organisations in their approach to
operating public space CCTV.

On that basis, the Council will:

    -    Complete Privacy Impact Assessments for its public space cameras and operating system
         using guidance from the Commissioner.

    -    Develop an annual review of its CCTV operation

    -    Publish the Impact Assessments (May 2018) and annual review (2019) on its website when
         complete.
Principle 3

There must be as much transparency in the use of a surveillance camera system as possible,
including a published contact point for access to information and complaints.

    1. Does signage exist highlighting the use of surveillance cameras?        Yes         No

    2. Does the signage highlight the point of contact?                        Yes         No

    3. Has there been proportionate consultation and engagement with the       Yes         No
       public and partners to establish that there is a legitimate aim and a
       pressing need for the surveillance camera system?

    4. Is the surveillance system a proportionate response?                    Yes         No

    5. Does your publication of information include the procedures and
       safeguards that are in place, impact assessments undertaken,            Yes         No
       performance statistics and other management information?

    6. Do you have a complaints procedure in place?                            Yes         No

    7. Do you make the public aware of how to escalate complaints?             Yes         No

    8. Is there a defined timescale for acknowledging and responding to        Yes         No
       complaints and is this conveyed to the complainant at the outset?

    9. Do you publish the number and nature of complaints received?            Yes         No

    10. Have you identified any areas where further action is required to      Yes         No
        more fully conform with the requirements of Principle 3?

Action Plan

South Ayrshire Council believes that, in general, its public space CCTV is a proportionate means of
achieving a legitimate aim.

Signage does exist, but it needs reviewed, both in terms of the wording and its location. The Council
recognises that there needs to be clearer signage at each of the main entrance routes into the towns
where CCTV operates. Signage will be updated to ensure it clearly states the reason for CCTV, the
owner of the operation (the Council), and the correct contact number of 0300 123 0900.

It is recognised that further consultation and engagement is required both internally and externally
around the use of CCTV, and this will be undertaken as part of the Privacy Impact Assessment
process. At the point the Privacy Impact Assessments are published, the Council will also be in a
position to publish CCTV related statistics and management information.

The Council has a corporate complaints process, which complaints about CCTV would normally fall
under in the first instance. The corporate complaints process is widely promoted across the Council,
whether that be face-to-face, telephone or online. The Council fully adheres to the Scottish Public
Services Ombudsman complaints process. Whilst the number of complaint across the Council is
published, the Council does not publish how many complaints were specifically CCTV related, but
this information can be collated going forward and will be published alongside the Privacy Impact
Assessments.
Principle 4

There must be clear responsibility and accountability for all surveillance camera system
activities including images and information collected, held and used.

1. What arrangements are in place to provide clear responsibility and accountability?

Public Space CCTV is monitored by the Council's Emergency Response Team (ERT), and their
CCTV Code of Practice was developed in 2012.

Revised protocols were agreed with Police Scotland in 2017 with regards to directed surveillance
operations.

The Council has a Data Protection Officer within its Information and Governance Team.

2. Are all staff aware of their responsibilities?                                Yes       No

3. Please explain how you ensure the lines of responsibility are adhered to.

All ERT staff receive in-house training on CCTV. All staff are conversant with the Code of Practice,
and relevant operational procedures. The Code of Practice states the roles and responsibilities.

4. If jointly owned, is it clear what each partner organisation is responsible   Yes       No
   for and what the individual obligations are?

This is not applicable.

5. Have you identified any areas where further action is required to more
   fully conform with the requirements of Principle 4?                           Yes       No

Action Plan

The Code of Practice will be reviewed and updated in line with the Privacy Impact Assessment
process.

Whilst operational liaison exists between Police Scotland and South Ayrshire Council, this will also
be reviewed and updated in line with the Privacy Impact Assessment process.

The updated Code of Practice will need to be adopted by the Ayrshire Roads Alliance where they
continue to monitor any aspect of the Council's public space CCTV.

Currently a key camera (Whitletts Roundabout) is owned by Traffic Scotland, but images are relayed
to SAC’s Control room as well as Transport Scotland. Traffic Scotland have indicated the image feed
to the SAC control will cease shortly, but where the arrangement continues then further clarity is
required on who the data owner is, and steps taken to ensure any informal ‘agreement’ is made
formal.

In all cases, to ensure compliance with data protection principles, revised data sharing agreements
will be implemented with all partner agencies.
Principle 5

Clear rules, policies and procedures must be in place before a surveillance camera system is
used, and these must be communicated to all who need to comply with them.

1. Do you have clear policies and procedures which help to ensure that any
   legal obligations affecting the use of such a system are addressed?
                                                                                 Yes       No
    If so please specify.

See Principle 4.

2. Do you follow a quality management system?                                    Yes       No

3. Are the rules, policies and procedures part of an induction process for all   Yes       No
   staff?

4. How do you ensure that all system users remain up to date and efficient with relevant operational,
   technical, privacy considerations, policies and procedures?

The Council has a Performance, Development and Review (PD&R) process which covers work
objectives and expectations. Regular team meeting and communications ensure advisors are
informed.

5. Have you considered qualifications relevant to the role of the system
   users, such as the National Occupational Standard for CCTV operations         Yes       No
   or other similar?

6. If so, have any of your system users undertaken any occupational              Yes       No
   standards to date?

7. Do your system users require SIA licenses?                                    Yes       No

8. If staff do not need a license, how do you ensure they have the necessary skills and knowledge
   to use or manage the surveillance system?

Training is managed in-house and each new member of staff is allocated a supervisor who will
shadow and train the advisor until competent in CCTV. There are online e-learning modules designed
to complement on the job training (under a revised training plan) which staff will also complete
refresher training every 6 months

9. Have you identified any areas where further action is required to more        Yes       No
   fully conform with the requirements of Principle 5?

Action Plan

It is recognised that whilst mechanisms are in place around training and adherence, these need to
be reviewed to ensure they are as robust as possible. Ongoing training on RIPSA and the CCTV
Protocol that exists between SAC and the Police would be beneficial to the staff using the system.
CCTV will form a specific work objective for ERT advisors within the Council's PD&R process.
Alongside that, there will be a monthly check to ensure operators can evidence their understanding
of CCTV operation and adherence.
The Council will consider further the BS 62676/11064 series, alongside BS 7958 and 8495.

The guidance from the CCTV Commissioner will be the main reference point for the Council.
Principle 6

No more images and information should be stored than that which is strictly required for
the stated purpose of a surveillance camera system, and such images and information
should be deleted once their purposes have been discharged.

    1. On what basis are images retained and for how long?

Images are stored for 31 days on a digital hard drives, and only for the specified purpose of the
system. They are deleted from the system after this period. The authority does not retain copies
of any discs.

    2. Do you have an auditable process for reviewing images and managing their          Yes   No
       retention?

    3. Are there any time constraints in the event of the enforcement agency not         Yes   No
       taking advantage of the opportunity to view the retained images?

Police Scotland have confirmed that 31 days generally allows enough time for key
images to be downloaded as part of any investigation.

    4. Are there any time constraints which might affect external parties from           Yes   No
       viewing the images?

    5. Do you quarantine all relevant information and images relating to reported        Yes   No
       incident until such time as the incident is resolved and/or all the information
       and images have been passed on to official third parties?

    6. Have you identified any areas where further action is required to more fully      Yes   No
       conform with the requirements of Principle 6?

Action Plan

A CCTV activity log is in place for both ERT Advisors and representatives of Police Scotland when
actively moving cameras. The process for managing and quarantining retention needs reviewed
and refined, as does the auditable process in relation to reviewing images, and these will form part
of the updated Code of Practice.
Principle 7

Access to retained images and information should be restricted and there must be clearly
defined rules on who can gain access and for what purpose such access is granted; the
disclosure of images and information should only take place when it is necessary for such a
purpose or for law enforcement purposes.

1. Do you have a policy on who has access to the stored information?          Yes          No

2. Do you have a policy on disclosure of information?                         Yes          No

3. What checks to do you have in place to ensure that the disclosure policy is followed?

    All disclosures are recorded and logged, either through CCTV logs, RIPSA (Regulation of
    Investigatory Powers) or Data Access Requests.

4. Have you identified any areas where further action is required to more
   fully conform with the requirements of Principle 7?                        Yes          No

Action Plan

Whilst mechanisms are in place around disclosure, it is recognised they need reviewed to ensure
they remain fully robust and complaint. This will be incorporated into the updated Code of Conduct.
Principle 8

Surveillance camera system operators should consider any improved operational, technical
and competency standards relevant to a system and it purpose and work to meet and maintain
those standards.

1. What approved operational, technical and competency standards relevant to a surveillance
   system and it purpose does your system meet?

As part of our procurement process for both cameras and the operating system, the technical
specification requires NSI (or equivalent) compliance.

2. How do you ensure that these standards are followed appropriately?

Providers are required to prove their compliance at tender stage. Contracts are managed alongside
the Council’s procurement team with regards to supplier performance.

3. What steps are in place to secure certification against the approved standards?

As above.

4. Have you identified any areas where further action is required to more     Yes        No
   fully conform with the requirements of Principle 8?

Action Plan

The Council is currently developing its corporate public space CCTV strategy. It is recognised that
aspects of the current CCTV operating system require upgraded or replaced. At the point this
happens, there will be greater focus via the procurement process on approved standards.

Please also see the Action Plan for Principle 5.
Principle 9

Surveillance camera system images and information should be subject to appropriate
security measures to safeguard against unauthorised access and use.

1. What security safeguards do you have in place to ensure the integrity of images and information?

The control room is coded entry only, and a log book confirms all visitors. Only ERT advisors or the
Police Scotland CCTV Liaison Officer are able to access the CCTV operating system. Police
Scotland take full responsibility for any images they download for evidential purposes and have their
own safeguards in place. The system deletes images after 31 days. The system is password
protected.

2. If the system is connected across an organisational network or intranet, do sufficient controls and
   safeguards exist?

The CCTV system is not currently part of the corporate network. All images come in directly via BT
analogue fibre.

3. What is the specified purpose for which the information are being used and accessed and is this
   consistent with the stated purpose?

The purpose directly relates to the objective laid out in Principle 1.

4. Do you have preventative measures in place to guard against the misuse
   of information and images?                                                    Yes         No

5. Are your procedures and instructions and/or guidelines regarding
   storage, use and access of surveillance system information                    Yes         No
   documented?

6. Have you identified any areas where further action is required to more
   fully conform with the requirements in Principle 9?                           Yes         No

Action Plan

It is recognised that whilst mechanisms are in place around safeguarding, it is recognised they need
reviewed to ensure they remain fully robust and complaint. This will be incorporated into the updated
Code of Conduct.

It is likely that the Council will upgrade or replace significant elements of its CCTV operation in the
next 3 years, and transmission may move from analogue to internet, and may link to the corporate
network. The Council’s ICT and Information and Governance teams will be fully involved in any
decision taken.
Principle 10

There should be effective review and audit mechanisms to ensure legal requirements, policies
and standards are complied with in practice, and regular reports should be published.

    1. Does your system have a review process that shows it still addresses   Yes         No
       the needs and delivers the benefits that justify its use?

    2. Have you identified any cameras that do not remain justified in        Yes         No
       meeting the stated purpose(s)?

    3. Have you conducted an evaluation in order to compare alternative       Yes         No
       interventions to surveillance cameras?

    If so please provide details.

    4. Is it cost effective to continue running your surveillance camera      Yes         No
       system?

    5. Have you identified any areas where further action is required to      Yes         No
       more fully conform with the requirements of Principle 10?

Action Plan

Using a range of statistics, such as the number of recorded crimes within the camera radius, and the
number of Police evidential packages that utilise CCTV footage, the Council is able to review the
effectiveness of cameras. However the proposed Privacy Impact Assessment will ultimately confirm
camera viability, taking into account internal and external consultation. The Assessment will also
allow clarity around alternative interventions.

With regards to cost, the CCTV system has a set budget and adheres to that budget. However it is
recognised that a more modern CCTV system that embraces new technology will likely bring longer-
term savings, and these will be explored as part of the Council’s CCTV strategy.
Principle 11

When the use of a surveillance camera system is in pursuit of a legitimate aim, and there is a
pressing need for its use, it should then be used in the most effective way to support public
safety and law enforcement with the aim of processing images and information of evidential
value.

    1. Are the images and information produced by your system of a
       suitable quality for the criminal justice system to use without           Yes        No
       enhancement?

    2. Do you have safeguards in place to ensure the forensic integrity of
       the images and information including a complete audit trail?              Yes        No

    3. Do you have a policy on data storage, security and deletion?              Yes        No

    4. Is the information stored in a format that is easily exportable?          Yes        No

    5. Does the storage ensure the integrity and quality of original recording
       and the meta data?                                                        Yes        No

    6. Have you identified any areas where further action is required to
       more fully conform with the requirements in Principle 11?                 Yes        No

Action Plan

South Ayrshire Council has an agreement that Police Scotland download images onto disc for court
evidential purposes. The Scottish Courts have yet to embrace digital files for evidential purposes.

Whilst information is exportable, the process is not easy or streamlined nor are images of the highest
quality, and this will be a key consideration when upgrading or replacing aspects of the CCTV system.
Principle 12

Any information used to support a surveillance camera system which compares against a
reference database for matching purposes should be accurate and kept up to date.

    1. Do you use any specialist technology such as ANPR, facial
       recognition, Body Worn Video (BWV) or remotely operated vehicles       Yes       No
       (Drones)?

    2. Do you have a policy in place to ensure that the information
       contained on your database is accurate and up to date?                 Yes       No

Not Applicable – No database of images is kept.
    3. Do you have safeguards in place to ensure the forensic integrity of
       the images and information including a complete audit trail?           Yes       No

Not Applicable – No database of images is kept.

    4. Do you have a procedure for deciding when and whether an               Yes       No
       individual or vehicle should be included in a reference database?

Not Applicable – No database of images is kept.

    5. What policies are in place to determine how long information remains   Yes       No
       in the reference database?

Not Applicable – No database of images is kept.

    6. Are all staff aware of when surveillance becomes covert surveillance
       under the Regulation of Investigatory Powers Act (RIPA) 2000?          Yes       No

    7. Have you identified any areas where further action is required to
       more fully conform with the requirements in Principle 11?              Yes       No

Action Plan

A separate self-assessment will be completed by South Ayrshire Community Safety which will clarify
the use of body-worn and redeployable cameras further.
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