The Closed Circuit Television System on the BAM Estate

Following a spate of incidents in 2002 the Board of BAM Estate considered that a number of security enhancements were needed to the Estate, and as part of this an overt surveillance camera system was needed to deter criminals and to improve the safety of residents and their visitors.  At their meeting on 9th December 2002 they agreed that a scheme of 6 cameras connected to a centralised control in the Estate Office would be the minimum requirement for the purposes of crime prevention and public safety on the BAM Estate.  They subsequently approved the installation of the scheme at their meeting on 16th January 2003.  This provision was gradually extended to 12 external cameras.  Due to further break-ins in 2012 it was decided to install internal cameras in the entrance ways of each block, and this programme was completed in 2015.  There are now a total of 52 surveillance cameras covering public places.

This is available to download as a pdf.

The scheme is for the purpose of crime prevention and public safety, and to assist the appropriate authorities in the detection of criminal activity or the apprehension and prosecution of offenders.

Estate Management (Hampstead) Ltd is registered as Data Controller with the Information Commissioner’s Office under registration reference: Z7601589 and this extends to include CCTV for Crime Prevention. 

Codes of Practice
Management have a duty to have regard to the guidance issued by Government in the Surveillance Camera Code of Practice pursuant to POFA 2012 and the IOC Data Protection Code of Practice for Surveillance Cameras 2015, and any statutory obligations under the Data Protection Act 1998. 

Guiding Principles:-

1.     Use of the surveillance camera system must always be for the specified purpose which is in pursuit of a legitimate aim and necessary to meet an identified pressing need.  It should not be used for other purposes that would not have justified its establishment in the first place.

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

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

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

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

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

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.

8.     The surveillance camera system operators should consider any approved operational, technical and competency standards relevant to a system and its purpose and work to meet and maintain those standards.

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

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.

11. The use of the surveillance camera system is in pursuit of a legitimate aim and a pressing need, and it should 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.

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

Security and Disclosure Policies
Quality of the images.

1.     The date and time references should be checked weekly to ensure their accuracy.  In particular the necessary corrections must be made manually to adjust for Summer Time.

2.     A daily log is to be kept.  Faulty cameras or systems are to be repaired within two weeks.

Processing the images

1.     Images are not to be retained for longer than 31 days.

2.     Once the retention period has expired the images are to be erased.

3.     If images are to be retained for evidential purposes they are to be locked away under the control of the Estate Manager.

4.     Removal of medium with recorded images is to be documented as follow:
a.  The date and time of removal
b.  The name of the person removing the images
c.  The name of the person viewing the images, and any organisation they represent
d.  The reason for the viewing
e.  The outcome, if any, of the viewing
f.   The date and time the images were returned.

5.     Access to the recorded images is to be restricted to the Estate Manager, who will decide whether to allow access to third parties.

6.     Viewing of recorded images is to take place in a restricted area.

Access to and disclosure of images to third parties

1.     Disclosure of the recorded images to third parties is limited to the following:
a.  Law enforcement agencies where the images recorded would assist in a specific criminal enquiry
b.  Prosecution agencies
c.  Relevant legal representatives
d.  The media, where it is decided by a Law enforcement agency that the public’s assistance is needed.
e.  People whose images have been recorded and retained (unless disclosure to the individual would prejudice criminal enquiries or criminal proceedings)

2.     All requests for access or disclosure are to be recorded, and if allowed the following is to be recorded:
a.  The date and time at which access was allowed or disclosure made
b.  The identification of any third party to whom access was allowed or disclosure made.
c.  The reason for allowing access or disclosure
d.  The extent of the information to which access was allowed or which was disclosed.

Access by data subjects

1.     Data subjects will be provided with a standard subject access request form which indicates the information required in order to locate the images requested:
a.  Dates and times of when they visited the premises of the user of the equipment.
b.  If the individual making the request is unknown to the Estate Manager, a photograph of the individual may be requested in order to locate the correct image.
c.  The fee of �10.00 that will be charged for carrying out the search for the images requested. 
d.  Whether the individual would be satisfied with merely viewing the images recorded.
e.  Indicates that the response will be provided promptly and in any event within 40 days of receiving the required fee and information.
f.   Explains the rights provided by the l998 Act.

2.     Individuals should also be provided with a leaflet which describes the types of images which are recorded and retained, the purposes for which those images are recorded and retained, and information about the disclosure policy in relation to those images.