The Treehouse Café Security Camera Policy. 

• The Treehouse Café uses security camera recordings for the prevention, identification and reduction of crime and to monitor the cafe in order to provide a safe and secure environment for staff, volunteers and visitors, and to prevent the loss or damage to café property. 
• Camera surveillance at The Treehouse is intended for the purposes of: 

•  protecting the cafe and café property, during opening hours; 

•  promoting the health and safety of staff, volunteers and visitors; 

• preventing bullying; 

• reducing the incidence of crime and anti-social behaviour (including theft and vandalism); 

• supporting the Police in a bid to deter and detect crime; and 

• assisting in identifying, apprehending and prosecuting offenders 

• The system comprises of 2 freestanding, movable cameras. 
• The security cameras are owned and operated by The Treehouse Cafe under the decision of the management. 
• The cameras can be monitored remotely via a mobile phone application. This is only accessible by Treehouse directors – Lorna Becker and Rachel Forsyth. 
• The Treehouse’s camera system is registered with the Information Commissioner under the terms of the Data Protection Act. This policy outlines the school’s use of CCTV and how it complies with the Act. 
• All authorised operators and employees with access to images are aware of the procedures that need to be followed when accessing the recorded images. All operators are trained in their responsibilities under the CCTV Code of Practice. All employees are aware of the restrictions in relation to access to, and disclosure of, recorded images. 
• The Treehouse complies with Information Commissioner’s Office (ICO) CCTV Code of Practice to ensure it is used responsibly and safeguards both trust and confidence in its continued use. 
• The use of the camera system will be conducted in a professional, ethical and legal manner and any diversion of the use of camera security technologies for other purposes is prohibited by this policy e.g. the cameras will not be used for monitoring employee performance. 
• Camera monitoring of public areas for security purposes will be conducted in a manner consistent with all existing policies adopted by the school, including Equality & Diversity Policy, Dignity at Work Policy, Codes of Practice for dealing with complaints of Bullying & Harassment and Sexual Harassment and other relevant policies, including the provisions set down in equality and other educational and related legislation. 

Justification for Use of security cameras. 

• The use of cameras to monitor both entrances to the café, community fridge area and serving area for security purposes has been deemed to be justified by the directors – Lorna Becker and Rachel Forsyth. The system is intended to capture images of intruders or of individuals damaging property or removing goods without authorisation or of anti- social/intimidating/threatening behaviour. 
• Cameras will not be used to monitor The Treehouse lounge area or café back room seating area. 
• The installation of security cameras is proportionate in addressing such issues that have arisen prior to the installation of the system. 

Data Protection Impact Assessments 

• Where new CCTV systems or cameras are to be installed, The Treehouse will carry out a full Data Protection Impact Assessment identifying risks related to the installation and ensuring full compliance with data protection legislation. This may involve the need for consultation with staff, volunteers  and local authorities. 
• Any future updates of or additions to the cameras will be assessed using the Data Protection Assessment Procedures. 
• Location of Cameras 
• Cameras will be sited so they only capture recordings relevant to the purposes for which they are installed and care will be taken to ensure that reasonable privacy expectations are not violated. 
• The Treehouse will ensure that the location of equipment is carefully considered to ensure that images captured comply with the Data Protection Act. The Treehouse will make every effort to position cameras so that their coverage is restricted to the areas deemed necessary. 

Covert Surveillance 

• The Treehouse will not engage in covert surveillance. 

Notification 

• A copy of this Camera Policy will be provided on request to staff, volunteers and visitors to the The Treehouse and will be made available on the website. 
• The location of cameras will also be indicated and adequate signage will be placed at each location in which a camera(s) is sited to indicate that recording is in operation. 
• Adequate signage will also be prominently displayed at the entrance to The Treehouse. 
• Appropriate locations for signage will include: - Front and back entrance doors. 

Storage and Retention 

• The images captured by the camera system will be retained for a maximum of 42 days, except where the recording identifies an issue and is retained specifically in the context of an investigation/prosecution of that issue. 
• Access will be restricted to authorised personnel. Supervising the access and maintenance of the Camera System is the responsibility of the directors. 

• In certain circumstances, the recordings may also be viewed by other individuals in order to achieve the objectives set out above. When camera recordings are being viewed, access will be limited to authorised individuals on a need-to-know basis. 
• Files are stored on a cloud based system with security access. 

Access 

• Access to the camera system and stored recordings will be restricted to authorised personnel only. 
• A record of the date of any disclosure request along with details of who the information has been provided to (the name of the person and the organisation they represent), why they required it and how the request was dealt with will be made and kept, in case of challenge. 
• Data will be provided to those requests authorised in a permanent format where possible. If this is not possible the data subject will be offered the opportunity to view the footage. 
• In relevant circumstances, camera footage may be accessed: 
• By the police where The Treehouse are required by law to make a report regarding the commission of a suspected crime; or 
• Following a request by the police when a crime or suspected crime has taken place and/or when it is suspected that illegal/anti-social behaviour is taking place on The Treehouse’s property, or 
• To individuals (or their legal representatives) subject to a court order. 
• To The Treehouse insurance company where the insurance company requires same in order to pursue a claim for damage done to the insured property. 

 Subject Access Requests (SAR) 

• Individuals have the right to request access to camera footage relating to themselves under the Data Protection Act. 
• Individuals submitting requests for access will be asked to provide sufficient information to enable the footage relating to them to be identified. For example, date, time and location. 
• The Treehouse will respond to requests within 30 calendar days of receiving the request in line with The Treehouse’s right of access policy. 
• The Treehouse reserves the right to refuse access to camera footage where this would prejudice the legal rights of other individuals or jeopardise an on-going investigation. 
• A record of the date of the disclosure along with details of who the information has been provided to (the name of the person and the organisation they represent) and why they required it will be made. 
• Where footage contains images relating to 3rd parties, The Treehouse will take appropriate steps to mask and protect the identities of those individuals. 

Complaints 

• Complaints and enquiries about the operation of security cameras within The Treehouse should be directed to the directors in the first instance. 

 Staff Training 

• Staff authorised to access the camera system will be trained to comply with this policy. Staff will understand that all information relating to the camera recordings must be handled securely. 
• Staff will receive appropriate training to enable them to identify and handle different requests according to regulations. 
• Staff misuse of surveillance system information will lead to disciplinary proceedings. 

 Responsibilities 

• The directors will: 
• Ensure that the use of camera systems is implemented in accordance with the policy set down by The Treehouse 
• Oversee and co-ordinate the use of camera monitoring for safety and security purposes within The Treehouse 
• Ensure that all existing and future camera systems will be evaluated for compliance with this policy 
• Ensure that the camera monitoring at The Treehouse is consistent with the highest 

standards and protections 

• Review camera locations and be responsible for the release of any information or recorded camera  materials stored in compliance with this policy 
•  Ensure that the perimeter of view from fixed location cameras conforms to this policy both 

internally and externally 

• Give consideration to both staff and volunteer feedback/complaints regarding possible invasion of 

privacy or confidentiality due to the location of a particular camera 

•  Ensure that all areas being monitored are not in breach of an enhanced expectation of the privacy 

of individuals within The Treehouse and be mindful that no such infringement is likely to take place 

• Ensure that images recorded on digital recordings are stored for a period not longer 

than 28 days and are then erased unless required as part of a criminal investigation or court 

proceedings (criminal or civil). 

• Ensure that camera control is solely to monitor suspicious behaviour, criminal damage etc. and 

not to monitor individual characteristics 

• Ensure that camera control is not infringing an individual’s reasonable expectation of privacy in public areas.