Trinity Hall’s policies include Accessibility, Equal Opportunities and Freedom of Speech.
Trinity Hall is committed to making accessible information and resources that are available via the web for all users (also see our Equal Opportunities Policy below). The section of the Quality Assurance Agency (QAA) Code of Practice relating to students with disabilities states that institutions should consider disabled students in every aspect of planning and administration of academic and social activities. The Disability Discrimination Act (1995) and Special Education Needs and Disability Act [SENDA] (2001) – which amended the first act to include education, the latter became law in May 2001 with teaching and learning components falling under legislation in September 2002. SENDA legislates that it is an offence to discriminate against a disabled person by treating him or her less favourably than others for a reason relating to their disability. For the purposes of the legislation a disabled person is defined as someone who has a physical or mental impairment, which has an effect on his or her ability to carry out normal day-to-day activities. The Act covers all aspects of an institution’s student services. ‘Student services’ is given a broad meaning of ‘services of any description which are provided wholly or mainly for students’ and will obviously include educational services such as teaching and learning provision. Discrimination can also occur where an institution fails to make a ‘reasonable adjustment’ where the disabled student is placed at a ‘substantial disadvantage’ in comparison with someone who is not disabled and such failure cannot be ‘justified’.
The University favours the principles of usability and universal design, which will be of benefit to as many users as possible. By following these principles and incorporating techniques to ensure information and resources are accessible with assistive technologies, separate resources for disabled users should not be required.
Where possible web pages are written to conformance level 1 standard (A), and as closely as possible to conformance level 2 (AA) and 3 standard (AAA).
1.1 Trinity Hall (the “College”) has in place and is further developing a CCTV surveillance system, “the system” on the College site. The College site comprises for this purpose all Trinity Hall properties located within the City of Cambridge with the exception of residential properties in Bateman Street. Images can be monitored and are recorded centrally and will be used in strict accordance with this policy. The system is owned by Trinity Hall, Trinity Lane, Cambridge, CB21TJ. The College is registered with the Information Commissioners Office as the Data Controller for personal data processed by the College including audio and visual data from its CCTV system. The purposes for which data is processed by the College are set out in the register entry.
“CCTV” means Closed Circuit Television.
“Data Subject” means an individual who is a subject of personal data.
“System manager” shall mean, for the purposes of this policy, the member of staff with specific responsibility for management and control of the College’s CCTV systems or his/her nominee. Currently this is the Head Porter and Deputy Head Porter.
“System”means the College’s CCTV Surveillance System including CCTV cameras and audio recording devices.
“Data” in this context includes digital video images and audio recordings.
“Personal Data” has the meaning set out in the Data Protection Legislation, and in this context includes, but is not limited to, audio or video footage from which a person can be recognised, and audio or video footage containing information about an identifiable individual.
“Data Controller” has the meaning set out in the Data Protection Legislation, and refers in this context to Trinity Hall. Trinity Hall is registered with the Information Commissioner’s Office as the Data Controller for personal data processed by the College including audio and visual data from its CCTV system.
“Data Protection Legislation” refers to the Data Protection Act 1998, and the General Data Protection Regulation (2016/679) when it comes into force.
2.0 The purpose of the system
2.1 The system has been installed by Trinity Hall with the purpose of reducing the threat of crime generally, protecting Trinity Hall ‘s premises and helping to ensure the safety of all Trinity Hall’s staff, students and visitors consistent with respect for the individuals privacy. These purposes will be achieved by monitoring the system to:
- Deter those having criminal intent
- Assist in the prevention and detection of crime
- Facilitate the identification, apprehension and prosecution of offenders in relation to crime and public order
- Facilitate the identification of any activities/event which might warrant disciplinary proceedings being taken against staff or students and assist in providing evidence to managers and/or to a member of staff or student against whom disciplinary or other action is, or is threatened to be taken.
- The system will also be used for the purpose of health and safety, particularly in the gym, to ensure individuals using this facility on their own are being monitored in case they become injured and need support.
The system will not be used:
- To provide live streaming images for public access.
- To provide images for any marketing purpose.
2.2 Covert recording
a. Covert cameras may be used under the following circumstances on the written authorisation or request of the Head Porter / Junior Bursar and where it has been assessed by the Senior Officers Group and the College Data Protection Officer.
- that informing the individual(s) concerned that recording was taking place would seriously prejudice the objective of making the recording;
- that there is a reasonable cause to suspect that unauthorised or illegal activity is taking place or is about to take place
- that resort to covert recording is, in all the circumstances, proportionate given the impact this may have on the privacy and related interests of individuals.
b. Any such covert processing will only be carried out for a limited and reasonable period of time consistent with the objectives of making the recording to capture evidence of the specific suspected unauthorised activity. The decision to adopt covert recording will be fully documented and will set out how the decision to use covert recording was reached and by whom and whether any steps can be reasonably taken to reduce collateral intrusion
c. Any data collected will be dealt with under the principles set out elsewhere within this policy.
3.0 Operation of the system
3.1 The system is operational and images are capable of being monitored for twenty-four hours a day throughout the whole year. Real time monitoring facilities are available in both porters’ lodges and from the Junior Bursar’s, Head Porter’s and Deputy Head Porter’s offices.
3.2 An emergency audio function will be available in the Central Site and Wychfield Porter’s Lodge. An emergency button can be pushed at the discretion of the porter on duty in the event they feel threatened or consider a current situation requires audio capture as well as visual images.
3.3 The public and College community are made aware of the presence of the system by appropriate signage placed at the entrances to the College.
3.4 To ensure privacy, wherever practicable, the CCTV cameras are prevented from focusing or dwelling on domestic accommodation. CCTV cameras are predominantly positioned facing outwards towards external entrances to College sites except for two locations. Firstly the Pavilion, to ensure anyone training alone is monitored for safety and secondly the entrance to the library to record the security of the College’s books. Any cameras facing into public areas are sited so that the minimum amount of collateral intrusion is caused in order to achieve the stated purposes.
3.5 Data captured by cameras will be recorded on equipment located securely within College buildings. The Head Porter and Deputy Head Porter will have monitoring equipment which will allow them to monitor live images from the cameras, but will also have the facility to search and view stored images. Any transfer of images onto other media will only take place in line with saving the images for achieving one of the purposes of the system outlined above. Transfer of images onto other media will only be carried out by the system manager. Should it be necessary to create a copy of any data onto other media, a College incident report will be created by the system manager detailing: the reasons why the copy was made, the date and time stamps of the recording, the format of the copy and to whom the copy was distributed. The system manager must satisfy themselves that distribution of any data so processed is done so for the purposes described in the ICO data register and to the recipients permitted under the register entry.
3.7 Authorised IT staff will be able to access the system to carry out maintenance and upgrade support functions, and are not permitted to access this system for reasons outside their scope of authority.
3.8 All recording media used for the monitoring and capture of images on the College’s CCTV system belongs to and remains the property of Trinity Hall. Any decision to retain data / recordings over the specified retention period will be fully documented and will set out how the decision to retain information was reached, including for release to a third party (including the Police) under the exemptions contained within sections 28(1), 29(1)(a) and (b) and/or 35(2)(a) of the Data Protection Act 1998.
3.9 Unless required for any of the reasons contained within Section 29(3) of the Data protection Act 1998, recorded images will be retained for no longer than required for the purpose for which they were originally obtained, after that time the images are automatically overwritten by the recording equipment (currently 21 days).
4.0 Access to Recordings by Staff or Third Parties
4.1 It is important that access to and disclosure of images is restricted and carefully controlled, not only to ensure that the rights of individuals are preserved but also to ensure that the chain of evidence remains intact should the images be required for evidential purposes. These aspects of the CCTV Surveillance System Policy reflect the Second and Seventh Data Protection Principles of the Data Protection Act 1998.
In general, viewing of live images will be restricted to the College porters. Any other persons seeking to view recorded images will require the prior authority of the system manager.
4.2 Requests by persons outside the College (other than the Police) for viewing or obtaining recordings will be assessed on a case by case basis by the Head Porter (or his deputy) and access will only be granted where it is consistent with the obligations placed on the College by the Data Protection Act 1998.
All requests for access will be recorded on a College incident report detailing the date and time at which access was allowed/or disclosure made; the reason for the access/disclosure; the extent of the information accessed/disclosed; name of the porter providing access.
If access to images is denied to any member of staff or third party (including the Police), the Head Porter will document the reasons for the denial and the information will be logged at the Control Room.
Access by the Police
4.3 Where a police officer requests access to CCTV images either by viewing such data or requesting a copy of the data, they should supply the College with a DATA access request form. Requests for access to images by the Police will not normally be denied and can be made without the authority of the Head Porter provided they are accompanied by a written request signed by a Police Officer, who must indicate that the images are required for the purposes of a specific crime enquiry.
Access by Data Subjects
4.4 CCTV digital images, if they contain Personal Data, are covered by the Data Protection Legislation. Anyone who believes that they are a subject of Personal Data recorded by the System is entitled to ask for a copy of the data, subject to exemptions contained in the Data Protection Legislation. They do not have the right of instant access.
4.5 A Data Subject who wishes access to their Personal Data should apply in writing to the College Data Protection Officer, the Compliance Officer. Subject Access Requests will be dealt with by the Compliance Officer. Any Fellow or member of staff receiving a Subject Access Request must forward it to the Compliance Officer.
4.6 The Compliance Officer will then arrange for a copy of the data to be made and given to the applicant. The Data Subject should not ask a Fellow, or another member of staff to show them the data, or ask anyone else for a copy of the data. All communications should go through the Trinity Hall Compliance Officer (firstname.lastname@example.org). A response will be provided promptly and in any event within forty days of receiving any permissible fee, currently £10.00.
4.7 Where the College is unable to comply with a subject access request without disclosing information relating to another individual who can be identified from that information, it is not obliged to comply with the request unless that individual has consented to the disclosure or it is reasonable, in the circumstances, to comply without the consent of the individual.
4.8 The Data Protection Legislation gives the Data Controller the right to refuse a request for a copy of the data particularly where such access could prejudice the prevention or detection of crime or the apprehension or prosecution of offenders.
4.9 If it is decided that a data subject access request is to be refused, the reasons will be fully documented and the data subject informed in writing, stating the reasons.
5.1 It is recognised that members of Trinity Hall and others may have concerns or complaints about the operation of the system. Any complaint about the operation of the system should be addressed in the first instant to the Head Porter. Concerns or enquiries relating to the provisions of the Data Protection Act 1998 may be addressed to the Compliance Officer.
6.1 The responsible officer for this policy is the Junior Bursar
6.2 Implementation of this policy will be after consideration and consultation with affected parties and College members.
6.3 This policy and the procedures contained herein will be considered and reviewed by the Junior Bursar, Compliance Officer and the Head Porter to review operational effectiveness.
7.0 Version Control & Change History
|Version Number||Approval Date||Approved By||Amendment|
|1.1||N/A||IT Advisory Group||IT Advisory Review|
|1.2||N/A||Fellow||Data Protection Review|
|1.3||6 June 2016||Fellow||Clarification and Editing|
|1.4||14 March 2017||Governing Body||Minor Amendments by Fellow|
|1.5||17 March 2017||Fellow||Uploaded to Intranet|
For more information please see the following files:
See the University website for the our current Equal Opportunity Policy.