Use this checklist alongside the NEU’s CCTV model policy to negotiate a policy acceptable to the union.
You may not be able to secure everything on this checklist – if that is the case, you may wish to consult members on whether the proposed policy is sufficiently positive to be acceptable.
- Is there a clear explanation of why the policy is needed?
- Does it set out the aims of the policy?
- Does the policy state to whom it applies and what it covers?
- Is there a clear statement that CCTV monitoring will never be used to observe or monitor a member of staff’s performance?
Location of cameras
- Is it clear where cameras will be situated?
- Does it state that CCTV will not be used in classrooms?
Access to CCTV images
- Does the policy state who will have access to the recorded images?
- Who will administer the system?
Subject access requests (SARS)
- Is it clear that individuals will be able to make a request for the CCTV footage relating to themselves under the Data Protection Act and the GDPR?
- Does it set out how and to whom a request for access should be made?
Access and disclosure of images to third parties
- Is it clear that third party disclosure will only be allowed for authorised personnel such as the police or if a Court Order is received?
- Who will have overall responsibility?
- Are employee and management responsibilities clearly defined?
Data protection impact assessments and privacy
- Will the school conduct a Data Protection Impact Assessment when installing or moving CCTV concerns to consider privacy issues?
- Who is responsible for monitoring and reviewing the policy?
- How often will it be reviewed?
- Will recognised trade unions be consulted?