CCTV Policy

1. Introduction

1.1 This policy explains the purpose, use, and management of the CCTV installations and Body Worn Cameras (BWC) at the University of Westminster.

1.2 The purposes of the CCTV installations and BWC are:

  • the protection of colleagues, contractors, students, visitors, and the assets of the University
  • the prevention, investigation and detection of crime and disciplinary offences in accordance with the University disciplinary procedures
  • the apprehension and prosecution of offenders (including the use of images/data as evidence in criminal/civil proceedings)
  • the monitoring of the security of the premises

1.3 The principles of the policy are:

  • that individuals' rights are respected and protected
  • that the installations and BWC are operated fairly and within the law
  • that the CCTV system and BWC are operated for the purposes for which they were set up
  • that the recorded material/data stored is fairly and lawfully processed
  • that recorded material/data is adequate, relevant and not excessive for the purposes
  • that recorded material/data is accurate, securely stored, and not kept for longer than is necessary

1.4 This policy and its operations will be subject to regular reviews, no less than every five years.

1.5 This policy is supported by the CCTV and BWC Operational procedures.

1.6 This policy excludes the use of video and audio streaming devices, including mobile devices, laptops etc used for the purposes of teaching, learning, communication etc.

2. CCTV system and BWC overview and definitions

2.1 The CCTV system includes approximately 500 cameras over 11 buildings. The systems will be operated 24 hours per day, 365 days per year.

2.2 The CCTV installations comprise all fixed cameras, printer monitors, signs, recording and playing equipment, information, material, data, and any ancillary equipment required for the operation of the installations (e.g. cabling, printers, power supplies).

2.3 The BWC equipment comprises of portable recording devices which can record both visual images and audio.  These will be worn by any member of the contracted Security company working (CIS at the time of writing) on behalf of the University of Westminster (and may exceptionally be worn by other colleagues or contractors should the University require this), attached via a holder.  Also included in this definition is the replaying equipment, information, material and data and any ancillary equipment required for their operation.    

2.4 Recorded material/data means any material recorded by the CCTV installations or BWC equipment, either in digital or analogue form on video cassette tape, PC computer system tape, hard copy print, or any document copy. The recorded material/data are the property of the University of Westminster.

2.5 The CCTV systems will be maintained on behalf of the University by the University’s contracted maintenance provider (CBRE at the time of writing) and their sub contracted partners to ensure compliance with the Data Protection Act 2018.

2.6 The University’s security (manned guarding) contractor, (CIS Security at the time of writing), has authority to operate the CCTV equipment and will ensure compliance with this policy and the Data Protection Act 2018.

2.7 The security contractor (CIS Security at the time of writing), has authority to operate and maintain the BWC equipment and will ensure compliance with this policy and the Data Protection Act 2018.

3. CCTV and BWC owners

3.1 The CCTV system and BWC are owned by the University of Westminster.

3.2 The Director of Estates Planning and Services is the responsible person for the management and operation of the system, with nominated individuals given authority to manage the day-to-day operations and ensure strict compliance with this policy.

3.3 The University’s Information Compliance team have ensured this policy complies with the Data Protection Act 2018. For any Data Protection queries please email: [email protected].

4. Data Protection Act 2018

4.1 The University's CCTV installations and BWC equipment and data will be registered under the Data Protection Act 2018 and all release of information will be in accordance with the registration.

4.2 An exemption to the provisions of the Data Protection Act 2018 covers the disclosure of information for the purposes of:

  • Preventing or detecting crime
  • Apprehending or prosecuting offenders
  • Assessing or collecting any tax or duty

This exemption applies only where non-disclosure would be likely to prejudice one of these purposes.

4.3 For the purpose of the Data Protection Act 2018 the University of Westminster is the data controller.

5. Access to images

5.1 The ability to review recorded and live images is limited to authorised personnel only, namely:

  • Security Contract Manager and the appointed Security Supervisor
  • Campus Services Manager
  • Estate Services Manager (Soft FM services)
  • Estate Services Team Leader
  • Residential Manager and the appointed Deputy Manager (for Halls of Residence related footage only)

5.2 Any of the above named individuals who review footage are required to record this viewing in a centrally accessible log.  This log will be retained for three years. 

5.3 The ability to remove recorded footage on to an appropriate device is limited to authorised personnel only, namely:

  • Security Contract Manager and the appointed Security Supervisor
  • Campus Services Manager
  • Estates Services Manager (Soft FM services)

5.4     Any removal of footage by the above-named individuals are required to record this removal in a centrally accessible log.  This log will be retained for three years.

6. Applications to have CCTV/BWC footage reviewed/copied

6.1 University colleagues, students and other individuals using the University premises (e.g. visitors, contractors etc) may apply to have copies of their personal data held in CCTV and BWC footage.

6.2 The request must be made in writing as per instructions in Appendix A and detail:

  • The date, time and location
  • The reason for the request (which must comply with the purposes as laid out in 1.1 of this policy)

6.3 All requests should be made as soon as practically possible to ensure footage is not erased in line with the retention schedule (see item 7.3).  If these images have been retained a copy will be made available.

7. Recording usage, retention and disposal

7.1 Recordings are to be held securely on the University network and can only be accessed by named individuals. 

7.2 Recordings from BWC devices will be downloaded from the portable device at the end of each shift.  No recordings are left on any BWC device after they are downloaded.

7.3 Unless required for evidential purposes or the investigation of a crime or otherwise required by law, recorded images will be retained for no longer than 30 days from the date of recording.

7.4 At the end of their useful life all footage held on separate devices for evidential purposes will be erased and securely disposed of.

8. Installation of CCTV and BWC cameras

8.1 CCTV systems and BWC will not be installed or operated on University property other than for the purposes detailed in Section One of this policy.

8.2 The location of CCTV cameras will be determined by the Estates Planning & Services department, with professional advice sought as appropriate.  In addition, periodic security specialist audits will be carried out to determine appropriate coverage. 

8.3 No CCTV cameras are allowed to be installed without agreement with the Estates Planning and Services department.  Should a University colleague, department etc believe they require additional CCTV coverage they should complete the Request for Additional CCTV form located at the end of this policy (Appendix C).   

8.4 No BWC should be used without agreement with the Estates Planning and Services department.  Should a University colleague or department believe they require the use of BWC the should complete the Request for Additional CCTV/ use of BWC form located at the end of this policy (Appendix C).

8.5 Each area of the University building/premises monitored by CCTV systems or BWC will be identified by a sign/notice in the approved format.  

8.6 Further information can be found in the CCTV and BWC operational procedures document.

9. Complaints procedure and enquiry service

1.1 For any complaints regarding CCTV and BWC the usual complaints procedure applies. Complaints by students should go through the standard student complaint procedure whilst colleague or visitor complaints should follow the information in Appendix B.

1.2 For general enquiries in relation to CCTV, BWC and this policy please email the appropriate campus team:

10. Relevant documents

Requesting to review/copy CCTV or BWC footage (Appendix A)

  • Complaint procedure (Appendix B)
  • Request for additional CCTV cameras and use of BWC (Appendix C)
  • CCTV and BWC Operational procedures (Appendix D)

Appendix A – Request to review/copy CCTV and BWC footage

A request to review/copy CCTV and BWC footage can be made by:

  • Individuals whose images have been captured
  • Police in response to an incident e.g. to assist in a specific criminal enquiry, identify a victim, witness or perpetrator in relation to a criminal incident
  • An official enforcement authority (other than the police), eg the Health and Safety Executive, the Environment Agency etc.
  • In relation to an official internal investigation e.g. an incident involving University students or colleagues which may breach the University’s disciplinary policies and/or the law.

To request CCTV or BWC footage is reviewed you must advise the following:

  • Name
  • Student/Colleague ID number
  • Email address
  • Date of footage to be reviewed
  • Time of footage to be reviewed
  • Location of footage to be reviewed
  • Reason for the request

This information must be sent to the site where the incident took place:

Where the police or other law enforcement agencies require a copy of CCTV or BWC footage, a request should be made under Schedule 2 of the Data Protection Act 2018 to the Campus Services Manager for that site, copying in . 

An individual who requires a copy of CCTV or BWC footage of their own recorded image may request this under a Subject Access Request under the Data Protection Act 2018.  Please email: [email protected] with your request.

Appendix B – Complaints process

Students wishing to raise a formal complaint should refer to the student complaints page for guidance on the student complaints procedure. 

Colleague or visitor complaints relating to CCTV and/or BWC should be sent to

Appendix C – Request for additional CCTV installations and use of BWC

The following information is required:

  • Name of requestor
  • School/Department
  • Date of request
  • Area identified for additional camera(s)
  • Reason(s) for additional camera(s)

This information must be sent to the site where additional cameras are required:

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