The Trustee Board is responsible for this policy.
Last updated 3rd March, 2026.
CCTV Policy (v1.0)
1. Introduction
1st Bournville Scout Group uses closed-circuit television (CCTV) to provide a safe and secure environment for volunteers, members and visitors, and to protect group property from unlawful damage and unauthorised access.
This policy sets out the use and management of CCTV equipment and images in compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Information Commissioner’s Office CCTV Code of Practice.
2. Data Controller
1st Bournville Scout Group (100th Birmingham) is the data controller for personal data processed through the CCTV system. The Trustee Board is responsible for determining the purposes and means of processing personal data captured by CCTV.
3. Lawful Basis for Processing
The lawful basis for processing personal data through the CCTV system is legitimate interests under Article 6(1)(f) of UK GDPR. Specifically:
- Protection of volunteers, members, visitors and property;
- Prevention and detection of crime and anti-social behaviour;
- Safeguarding of young people; and
- Ensuring compliance with health and safety obligations.
The charity will conduct a Legitimate Interests Assessment (LIA) / Data Protection Impact Assessment (DIPA) to ensure that the use of CCTV is necessary, proportionate, and does not override the rights and freedoms of individuals.
4. System Purpose
The purposes of using CCTV include:
- Assisting in the prevention and detection of crime or equivalent malpractice;
- Assisting in the identification and prosecution of offenders;
- Monitoring the security of the group’s premises, including outside of normal sessions and when the premises are unoccupied;
- Ensuring the safety of volunteers, members and visitors;
- Ensuring health and safety rules and procedures are being complied with; and
- Assisting with the identification of unauthorised actions or unsafe practices that might result in disciplinary or legal proceedings, and providing relevant evidence.
5. Camera Locations
Cameras are located at strategic points throughout the site where there is a legitimate reason to maintain the purposes defined above. Cameras are positioned to ensure maximum premises coverage and to capture clear images.
The group has positioned cameras to only cover communal or public areas on the charity’s premises. All cameras are clearly visible. No camera focuses on toilets, shower facilities or changing rooms.
Appropriate signs are prominently displayed so that volunteers, members and visitors are aware they are entering an area covered by CCTV, with appropriate contact information provided.
Changes to the system, such as viewing angles, must be approved by the system’s operators and recorded in the CCTV log. Any new image recording equipment must be approved by the Trustee Board.
6. Recording and Retention of Images
Images and audio produced by the CCTV equipment are intended to be as clear as possible to be effective for the purposes set out above. The cameras provide images of suitable quality for their specified purposes and are checked regularly to ensure images remain fit for purpose and that the date and time stamp recorded on the images is accurate. Audio is not recorded on internal cameras.
Images may be recorded continuously (24 hours a day, throughout the year).
CCTV images held on the hard drive are overwritten on a recycling basis and are not held for more than 30 days. This retention period balances operational needs with data protection principles.
Once the hard drive has reached the end of its use, it will be securely erased prior to disposal.
Images shared with law enforcement or retained for evidential purposes will be retained only as long as necessary for the specific purpose, in line with that organisation’s retention policy or until any legal proceedings have concluded.
All recorded images are stored in a secure location with restricted physical access. Footage is only accessible via secure personalised account logins and should only be viewed in secure areas where unauthorised persons cannot see the footage.
7. Access to and Disclosure of Images
Access to and disclosure of images recorded on CCTV is restricted to ensure that the rights of individuals are protected.
Access is restricted to the operators of the CCTV system and line managers who are authorised to view them in accordance with the purposes of the system. Access to CCTV footage will be limited to what is necessary for the specific purpose being addressed and will be proportionate to the nature of the concern.
CCTV must not be used to remotely watch the premises while people are present, and CCTV footage may only be accessed where necessary in response to a specific incident or concern.
CCTV operators must hold a full appointment within The Scout Association and have completed all required safeguarding and background checks. Operators will be authorised jointly by the Group Lead Volunteer and Chair of Trustees. The number of operators will be strictly limited, with no single individual acting as the sole authorised operator at any time.
Disclosure of images to other third parties will only be made in accordance with the purposes for which the system is used and will be limited to:
- The police and other law enforcement agencies, where images could assist in the prevention or detection of crime, identification and prosecution of an offender, or the identification of a victim or witness;
- Prosecution agencies, such as Crown Prosecution Service;
- Relevant legal representatives;
- Line managers involved with disciplinary processes; or
- Individuals whose images have been recorded and retained (unless disclosure would prejudice the prevention or detection of crime or the apprehension or prosecution of offenders).
The disclosure of images to external third parties, including law enforcement agencies, requires written authorisation from two trustees. To ensure appropriate oversight, at least one of the authorising trustees should be either the Group Lead Volunteer or the Chair of Trustees.
All requests for disclosure and access to images will be documented, including:
- Date of the request;
- Date of the disclosure;
- To whom the images have been provided;
- The reasons they are required; and
- Whether the request was granted or denied, and reasons.
Subject Access Requests
Individuals have the right to request access to CCTV footage that shows them. Requests must be made via a Subject Access Request to our Data Lead, contactable at chair@1stbournville.org.uk.
To help us locate the relevant footage, please provide:
- The date and approximate time when you were on the premises;
- The specific location/camera area;
- A description of yourself to help identify you in the footage; and
- Proof of identity (e.g., photographic ID).
For requests to be successful, they should be received as soon as possible, as footage may be overwritten after 30 days. Where requests have been received in a timely manner, the footage containing the data shall be retained until the request has been actioned. Requests will be processed within one month from receipt of a valid request, in accordance with UK GDPR requirements.
Where footage contains images of other individuals, we may need to redact or obscure these individuals to protect their privacy rights before disclosing footage to you.
8. Individual Rights
Under UK GDPR, individuals have certain rights regarding their personal data:
- Right of access – to request copies of CCTV footage showing you (via Subject Access Request);
- Right to object – to object to processing based on legitimate interests. However, this must be balanced against the group’s legitimate need for security and safety. Any objection will be considered on a case-by-case basis; or
- Right to complain – to lodge a complaint with the Information Commissioner’s Office if you believe your data protection rights have been breached.
For more information about how the group processes personal data, please see our Privacy Notice available on our website or on request.
9. Implementation and Review
The Trustee Board is responsible for the implementation of and compliance with this policy and the operation of the CCTV system.
This policy will be reviewed annually or sooner if there are changes to relevant legislation, the CCTV system, the purposes for which CCTV is used or best practice guidance.
10. ICO Registration
The group has registered with the Information Commissioner’s Office as a data controller; our registration number is ZC083622.
Contact Information
Data Lead / Chair of Trustees
Email: chair@1stbournville.org.uk
Information Commissioner’s Office
Website: www.ico.org.uk
Helpline: 0303 123 1113