We are obliged to ensure the health, safety and welfare of our employees. It is important that we protect and support our mobile workers while they do their duties away from the office. This includes our Community Safety Wardens (CSWs) and Community Safety Enforcement Officers (CSEOs). Who, through the nature of their work, are at times open to aggressive/abusive encounters.
There are already several policies and procedures in place, which include:
- The Lone Working Policy.
- The use of mobile phones and/or radio communication systems to help manage the risk.
Also, a BWV camera can be worn. This records sound and pictures to help the Officer gather clear evidence. It also adds an extra level of security. The system acts largely as a deterrent and the device does not record unless the Officer turns it on.
Using it helps make our operation more transparent to the public, with evidence available when we look at customer's complaint. Evidence can also be used by Police as proof to prosecute if there are more serious incident of abuse.
Any recordings made should be captured, stored securely and used in line with the:
- General Data Protection Regulation (GDPR);
- and Information Commissioner's Office (ICO) CCTV Code of Practice.
Policy aim
To explain how we use BWV cameras to make sure they comply with the law and codes of practice. This policy and associated procedures will standardise the use of BWV and the evidential product produced.
The intention is for the use of BWV to:
- Raise standards of service.
- Reduce incident escalation.
- Be used in the process of enforcement activities to make sure it is accurate and transparent.
- Reduce complaints.
This policy applies to all our staff that may use BWV and/or the associated software. Staff must use the equipment in line with this policy, associated procedures and organisation strategies. They will get full instructions in its use and the relevant laws.
We will monitor the use of the BWV to make sure it is the right tactic. Also, the use is in line with policy and procedure.
Using BWV
- All camera units are stored in our Communications Facility, which is a secure and restricted access area. All Officers have a personal access card that allocates a bodycam to them. This is until it is returned and disconnected at end of their shift/working day.
- Once allocated, the Officer will take responsibility for the safe keeping of the unit. Before leaving the premises each day they should check the unit is working correctly. Also, make sure they are wearing it at all times whilst on mobile patrols.
- The camera should only be switched on during specific incidents. For Officers, this will be:
- When issuing Fixed Penalty Notice (FPN) ticket;
- during an incident of aggression/abuse;
- or any significant incident/situation that needs to be recorded.
- It is important to make sure BWV is only used during the specified incidents above. It is equally important to be mindful of the impact on our reputation of not recording an incident. If an incident is not recorded, the Officer's rationale must be captured in their pocketbook. They are likely to have to explain this, especially if evidence is required in court.
- The device should clearly show recording is taking place. In an incident with a member of the Public, the Officer should make it quite clear they are recording.
- If recording has started before the public arrive, they should be told straight away that recording is taking place.
- Officers should try to minimise intrusion of privacy on those persons who are present, but not involved. The camera should be focused on the incident and not bystanders.
- Recording must continue uninterrupted from the start until the end of the incident. The Officer should continue recording for a short period after any incident to clearly show the incident has ended.
- The recordings taken will be downloaded at the end of each day and stored securely on a Council approved device. Any transfer to unauthorised storage facilities may result in legal or disciplinary proceedings.
Storing and viewing a recording
- All information recorded will be encrypted so only authorised personnel can view it.
- The recordings will be stored on a secure Council approved device.
- The recordings will only be accessible by authorised personnel. Non-evidential data will be kept for a maximum of 30 days before it is deleted. Those needed as evidence will be kept for (whichever is longer):
- a maximum of 6 months;
- or until the evidence is no longer needed.
- A record or audit trail will be kept. This will detail how any information needed by the Police or as evidence in court has been handled.
- Any evidential data will be deleted once it is no longer needed. A record or audit trail of this process will also be captured.
- The recording will only be viewed by authorised personnel in the following situations. Any viewings will be logged so there is an audit trail:
- An Officer has reported an aggressive/abusive incident which needs to be investigated further or reported to the Police.
- A complaint has been received which needs to be investigated:
- about the way a FPN has been issued;
- or the behaviour of an Officer.
- A member of the public has asked for a copy of the recording made of them. You will be informed by the Data Protection Officer if this is the case.
- Evidence has been requested by the Police or is required as evidence in court.
- Where the footage will assist in the way an issued FPN is dealt with.
- Used as part of debriefs into multi-agency incidents.
- Recorded images will be viewed by the authorised personnel in a private/restricted area (Communications facility).
References
- Data protection and your business (GOV.UK) - Data Protection Act 2018.
- Human Rights Act 1998 (legislation.gov.uk).
- Video surveillance (ICO) - CCTV Code of Practice.
- Surveillance Camera code of Practice (GOV.UK).