How to review your CCTV policy

If you're reviewing your school's CCTV policy, know key points to look out for as well as questions you could ask to challenge the policy. See our model policy, as well as examples from other schools, for further guidance.

Last reviewed on 19 July 2022See updates
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Contents
  1. Key facts
  2. No requirement to have a CCTV policy
  3. Consider these key points 
  4. Ask these 3 key questions to challenge the policy
  5. Model policy
  6. Examples from primary schools
  7. Examples from secondary schools
  8. Example from a special school

Key facts

  • This policy is non-statutory
  • You can delegate the approval of this policy to an individual or committee
  • The board determines the review cycle
  • The headteacher and senior leadership team (SLT) will write and be responsible for the implementation of this policy

No requirement to have a CCTV policy

There's no legislation that says you need this policy, although you may choose to have 1 to set out how you'll use any CCTV cameras in school.

Under the UK GDPR, you will need to include details of any CCTV usage in your privacy notices where relevant, but these are the only documents it must be mentioned in.

Consider these key points 

Below we suggest what could be included in a CCTV policy but, since it’s non-statutory, there's room for variation.

It’s not meant as a guide for writing a policy, since that’s your school leaders’ job, but use it to give you a sense of what to look out for when reviewing it.

Aims and objectives

For example:

  • The purpose of the CCTV system, such as to: 
    • Make members of the school community feel safe
    • Deter criminality in the school
    • Assist police to deter and detect crime
  • What the CCTV system will not be used for, such as to:
    • Encroach on an individual's right to privacy
    • Monitor people in spaces where they have a heightened expectation of privacy (including toilets and changing rooms)
    • Follow particular individuals, unless there is an ongoing emergency incident occurring
  • If the CCTV system complies with the Data Protection Act 2018 and UK GDPR
  • What would happen if the police request that CCTV footage be released to the media
  • That it should be of good enough quality to be of use to the police or the court in identifying suspects

Covert surveillance and camera location

An explanation of when covert surveillance will be used, a list of where cameras are located, and that appropriate signage is in place.

Roles and responsibilities

Who will do what under the policy, such as:

  • Governing board – make sure the school complies with relevant legislation and that the CCTV system is used within the parameters of the policy
  • Headteacher – make sure the policy is implemented and adhered to 
  • Other staff – main duties of staff members with specific responsibility for data protection and system management

Storage of and access to CCTV footage

An explanation of:

  • How long footage will be retained for, and what will happen to the footage afterwards
  • When footage might be stored for longer 
  • Who will have access to CCTV footage, and how
  • How access to the footage will be logged
  • How subject access requests (SARs) will be handled
  • What will happen if a third party needs to access the footage

Monitoring arrangements

A description of how:

  • School staff (such as the data protection officer (DPO)) will monitor the CCTV system, and carry out checks and assessments (such as a data protection impact assessment) where necessary
  • The governing board will monitor compliance with any statutory requirements and any other relevant guidance

Ask these 3 key questions to challenge the policy

1. How will you manage potential questions and complaints surrounding this policy?

School leaders should be able to explain how they'll implement the policy in a way that all stakeholders (staff, pupils and parents) can understand.

They should acknowledge any questions or concerns they anticipate, how they'll mitigate those, and how they'll follow your school's complaints procedures as necessary.

2. What's changed in this most recent update, and why? 

Your policy should be based on key bits of legislation and guidance:

If there have been updates to any of these documents, you’ll need to check that your school leaders have made sure the policy reflects the latest version.

Your senior leaders might also have updated the policy in response to any incidents you've had in the school, or new best practice guidance school leaders have learned through their professional development activities.

3. How will we know this policy is working and that it's being properly implemented?

School leaders should be able to explain:

  • Key objectives of the policy and how they'll measure success
  • How implementation will be monitored and reported

For more questions you can ask when reviewing policies, see this article.

Model policy

This model document is not meant as a guide for writing or updating your school's policy, since that's your school leaders' job. Instead, use it to give you a sense of what a good policy looks like. 

Our model is:

  • Designed for your school leaders to adapt to suit your school's context
  • In line with relevant requirements and good practice
  • Approved by Forbes Solicitors

Model Policy: CCTV

Examples from primary schools

Maintained school in Barking and Dagenham

Hunters Hall Primary School has a CCTV policy with sections on:

  • Location of cameras
  • Storage and retention of CCTV images
  • Access to CCTV images
  • Responsibilities of the headteacher
  • CCTV signage

Academy on the Isle of Wight

Lanesend Primary School has a CCTV policy (look under the heading 'Money Group') which covers:

  • A statement of intent
  • Monitoring procedures
  • Access to and disclosure of images
  • Procedures in case of any breaches of the code

Examples from secondary schools

Academy in Wigan

Fred Longworth High School has a CCTV policy that includes sections on:

  • Operation of the system
  • System functionality and access
  • Monitoring procedures
  • Video CD/DVD procedures

Academy in Wokingham

The Holt School has a CCTV policy that covers:

  • Roles and responsibilities for the data protection officer and other staff
  • Protocols for using CCTV
  • Security of the system
  • Access to CCTV images

Example from a special school

Stony Dean School in Buckinghamshire has a CCTV policy that covers:

  • Siting the cameras
  • Covert monitoring
  • Storage and retention of CCTV images
  • Complaints

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