Community Safety officers play a vital role in ensuring the safety and wellbeing of all staff, students and visitors on the University of Warwick campus. To ensure the safety of everyone, including our officers, they are equipped with personal-issue body worn video (BWV) cameras.
BWV is currently used as a means of capturing key evidence in such a way that it can bring a compelling and an accurate account of the circumstances at that time. This does not replace the needs to use other types of evidence but does go a considerable way in reducing any ambiguities and should be considered as an additional evidential aid.
The equipment is worn by uniformed Community Safety staff and the use is primarily driven by the incidents and circumstances presented to them, or in anticipation of responding to a reported and unfolding incident.
The cameras are always worn overtly by uniformed staff during deployment.
This equipment has been introduced in many universities and local authorities to deter and detect crime and anti-social behaviour. The cameras will not ordinarily be switched on and will only be activated when the officer responding to an incident deems it necessary, and any activation will be announced. The cameras have a “pre-record” function, so that when activated, the camera will record the incident, and preserve 30 seconds of video and audio prior to activation. All data is encrypted on the camera and retained for 31 days (unless required to respond to a subject access request or for evidential purposes).
The use of these cameras is in accordance with the University’s CCTV Policy, legislation, the Information Commissioner’s PIA Codes of Practice, the Surveillance Camera Commissioner’s Principles and best practice.
Access to recordings is limited to authorised members of staff.
What steps have the Community Safety team taken in consideration of the impact on the privacy of the public by using these cameras?
A privacy impact assessment was undertaken to consider the impact upon individuals and their privacy, and to consider measures which could be put in place to mitigate any effect on individuals and their privacy. A copy of the assessment can be viewed here: BWV DPIA
The public’s concerns regarding privacy issues are recognised. Accordingly, this technology is only ever deployed in an overt manner, using trained, uniformed staff, and in defined operational circumstances.
All captured data is processed to ensure compliance with Regulation 2016/6791 (GDPR), the UK Data Protection Act 2018 and the Human Rights Act 1998, the Information Commissioner’s Code of Practice and the Surveillance Camera Commissioner’s guidance.
The Community Safety team has implemented a policy and procedure which endeavour to mitigate any privacy issues and to ensure officer's compliance with the Information Commissioner’s Office (ICO) “Data Protection Code of Practice for surveillance cameras and personal information”. A copy of the ICO code can be found here and a copy of the Community Safety team use of body worn video policy can be found here: BWV Policy
When and where will the cameras be used?
Community Safety officers will only activate the BWV camera when they believe there is a justifiable need to. When capturing information on these devices, staff only do so to fulfil a lawful purpose. The legitimate purpose behind the use of this equipment is to gather evidence at the scene of an incident so that an accurate record of events can be made available to investigators, to prevent and detect crime, and to prevent public disorder.
There is a ‘pre-record’ function on the cameras which means that when Community Safety officers are carrying out their duties, the cameras will be continually background recording on a ‘loop’, for 30 seconds at a time. This footage is then recorded-over by a new 30 second recording, and this process continues throughout the day.
The most recent 30 seconds of ‘pre-record’ footage is only retained on the device if the officer activates the record slider on the device. Then the camera captures and retains that preceding 30 seconds of footage with the recording of the incident.
Unless the record button gets activated, the 30 seconds of pre-record footage is automatically deleted when the camera is turned off.
This ‘pre-record’ feature helps to establish/clarify what has led to the record function being activated.
The devices record both audio and visual data. This is to provide a reliable record of what was said in an incident as it may be used as evidence in an internal or external investigation.
How will I know when recording is taking place?
The cameras are worn overtly on the outside of the officer’s uniform, normally on a chest mounted clip and the visual display on the camera will clearly show when recording is taking place. When the record button is first activated, the camera also emits a loud beeping sound.
Officers should also advise, where possible, that they have commenced recording when they first activate the device.
How will this recorded data be kept secure?
All recordings will be securely held in accordance with agreed data protection procedures. The cameras will encrypt all recordings so that there can be no unauthorised access to any data recorded. Access to recordings will be restricted only to authorised personnel.
How long will these recordings be retained?
Recordings would be deleted after 31 days unless retention is required as part of a subject access request (SAR), or an internal or police investigation, in which case the recording will be retained securely until the investigation or SAR is completed.
Who can access these recordings?
Authorised and trained members of the Community Safety team can access the recordings. If the footage is deemed evidential for a criminal or disciplinary matter, the footage can be shared internally.
Statutory prosecution agencies, such as the police, will be able to view the recordings for law enforcement purposes, and recorded data may be released to them, on receipt of an appropriately signed Request for Information form that will be managed through the Information Data Compliance team, for evidential purposes, for example to support a prosecution.
Data subjects (the person who has been recorded) can request to view the footage. Requests must be made via a subject access request. Click here for details of how to make a subject access request.