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The Australian National University
Facilities and Services Division
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A CODE OF PRACTICE
FOR CLOSED CIRCUIT TELEVISION SYSTEMS

Operated by the ANU Security Unit
Dated: 29 May 2008


TABLE OF CONTENTS

1..... INTRODUCTION
2..... STATEMENT OF PURPOSE
3..... SYSTEM USE
4..... SYSTEM DETAILS
5..... DATA PROTECTION - PRIVACY
6..... MANAGEMENT OF THE SYSTEM
7..... EXTENSION OF THE SCHEME
8..... HALLS OF RESIDENCE AND COLLEGES
9..... ACCOUNTABILITY
10... PUBLIC INFORMATION
11... COOPERATION WITHIN A UNIVERSITY ENVIRONMENT
12... ASSESSMENT OF THE SCHEME AND CODE OF PRACTICE
13... OPERATING STAFF
14... COMPLAINTS
15... BREACHES OF THE CODE INCLUDING THOSE OF SECURITY
16... CONTROL AND OPERATION OF THE CAMERAS
17... ACCESS TO AND SECURITY OF THE MONITORS/CONTROL ROOM
18... TAPES AND RECORDED MATERIAL
19... PHOTOGRAPHS
20... DEALING WITH INCIDENTS
21... POLICE CONTACTS
22... COMPLIANCE AUDIT

NOTES

1. INTRODUCTION

1.1. This document details the Code of Practice that will be applied to the management of the close circuit television system (CCTV) established on the Acton campus of the University by the Facilities and Services Division. The system has been implemented by the University to assist in the protection of staff, students and visitors to the campus as well as providing enhanced security of University assets.

1.2. The CCTV system will be managed in accordance with all relevant external regulations and University policies. The conditions applied to the use of the system, including the storage, disposal and access to images and the storage of information, are detailed within this Code of Practice.

1.3. The Director, Facilities and Services has executive responsibility for the system, including approving any extension of the system within the University. The Director is also responsible for managing adherence with the conditions laid down in the Code of Practice and is the only officer authorised to approve amendments to the conditions of the Code. Any changes or extensions to the Code or System will only take place after consultation with relevant University management. Where specific arrangements are established with an area, a written record of the agreed procedures will be made.

1.4. The Director may authorise an agent to approve minor changes to the system and to this Code, where appropriate. Minor changes are those that do not have a significant impact on the intent of the Code or the procedures established to monitor adherence with its provisions.

1.5. Where appropriate, the Australian Federal Police will be asked to investigate any matter recorded by the CCTV system which is deemed to be of a criminal nature

.

2. STATEMENT OF PURPOSE

2.1. As indicated in the previous section, the CCTV system is intended to provide an increased level of security in the University environment for the benefit of those who study, work, live in, or visit the campus. Subject to this Code of Practice the System will not be used to invade the privacy of any individual. For the purpose of this Code, the University environment includes all University land and buildings, including those areas occupied by Colleges and commercial businesses.

2.2. The system will only be used for the following purposes and within this Code of Practice at all times:

  1. To reduce the fear of crime and to reassure the public;
  2. To prevent, deter and detect crime, criminal damage and public disorder;
  3. To identify, apprehend and prosecute offenders in relation to crime, criminal damage, public disorder, road traffic accidents involving serious injury and all forms of harassment;
  4. To provide the University, the Police and the Government with evidence upon which to take criminal and civil actions in the Courts;
  5. To monitor and assist traffic management issues; and
  6. To assist other Emergency Services.

2.3. There may be circumstances where the Australian Federal Police wish to conduct a pre-planned operation on the University site. The Director or agent may authorise the use of this system to support these operations, provided it is done within the provisions of this Code and a representative of the AFP is present in the Control Room for the full duration of the operation.

2.4. Any use of this system or materials produced which is frivolous, or for private purposes, or is otherwise inconsistent with the objectives and procedures outlined within this Code will be considered gross misconduct. Any University staff member involved in incidents of this type will face appropriate disciplinary action in accordance with the relevant University policies. A 24-hour record is kept of event activity in the Control Room or at the location of the CCTV units.

2.5. As community confidence in the system is essential, all cameras will be operational. An appropriate maintenance program will be established and under no circumstances will "dummy" cameras be used.

3. SYSTEM USE

3.1. The system will be used to respond to the following key objectives, which will be subject to annual assessment and reports:

  1. To detect, prevent or reduce the incidence of property crime and offences against the person;
  2. To reduce the theft of cars and theft from cars both on streets and in car parks;
  3. To improve general security monitoring in the lighted path areas of the campus, both in terms of personal security and security of premises;
  4. To make the Union Court area a more attractive area to shop or work in;
  5. To reduce graffiti (particularly offensive graffiti), vandalism and other criminal damage to improve the environment and reduce costs;
  6. To prevent and respond effectively to all forms of harassment and public disorder;
  7. To improve communications and the operational response of Security patrols in and around the areas of campus where CCTV operates; and
  8. To assist in traffic management.
  9. Provide emergency service assistance

4. SYSTEM DETAILS

4.1. The CCTV System consists of a number of overt colour CCTV cameras situated on University property, which continuously record activities in that area.

4.2. A Control Room is situated on campus and is capable of receiving images from throughout the area. The Control Room is staffed 24-hours a day by qualified Control Operators working in shifts. The Control Room is also equipped with a licensed radio system linking patrol units and the Control Room. Emergency Phones within the viewing area will be monitored and are connected directly to the Control Room.

5. DATA PROTECTION - PRIVACY

5.1. All data collected using this system, including images, will be managed in accordance with the provisions of the Commonwealth Privacy Act 1988 and the relevant University policy relating to the control of private information (The University's privacy policy is located at the following URL: http://www.anu.edu.au/legal/content/privacy).

5.2. All persons involved in the operation of the system are to exercise care to prevent improper disclosure of material.

6. MANAGEMENT OF THE SYSTEM

6.1. The Facilities and Services Division (ANU Security Unit) is responsible for compliance with this Code of Practice and Operational Manual.

6.2. The Division is responsible for managing compliance with this Code, including compliance by staff and contractors employed to work on the system or in the Control Room.

6.3. The Manager, Security and Campus Services, shall be responsible for the day-to-day management of the system and associated processes. In particular, the Manager will be responsible for Police liaison, compliance with the Code of Practice and Operational Manual by staff, contractors or any other authorised person, staff training, the preparation reports and the evaluation of the system performance.

6.4. The Manager will be responsible for managing the Control Room, ensuring that only authorised personnel are given access. A record will be kept of all personnel entering the control room.

7. EXTENSION OF THE SYSTEM

7.1. Where an agreement is reached to extend the System, the parties (that is the Division and any area affected by the extension of the System) agree to take the following actions:

  1. At the outset, they will identify and agree on primary aims and associated issues that must be addressed to achieve those aims.
  2. They will identify and plan for resource implications, including deciding the commitment levels of resourcing that will be provided by each participant (client).
  3. They will agree to the extent of involvement and respective responsibilities of each party.
  4. They will identify any issues that can only be resolved by agreement of all parties participating at that stage of the System (including a decision to change operating priorities to extend the technical capacity of the system).
  5. They will establish protocols to govern the process for decision making both in establishing the system within the area and for the ongoing management of the system.
  6. They will establish operational procedures for the management of the system and, as appropriate, implement protocols for monitoring and auditing of the System, as it affects those areas.
  7. They will draft and sign an agreement outlining the responsibilities of the parties, and in particular, acknowledging the requirement for all parties to comply with the provisions of this Code, including the enforcement of sanctions detailed within the Code.
7.2. Prior to any extension of the System being approved the following actions will be completed:
  1. The Facilities and Services Division will conduct a needs assessment and prioritisation of risk management objectives.
  2. Consultation shall be undertaken between the Division and the local areas (and any other parties affected by the extension).
  3. Where cameras are to be installed externally at the Halls of Residence, the Division will consult with residents. See Section 9 of this Code for details of protocols associated with the extension of the system to internal areas of Colleges and Halls.

8. HALLS OF RESIDENCE AND COLLEGES

8.1. Given the particular needs of residential areas, in addition to the above, the following actions will be taken where the system is extended for use in the internal areas of a Residential college or Hall:

  1. The reason for the extension will be clearly identified
  2. The installation process will involve extensive consultation including attention to the views of the local management and resident groups.
  3. Camera locations and key objectives will be the subject of consultation with resident groups, including defining areas that will be considered private. This will ensure that cameras will not be used in a manner that will provide access to capturing images in a designated private area. (The University is under an obligation to ensure that operational procedures are adopted that impose restraints upon the use of cameras in connection with private residences).
  4. As part of their terms of employment local area staff will attend staff training on privacy issues raised by observation of residential areas and be required to sign an appropriate confidentiality agreement.
  5. Management, supervision and audit of the System will pay particular regard to those aspects of the System, which are intended to address individual privacy.
  6. Targeted observations of individuals will only be undertaken for specified reasons and for purposes and key objectives set out in this Code of Practice. Observations should be conducted in accordance with protocols established with the Police and subject to the Police and Criminal Evidence Act 1984,Criminal Procedures Investigation Act 1996, Privacy Act and Codes of Practice.

8.2. All relevant parties will agree to comply with the requirements of this Code before the adoption of any change in purpose or the adoption of new objectives for the System.

9. ACCOUNTABILITY

9.1. The University acknowledges the importance of accountability in the management of the system. With that in mind, the following steps will be taken to ensure the campus community is informed:

  1. Copies of the Code of Practice will be available to the public via the University web page.
  2. An annual report on the operation of the system will be prepared by the Director, Facilities and Services or agent and published on the University webpage. This report will provide information on any extensions to the system (that is, additional cameras) and changes to the Code of Practice. Where appropriate, the report will provide an analysis of the performance of the system, where that information does not contravene the privacy of individuals or undermine any possible criminal proceedings.

9.2. Any agreement approving Police participation in this System will be subject to both parties signing a document acknowledging their respective responsibilities under this Code. This agreement will be available for review by the University Executive or officers nominated by the University Executive, if required.

10. PUBLIC INFORMATION

10.1. Cameras will not be hidden and as far as possible will be placed in public view.

10.2. Signs that CCTV cameras are operating will be displayed at key positions. The signs will allow people entering the University to be made aware that CCTV systems operate within the University.

10.3. The Code of Practice will be available at the Libraries and on the Divisional web page, where the introduction of the system (or any subsequent changes) will be publicised through the ANU notice board for a period of two weeks.

11. COOPERATION WITHIN A UNIVERSITY ENVIRONMENT

11.1. The System will operate in a manner that is sensitive to the privacy of people living and working in the area.

11.2. Camera Operators will receive training in the varying degrees of privacy afforded by public, semi public and private premises within a mixed teaching, research, and residential University atmosphere.

12. ASSESSMENT OF THE SYSTEM AND CODE OF PRACTICE

12.1. The Facilities and Services Division is responsible for ensuring that the System is evaluated annually by the Director or agent.

12.2. Evaluation will be conducted according to the following criteria:

  1. Impact on crime/damage/public order.
  2. Impact on key objectives.
  3. Impact on neighbouring areas without CCTV.
  4. Operation of the Code.

12.3. Ongoing monitoring of the System will be conducted by the Manager, Security and Campus Services, who will also take all reasonable measures to ensure that all relevant parties are complying with the provisions of this Code.

13. OPERATING STAFF

13.1. This section applies to both University staff and contractors employed to work on the system. Staff and contractors will comply with the following conditions:

  1. The employment of staff will comply with all relevant University policies. Contractors will ensure that staff are employed in accordance with relevant industrial awards and legislation, including equal opportunity and occupational health and safety. Contractors will ensure that the selection process provides for thorough validation of the suitability of candidates to work in this environment.
  2. Contract staff must be qualified at a suitable level to complete the required duties of the contract work.
  3. University staff will be subject to the University disciplinary procedure in the event of actions that do not comply with the conditions of this Code. Where it is proved that contract staff have breached any of the conditions of this Code, these staff will not be permitted to continue working on campus. In appropriate circumstances, the University reserves the right to terminate a contract where a breach of this Code is proved. These conditions will be detailed in all contracts let for services in this area.
  4. The Manager, Security and Campus Services will ensure that all University staff will be briefed on their responsibilities under this Code. The Contractor will ensure all contract staff are briefed regarding the requirements of this Code. Where appropriate, the Facilities and Services Division will a briefing on the conditions of this Code in the Contractor Induction Program run by the Division.
  5. A requirement of confidentiality, which can be enforced during and after termination of employment.
  6. University management and Contractor managers will establish systems of monitoring and supervision that will ensure compliance with the Code of Practice and operational guidelines.

13.2. All University staff and contract staff must be briefed on the conditions of the Code of Practice and Operational Manual before commencing work on the system or within the Control Room area.

14. COMPLAINTS

14.1. Complaints regarding the CCTV system and its operation must be made in writing to the Director, Facilities and Services. Where appropriate, the Director will appoint an independent officer with suitable qualifications to investigate the complaint and provide a written report within an agreed period of time not to exceed eight weeks. The report will be presented to the Director, Facilities and Services, who will normally take action as appropriate within the University guidelines and then advise the complainant. Where the complainant is not satisfied with the resolution, the complaint can be directed to the Vice-Chancellor for investigation and action as appropriate. For this Code, the definition of an independent officer is one who does not directly work in areas responsible for the management or maintenance of the CCTV system. The investigating officer can be on the staff of the Facilities and Services Division.

15. BREACHES OF THE CODE INCLUDING THOSE OF SECURITY

15.1. Breaches of the Code of Practice and of security must be subject to proper investigation by, in the first instance, the person appointed by the Director to conduct an investigation. This person shall be responsible for making recommendations to the Director to remedy any breach which is proved or evidenced.

15.2. The University reserves the right to apply disciplinary sanctions for breaches, up to and including referring the breach to the Police.

16. CONTROL AND OPERATION OF THE CAMERAS

16.1. Control Room equipment and the remote control of cameras will only be operated by the Manager, Security and Campus Services, Control Room Staff and persons/staff under training. All these people will act with the utmost probity.

16.2. All use of cameras and recording equipment will accord with the purposes and key objectives of the System, as developed in training and specific operational instructions to staff, and shall comply with this Code of Practice.

16.3. Cameras will not be used to look into private property. Operational procedures shall be adopted to ensure restraints upon the use of cameras in connection with private premises.

16.4. System Operators will be subject to supervisory procedures to ensure compliance with this aspect of the Code.

16.5. System Operators are aware that recordings are subject to routine audit and that they may be required to justify their interest in a member of the public or premises.

16.6. The Manager, Security and Campus Services will decide the level of incidents to be reported to the Police. The Police shall log all such incidents. It is recognised that the decision as to what level of response is deployed is a matter entirely for the Police. The Manager, Security and Campus Services will liaise regularly with the Police on this subject.

16.7. The Operations Manual will provide guidance on the method of operation of cameras, length of time viewing monitors and of minimum operator's performance levels.

16.8. A record will be maintained as defined by the Manager, Security and Campus Services of all monitored:

  1. Passive Nuisances
  2. Active Nuisances
  3. Suspicious Person or Vehicle
  4. Assaults
  5. Crime in Progress including Escapes
  6. Road Traffic Accidents involving Serious Injury
  7. Traffic Management Matters
  8. Illegal Street Trading
  9. Other Approved Purposes

16.9. This record will be included as part of the means of establishing effective evaluation and targeting of key objectives.

17. ACCESS TO AND SECURITY OF THE MONITORS/CONTROL ROOM

17.1. Access to view monitors, whether to operate the equipment or view the images is strictly limited to staff with that responsibility.

17.2. A Control Room Main Log will contain details of all recordings made in relation to 16.8 above. Details of any visitors authorised by this Code, including times of arrival and departure and details of any telephone calls, will be recorded separately.

17.3. The Control Room will remain locked at all times. A coded door lock will strictly control access with a key override. Access will be strictly limited. All occupants will be identified prior to access. Routine access will only be granted to certain Managers, Operators, Police Officers, Maintenance Staff and those under training.

17.4. It is important that visits do not interrupt the efficiency of the system. Casual visits will not be permitted. Organised parties shall be allowed for lawful and proper reasons to visit by the Manager, Security and Campus Services with approval, in advance. The Manager, Security and Campus Services will be present during all organised visits.

17.5. Public access to or the demonstration of monitors will not be permitted except for lawful and proper reasons.

17.6. Visits by no more than two Police Officers at any one time will be permitted provided that they are on duty and the visit is in connection with liaison, training or purposes of the system. These visits must be authorised by the Director or agent in writing in advance.

17.7. Security procedures will be the subject of audits.

18. TAPES AND RECORDED MATERIAL

18.1. Recorded material will be used only for purposes defined in this Code of Practice. Access to recorded material will only take place as defined in the Code of Practice. In particular recorded material will not be sold or used for commercial purposes. The showing of recorded material to the public will only be allowed in accordance with the law, either in compliance with the needs of the Police in connection with the investigation of crime, which will be conducted in accordance with the provisions of any relevant police and criminal procedures, and any advice and guidance given to the Police from time to time; or in any other circumstances provided by law. Any showing of the material will protect the rights of innocent parties.

18.2. Ownership and copy right of all recorded material vests in the University.

18.3. Recording equipment will be checked from on an agreed schedule by the Manager, Security and Campus Services to ensure it is in good working order.

18.4. Digital image storage of CCTV activity is maintained sufficient for the purpose. Images required for evidential purposes must be stored separately and an additional copy made to maintain a full record of operational tapes retained for the stated period. This is in addition to evidential copies made. All digital storage no longer required shall be destroyed and erased.

18.5. Evidence images shall be stored in a secure cabinet and the key held by the Manager and Assistant Manager.  Discs or Media are uniquely and individually labelled. All image recordings handed to the Police or others as evidence will be subject to entries in relevant transmittal registers, which will also record details of all images removed, viewed, but not copied. The names of the persons viewing and the reason will also be shown. All viewing will be in accord with the "purpose" statement. The tape registers are to be securely stored.

18.6. Digital images for evidential purposes will be regarded as exhibits. Copying procedures will be agreed with prosecuting authorities and detailed in the Operational Manual. As far as possible certified copies, rather than the original, should be used for investigation purposes.

18.7. Police may be given CCTV access to image drives where an officer reasonably believes that access and/or copies of specific images are necessary for the investigation and detection of an offence or offences, or for the prevention of crime. Images provided to the Police shall at no time be used for anything other than the purpose specified and identified when operators release the tape to the Police. A Police Officer, not below the rank of Inspector, may visit the actual room from time to time to ensure that agreed procedures are being followed. All requests for access to CCTV image storage by Police must be approved by the Director or agent.

18.8. Access to images may be obtained in connection with civil disputes by Court Orders or be extended to lawyers acting for defendants or victims in criminal proceedings in consultation with the Police. All requests for access to images for this purpose must be approved by the Director or agent, only after consultation with the ANU Legal Office.

18.9. No other access will be allowed unless approved by the Director or agent. Approvals will only be granted for reasons which fall within the purposes and objectives of the scheme and in accordance with this Code of Practice.

19. PHOTOGRAPHS

19.1. Still images and static images (printed of electronic media) will not be taken as a matter of routine.

19.2. Still images from live incidents will only be taken at the request of the Director, Manager Security and Campus Services or the Police Officer in charge of the scene. A written record of the request including details of the requesting officer, time and date of the request and the reasons will be made. This record will be held by the Manager, Security and Campus Services.

19.3. Only a Police Officer authorised by a Police Officer of at least the rank of Sergeant may request that the operator produces a still image taken at a live incident, or still photographs from video recordings. Still photographs can only be requested where they are required for the prosecution or detection of crime.

19.4. All still images (printed of electronic) will remain the property of the University and will be filed in numerical sequence.

19.5. As indicated above, a record will be kept of the reason for the production of any image taken from live action. The stills record book will include the details of the staff member taking the image, date and time the image was taken and the reasons the image was taken.

19.6. Any still image released to the Police will be dealt with by the Police as an exhibit and shall at no time be used for anything other than the purpose specified.

19.7. Still images may only be destroyed or erased by the Manager, Security and Campus Services and within 31 days, unless made the subject of a Police application or required as evidence.

19.8. Images will not be used to brief operators so as to avoid contamination of operator's evidence.

19.9. Digital media for the recording, transcribing and coying of electronic images shall be secured in a locked cabinet.

20. DEALING WITH INCIDENTS

20.1. The level of Police response to incidents occurring on campus will be determined by the AFP and will be subject to the various priorities at the time the incident is reported. The University has no control over the priority allocated by the Police.

20.2. The Control Room operators and security supervisors are authorised to report relevant matters to the Police and other emergency services, as appropriate. A written record of any reports will be made at the time and will include details of the incident, date and time of the report and details of the AFP or other services officer taking the report. Where appropriate, the Control Room operator and security supervisors may elect to have the ANU Mobile Security Patrol attend the incident before making a formal report to the AFP or emergency services.

20.3. All incidents requiring attendance by the AFP or other emergency services will be reported to the Manager, Security and Campus Services, as soon as possible.

21. POLICE CONTACTS

21.1. For the day-to-day purposes, the University's contact liaison officer with the AFP will either be the Inspector with responsibility for City Centre Policing or the designated Area Inspector. As appropriate, the Community Policing Officer will liaise with the University in regard to decisions with significance for the operation and management of the System.

21.2. A record of telephone calls from the Police to the Control Room will be maintained, with details of caller, purpose of the call and outcome being recorded.

21.3. Audible voice logging of phone contact with ANU security is provided and will be used when operational, in dealing with live incidents.

21.4. Approval for the police use of the system in any manner will be subject to their agreement to comply with these Codes of Practice.

21.5. The presence of a Police Officer in the Control Room for a pre-planned operation or ongoing incident is permitted, subject to authorization being given by the Director or agent. This Officer may direct the operation of cameras. However, these directions must comply with conditions outlined in this Code of Practice. The Control Room operator has discretion to refuse directions where he/she believes that the request does not comply with the Code.

21.6. There will be no remote control facility at the Police Communications Centre but a Police Officer may direct camera operators during a live incident audibly, by the telephone, provided the actions requested comply with this Code of Practice.

21.7. Should a request from the Police arise for use of the system in any manner that is not provided for by the Code of Practice, this request must be agreed between the Director and the Area Police Inspector concerned. This approval process cannot be devolved to an agent.

21.8. A written record will be maintained of any use of the system at the request of the Police. This record will include details of the Police Officer making the request, details of the Divisional officer authorising the request, time and date of the request and reasons for the request.

22. COMPLIANCE AUDIT

22.1 Compliance by University staff (specifically Security officers) and contract staff will be subject to audit. These audits will be conducted as required and at least once per year. The Director, Facilities and Services will appoint an independent staff member to undertake the audit and provide a written report.

WarwickWilliams
Director
Facilities and Services Division

NOTES
For Manager, Security and Campus Services read also Assistant Security Manager or any other Officer so appointed by The Director, Facilities and Services.

Definitions:
Agent: An officer authorised by the Director, Facilities and Servics to act on his behalf under this Code of Practice. Normally, Manager Security and Campus Services unless otherwise stated.
Contractor: Contractor employed by the University to work on the CCTV system or in the ANU Control Room
Logbook: The electronic log used by ANU Security to record incidents occurring during a security shift
Operations Manual: Any authorised manual detailing standard operating procedures for activities undertaken or systems managed by ANU Security
Police: Australian Federal Police
Police officer: Australian Federal Police Officer
Register: Transmittal register used to record the transmission, archiving or disposal of tape media containing visual images recorded using the University CCTV system.
Security Officer: ANU Security Officer
Staff member: University staff member