CCTV (closed-circuit television) is a TV system in which signals are not publicly distributed
but are monitored, primarily for surveillance and security purposes.
PURPOSE:
WISE Indian Private School seeks to ensure the security and safety of all students, staff, visitors,
contractors, its property and premises.
Therefore, WISE has deployed CCTV monitoring in accordance with The Monitoring and Control Center
(“MCC”) – Law No.5 of 2011 (“MCC Law”) with the statutory aims to:
• promote a safe environment and to monitor the safety and security of its premises;
• assist in the prevention, investigation and detection of crime;
• assist in the apprehension and prosecution of offenders, including use of images as evidence in
criminal proceedings; and
• assist in the investigation of breaches of its codes of conduct and policies by staff, students and
contractors and where relevant and appropriate investigating complaints.
POLICY:
• The CCTV systems installed in and around WISE Indian Private School cover building
entrances, perimeters, external areas such as play grounds, internal areas such as
reception lobby, computer rooms, rooms with high value equipment, some corridors
and class rooms. They continuously record activities in these areas.
• CCTV Cameras are not installed in areas in which individuals would have an
expectation of privacy such as toilets, changing facilities etc.
• CCTV cameras are installed in such a way that they are not hidden from view. Signs
are prominently displayed where relevant, so that staff, students, visitors and
members of the public are made aware that they are entering an area covered by
CCTV.
Covert recording
• Covert recoding i.e. recording which takes place without the individual’s knowledge
may only be undertaken in exceptional circumstances, for example to prevent or
detect an unlawful act or other serious misconduct, and if is proportionate i.e. there
is no other reasonable, less intrusive means of achieving those purposes;
• May not be undertaken without the prior written authorisation of the Principal and
Admin Officer. All decisions to engage in covert recording will be documented,
including the reasons;
• Will focus only on the suspected unlawful activity or suspected serious misconduct
and information obtained which is not relevant will be disregarded and were
reasonably possible, deleted;
• Will only be carried out for a limited and reasonable period consistent with
particular purpose of the recording and will not continue after the investigation is
completed.
Control room
No unauthorised access to the Security Control Room (“the Control Room”) will be permitted at any
time. Other than Security Control Room Staff, access to the Control Room will be limited to:
• Persons specifically authorised by the Safety officer/ Principal;
• Security Supervisor;
• Security Control Room Operator;

• Maintenance engineers;
• police officers where appropriate; and
• Any other person with statutory powers of entry.
Monitors are not visible from outside the Control Room.
Before permitting access to the Control Room, security staff will satisfy themselves of the identity of
any visitor and existence of the appropriate authorisation. All visitors are required to complete and
sign the visitors’ log, which includes details of their name, department and/or the organisation that
they represent, the person who granted authorisation and the times of entry to and exit from the
Control Room. A log shall be retained setting out the following:
• Person reviewing recorded footage;
• Time, date and location of footage being reviewed; and
• Purpose of reviewing the recordings.
Processing of Recorded Images
CCTV images will be displayed only to persons authorised to view them or to persons who otherwise
have a right of access to them. Where authorised persons access or monitor CCTV images on
workstation desktops, they must ensure that images are not visible to unauthorised persons for
example by minimising screens when not in use or when unauthorised persons are present.
Workstation screens must always be locked when unattended.
Quality of Recorded Images
Images produced by the recording equipment must be as clear as possible so they are effective for
the purpose for which they are intended. The following points to be taken care of
• recording features such as the location of the camera and/or date and time reference must be
accurate and maintained;
• cameras must only be situated so that they will capture images relevant to the purpose for which
the system has been established;
• consideration must be given to the physical conditions in which the CCTV cameras are located i.e.
additional lighting or infrared equipment may need to be installed in poorly lit areas;
• cameras must be properly maintained and serviced to ensure that clear images are recorded and a
log of all maintenance activities kept; and
• as far as practical, cameras must be protected from vandalism in order to ensure that they remain
in working order. Methods used may vary from positioning at height to enclosure of the camera unit
within a vandal resistant casing.
Retention and Disposal
• CCTV images are not to be retained for longer than necessary, taking into account the
purposes for which they are being processed. Data storage is automatically managed by
the CCTV digital records which overwrite historical data in chronological order to produce
an approximate 28-day rotation in data retention.
• Provided that there is no legitimate reason for retaining the CCTV images (such as for use
in disciplinary and/or legal proceedings), the images will be erased following the
expiration of the retention period.
• All retained CCTV images will be stored securely.
Third Party Access
Third party requests for access will only be considered in line with in the following categories:
• Legal representative of the Data Subject;
• Law enforcement agencies including the Police;
• Disclosure required by law or made in connection with legal proceedings; and
• HR staff responsible for employees and administrative staff responsible for students in disciplinary
and complaints investigations and related proceedings.

• The Data Protection and Information Compliance team (Principal, Admin officer and safety
officer) will disclose recorded images to law enforcement agencies including the Police
once in possession of a form certifying that the images are required for either: an
investigation concerning security; the prevention or detection of crime; or the
apprehension or prosecution of offenders, and that the investigation would be prejudiced
by failure to disclose the information.
• Where images are sought by other bodies/agencies with a statutory right to obtain
information, evidence of that statutory authority will be sought before CCTV images are
disclosed.
• Every disclosure of CCTV images is recorded in the CCTV Operating Log Book and contains:
 The name of the police officer or other relevant person in the case of other
agencies/bodies receiving the copy of the recording;
 Brief details of the images captured by the CCTV to be used in evidence or for other
purposes permitted by this policy;
 The crime reference number where relevant; and
 Date and time the images were handed over to the police or other body/ agency.
• Requests for CCTV images for staff or student disciplinary purposes (or complaints
purposes) must be authorised by HR or Principal/Admin Officer /Safety officer.
Complaints Procedure
Any complaints relating to the CCTV system should be directed in writing to the safety officer/ admin
officer promptly and in any event within 7 days of the date of the incident giving rise to the
complaint. A complaint will be responded to within a month following the date of its receipt.
Records of all complaints and any follow-up action will be maintained by the relevant office. If a
complainant is not satisfied with the response they may appeal to the Principal. Complaints in
relation to the release of images should be addressed to the Administration officer/ Safety officer as
soon as possible and in any event no later than one month from the event giving rise to the
complaint.