CCTV Policy
MARSA OPEN CENTRE/MARSA INITIAL RECEPTION CENTRE
A. Policy Statement
The Agency for the Welfare of Asylum Seekers (hereinafter referred to as “the Agency”) processes personal data by means of CCTV (closed circuit television) cameras for the purpose of security monitoring in selected common areas of the Agency’s premises indicated above. The CCTV system was installed to comply with the Health and Safety legislation, to provide a safe and secure environment for the staff and visitors at the premises and to protect the property stocks and equipment on the same site. The scope of this policy is to define a proper procedure for the use of CCTV images and to detail the controls necessary to ensure compliance with the Data Protection Act.
B. Purpose
The CCTV system will monitor the following indoor and outdoor public areas under the direct control of the Agency’s management at Marsa open centre/Marsa Initial Reception Centre. These include;
1) Main entrance;
2) In front guard room and inside guardroom;
3) Main exit of MOC/IRC Offices;
4) Workshop area and workshop side car park;
5) General Store exit and gym;
6) Education centre and bedding store;
7) Kitchen and dorms;
8) Football pitch and side car park;
9) 1 st and 2nd floor corridors and stairwells;
10) Server room and IRC corridors;
11)Back side area of the MOC building
The above areas are monitored by the Agency to;
- Protect the health and safety of employees and visitors on the site;
- Monitor the security of the site and property, stocks and equipment thereon;
- Form part of the overall internal control procedures.
Whereas the CCTV system shall monitor the designated areas for the above-mentioned purposes, the Agency shall not view the system’s live images at all times. However the Agency reserves the right to appoint an officer to monitor the live images of the cameras.
However, in case of an activity captured by the cameras, which may involve a member of staff or service-user or a visitor and which may require an internal investigation, the Agency reserves the right to extract the relevant footage and take all such actions deemed necessary in the particular circumstance. The Agency also undertakes that in the case of an activity captured by the camera and which might lead to criminal charges, the relevant extract of the camera’s footage may also be disclosed to the law enforcement authorities for the purpose of the relevant investigation.
The recording medium shall be overwritten and any copies destroyed after seven (7) days unless these are strictly required for the purpose of an investigation. In similar cases, the relevant recordings shall be kept until the investigation is concluded and shall be destroyed once that it is no longer necessary.
C. Right of access
Any individual whose personal data is held by the Agency, in the form of a CCTV recording, can request access to that recording in terms of article 21 of the Data Protection Act. Although the law does not specifically entitle the individual to have an extract of the images being recorded, or to view directly the images, in the case of CCTV systems, the most practical approach is to grant direct viewing of the images, provided that the identity of third parties will be obscured.
If an individual is not satisfied with the reply as provided or with the manner access has been granted, the matter may be referred to the Data Protection Commissioner who will investigate the case and ascertain that the right of access is properly granted.
Right of access requests shall be made in writing and addressed to the Chief Executive Officer.
D. Logging Procedures
The Agency undertakes to comply with a strict security policy vis-à-vis the access to recorded images. Any internal access to visual images by the organisation or any disclosure of such images further to a request by a law enforcement body or by the data subject shall be logged
and kept as evidence.
Last Updated: 25 July 2016
