CCTV CODE OF PRACTICE

1 CCTV CODE OBJECTIVES The objective of this code of practice is to provide a framework for the management and integration of CCTV installations in locations within Edith Cowan University. CCTV is a long established technology which is widely deployed in commercial environments and public spaces. The method of application can be categorised into 2 main types;(a) monitored and (b) un-monitored installations reflecting the 2 purposes; either to provide real time observation of events in order for immediate responses in the event of an incident or to capture evidence of events which can subsequently be uploaded for investigative / evidentiary purposes.

ECU CCTV will operate a predominantly unmonitored CCTV system other than in instances when (a) security incidents are afoot, (b) when staff are available and (c) as a “background” system for security officers when available.

The available research on CCTV identifies that CCTV does not absolutely prevent crime or anti-social behaviour, but that it has the capacity to reduce the incidence of opportunistic anti-social behaviour and may provide reliable forensic evidence when such behaviour occurs. Such evidence can be used to identify perpetrators for potential prosecution under the relevant statutes or for disciplinary purposes. Research also indicates that CCTV provides a discernable level of comfort to members of society in the context of reducing the fear of crime in public places.

The preservation of digital evidence integrity is crucial to the applicability of CCTV for court related matters. ECU will take all reasonable steps to maintain the integrity of any potential digital evidence.

This Code of Practice describes the criteria to be applied when determining where and when CCTV equipment will be installed in any new / redeveloped built environments.

CCTV Code of Conduct Page 1 June 2015 All printed copies are uncontrolled Issue 2 2 KEY PRINCIPLES This Code of Practice contains the fundamental standards on which the Edith Cowan University CCTV system will be operated.

The Code of Practice is based on 12 key principles as listed below:

2.1 Principle 1 The CCTV system will be operated with a high level of due diligence and in accordance applicable laws. This code of practice will be used only for the purposes for which it is established or for future purposes which are subsequently agreed and properly endorsed by University management.

2.2 Principle 2 The CCTV system will be operated with due regard to the privacy and civil liberties of individual members of the student, public and staff populations, and will recognise the rights to freedom of religious and political expression along with individuals rights of assembly.

2.3 Principle 3 The public interest in the operation of the CCTV system will be recognised by ensuring the security and appropriateness of operational procedures.

2.4 Principle 4 Edith Cowan University has primary responsibility for compliance with the objectives of the CCTV System. This principal extends to include the maintenance, management and security of the operating system. In instances where the service is outsourced, proper audit functions will be conducted in order to ensure appropriate due processes and safeguards are employed by third parties in relation to governance matters.

2.5 Principle 5 Edith Cowan University will be accountable for the actions and materials provided by any third party under a service level agreement for such services provided in the management of the CCTV camera system.

2.6 Principle 6 All staff and contractors who are employed to use, operate or interact with the CCTV system, irrespective of their status within the University will be required to meet the highest standards of probity.

2.7 Principle 7 The public will be provided with clear and easily accessible information in relation to the operation of the Edith Cowan University CCTV system. The University maintains the right to protect any private, commercially sensitive or legally restricted material.

CCTV Code of Conduct Page 2 June 2015 All printed copies are uncontrolled Issue 2 2.8 Principle 8 Information recorded will be accurate, relevant and not exceed the levels necessary to fulfil the requirements of the CCTV system.

2.9 Principle 9 Information will be obtained fairly and in accordance with the privacy provisions of the Code of Practice as well as all relevant statutes.

2.10 Principle 10 Access to the CCTV system including: data, monitoring screens and physical devices (NVR/DVR) will be restricted from unauthorised access. Where practicable the control room will be protected from unauthorised access.

2.11 Principle 11 Digital files, photographs and recorded material will be retained for a period not exceeding 21 days unless required in relation to (a) the investigation of a suspected crime, (b) Internal security incidents or (c) court proceedings. All recorded material which does not meet the extended retention criteria will then be archived or destroyed.

2.12 Principle 12 Contact related to the CCTV system between Edith Cowan University staff and any third parties will be conducted strictly in accordance with this Code of Practice.

CCTV Code of Conduct Page 3 June 2015 All printed copies are uncontrolled Issue 2 3 PURPOSE The primary purpose of the Edith Cowan University CCTV system is to assist in the prevention of crimes against members of the University population and the wider community.

The secondary purpose of the CCTV system is to assist in the prevention of serious criminal offences, malicious damage to property, (including graffiti) and behaviour contrary to the stated values of the University.

The system may also be used to assist in the operation of the University incident response and emergency management procedures.

The objective of any security measure within ECU aims to:

i) Reduce crime levels by deterring potential offenders;

ii) Reduce fear of crime;

iii) Help ensure a fast, effective police response in emergency situations;

iv) Identify behaviour contrary to the interests of the University;

v) Assist in the detection and prosecution of offenders; and

vi) Help secure a safer environment for those people who live in, work in and visit the university

4 OPERATION 4.1 Introduction It is recognised that the perceived threat of violence or antisocial behaviour are important factors in determining how Students, Staff, visitors and other stakeholders develop a sense of safety within the campus. As part of its effort to combat the fear of crime and related criminal activity on University premises, ECU Security & Traffic Services take responsibility for providing technology, materials, training and security awareness services to a range of stakeholders.

4.2 Operational statement All CCTV installations will meet the requirements of Edith Cowan University’s CCTV Code of Practice. All installations will be designed to meet the particular requirements / limitations of the space in which they are deployed. Furthermore, consideration will also be given to the underpinning circumstances that have driven the need for installation of CCTV to be employed. .

All new installations will require the approval of the Director of Facilities and Services prior to works being undertaken.

Unmonitored CCTV installations will be used as a preferred deployment type over monitored installations. CCTV installations will always use operational devices.

CCTV Code of Conduct Page 4 June 2015 All printed copies are uncontrolled Issue 2 The use of “dummy” installations is not permitted as they can give a false sense of security to users of that space.

CCTV installations will always be of a sufficient standard to capture a satisfactory level of evidence. In determining the correct equipment to be use, consideration will be given to the existing level of (a) ambient and artificial lighting and the (b) required image quality. Image data may be retained locally at the point of capture or stored remotely from the installation.

CCTV installations will be installed where security risk management processes indicate that a sufficient risk of crime being perpetrated exists or in instances where sufficient community sentiment give rise to a need for electronic surveillance to be deployed. CCTV installations will also be activated where the value of particular assets provide a business case for installation of surveillance. A cost/benefit analyses will be undertaken in such instances.

CCTV installations will be clearly signed across the deployment. Australian case law recognises that persons in public places have extremely limited rights to privacy; however the University’s approach is to ensure that appropriate steps are taken to raise awareness that surveillance equipment is in operation.

CCTV installations may be deployed in University buildings, grounds and other leased premises. Installations may be established in either a permanent or temporary mode, depending on the reason for the deployment.

CCTV installations may be passive or “event activated” by means of motion, heat, sonic or other detectors.

4.3 Work Instructions This Code of Practice will be supplemented by the CCTV Standard Operational Procedures (Work instructions) giving instructions on all aspects of the operation of the system. These documents will be based relevant legislation and best practice within the security industry.

This Code of Practice is subject to relevant State and Federal law.

4.4 CCTV Camera system The distributed CCTV system is one of the initiatives that forms part of University crime prevention and incident investigation processes.

The CCTV system is only one of a number of systems employed to assist in preventing criminal activities and other behaviours which are at odds to the University’s values of Integrity, Respect, Rational Enquiry and Personal Excellence.

CCTV Code of Conduct Page 5 June 2015 All printed copies are uncontrolled Issue 2 4.5 System description The CCTV system comprises a range of reticulated and fixed cameras connected to a central control room via IP networks along with a small number of stand-alone cameras. All networked images are transmitted live to observation screens which may be monitored by security staff employed by the University or by a nominated service provider. All images are recorded and retained for a minimum of 21 days unless they are required in relation to the investigation of an internal security incident, crime or for court proceedings. Such evidence may be retained for longer periods.

4.6 Camera Design All cameras are of sufficient design quality to enable effective monitoring. Each camera is, or may be housed in a tinted environmental dome, which (a) protects the camera and (b) ensures that the camera itself is not intrusive to the aesthetic environment.

State of the art technology will be used to ensure optimum resolution and picture quality for its deployment. The technology used will be regularly reviewed to ensure the most up to date equipment appropriate to the purposes of the CCTV system is used.

Covert cameras may be used as part of investigations into security incidents or when an increased threat of security incident has been identified. Use of covert cameras is to be limited and must be authorised by the Manager, Campus Operations and Resources.

4.7 Camera locations Cameras are installed in those areas where a security risk assessment consistent with ISO:31000 and AS:HB167 demonstrates the need to view activities in real time or capture activities for later reporting to relevant authorities, including the WA or Federal Police. Environmental considerations are also taken into account when considering places of deployment.

4.8 Prohibited spaces In accordance with the relevant legislation ECU will not install CCTV cameras in areas where there is a reasonable expectation of privacy. These areas will include all bathrooms, dressing rooms and private accommodation areas.

4.9 Ownership of the CCTV Camera Systems Edith Cowan University Security & Traffic Services are the owner of the CCTV system. Edith Cowan University retains ownership of all equipment, vision, photographs, digital files and documentation pertaining to the system. The responsibilities of Edith Cowan University in relation to the system are outlined in section 5.

CCTV Code of Conduct Page 6 June 2015 All printed copies are uncontrolled Issue 2 4.10 Partners in the CCTV Camera system The WA Police are considered as partners in the context of their law enforcement role in the state of Western Australia.

4.11 Access to the System Routine access to the system will be limited to ECU security staff only. Contractors who perform maintenance on the system will be permitted to access the system under supervision and within limited parameters. Access may be granted by the Manager STS for audit, verification and software update purposes.

Review of footage will be logged through the CCTV system logging feature showing: time, date and footage viewed.

Any access that is deemed by the manager STS inconsistent with the stated goals of this code will result in disciplinary action.

4.12 Access to Footage Access to footage will be limited only to those authorised to view footage in accordance with the ECU CCTV work instructions. As a general principle access is restricted to:

1. Personnel who are authorised to utilise and access the CCTV system as part of their normal duties. This will by definition be limited to security operations staff, other authorised operational staff and their managers.

2. WA Police or other Law enforcement agencies for the investigation of a crime or during the management of a major security incident.

All other access to the CCTV system is to be authorised by the Manager of Security and Traffic Services (or their nominated delegate). The release of digital, analogue or hardcopy material to external parties may only be made with the express approval of the Manager of Security and Traffic Services.

4.13 Storage Storage of footage within the system will be password protected and stored on all individual DVR/NVR recording devices and written over on an ongoing basis. Storage of all downloaded footage will be in accordance with the ECU records management policy.

4.14 Disposal All hard drives replaced or removed from the system will have all data erased to the minimum standard as set out in the U.S Department of Defence Standard DoD 5220.22-M (the clearing and sanitizing of digital media).

CCTV Code of Conduct Page 7 June 2015 All printed copies are uncontrolled Issue 2 5 AMENDMENTS TO THE CODE OF PRACTICE 5.1 Minor A minor change to the CCTV Camera Program or Code of Practice may be made with the agreement of both the Director of Facilities & Services and the Manager, Security & Traffic Services.

A minor change is such as may be required for the purposes of adjustment of the Program or clarification of the Code of Practice, for example, the replacement of one brand of video recorder with another or a change to the wording of a particular section of the Code of Practice where its meaning might otherwise be ambiguous, or a proposal to install further cameras under the prevailing conditions of use.

5.2 Major A major change to the CCTV system or to the Code of Practice will take place only after consultation with relevant Faculties and Centres and the completion of a Security Risk Assessment. A major change is defined as a change that would have a significant impact upon the operation of the system or the Code of Practice, for example, a change to the purposes of the system.

6 RESPONSIBILITIES OF THE OWNER OF THE SYSTEM

Edith Cowan University Security & Traffic Services and or its external service provider will be responsible for the introduction and implementation of the Code of Practice and for ensuring compliance with the principles contained within the Code.

All staff and service providers will comply with the requirements for accountability set out in this Code of Practice. Risk and Assurance Service Centre will be responsible for the audit of all CCTV processes.

Security & Traffic Services will consult as necessary in connection with the implementation or modification of any part of the CCTV installation.

CCTV Code of Conduct Page 8 June 2015 All printed copies are uncontrolled Issue 2 7 RELATED LEGISLATION, STANDARDS AND GUIDELINES 7.1 Legislation Privacy Act 1988 (Commonwealth), The Surveillance Devices Act (WA) 1998, The Security & Related Activities (Control) Act (WA) 1996,

7.2 Standards AS4806 -2006 Closed Circuit Television (CCTV) ISO31000:2010 Risk Management HB167:2006 Security Risk Management Handbook

7.3 Guidelines Western Australian CCTV guidelines, WA Police Office of Crime Prevention

8 PUBLIC INFORMATION

Where practicable, clearly visible signage will be displayed indicating that CCTV cameras are in operation throughout the University.

These signs will:

i) inform the public that cameras are in use in that particular location;

ii) allow people entering the area to make an informed approximation of the area covered by the system;

Copies of this Code of Practice will be made available to the public upon request.

9 CONTACT Inquiries in relation to the Edith Cowan University CCTV system and its operation can be made in writing to:

The Manager, Security & Traffic Services ECU Security 270 Joondalup Drive Joondalup WA 6027 Email: [email protected]

CCTV Code of Conduct Page 9 June 2015 All printed copies are uncontrolled Issue 2