Documents
Resources
Learning Center
Upload
Plans & pricing Sign in
Sign Out

CCTV Policy

VIEWS: 209 PAGES: 22

									                                     CCTV Policy

Version                                  1.0
Approving Committee :                    Quality Committee

Date ratified:                           14.12.2010

Reference Number:                        76

Name/Department of originator/author:    H&S Advisor/LSMS

Name/Title of responsible                Health, Safety & Security Committee
committee/individual:
Date issued:                             15th December 2010

Review date:                             July 2012

Target audience:                         All employees


Version                 Date         Control Reason
Draft v0.1              04.2010      Information Governance Manager
Draft v0.2              22.09.2010   Issued for comment Health, Safety & Security Committee,
                                     Nurse Director/Director of Clinical Quality & Innovation; Head
                                     of Operations & Facilities Management; Head of Estates, IT
                                     Security Manager, Deputy Chief Operating Officer CHC
                                     HMR; CHC HS&S Committee; JNCC
Draft v0.3              24.09.2010   IT Security Manager
Draft v0.4              09.11.2010   EIA Screening
Draft v0.4              14.12.2010   Issued for approval to Quality Committee




                                                                                    Page 1 of 22
                                   CONTENTS

 SECTION                              TITLE                       Page No.
    1.       Introduction                                            5
             1.1    Rationale
             1.2    Policy Key Points
             1.3    Supporting Documentation

     2.      Aims and Objectives                                      5

     3.      Roles and Responsibilities                               6
             3.1   Heywood, Middleton & Rochdale PCT
             3.2   Health, Safety & Security Committee
             3.3   Caldicott Guardian
             3.4   Local Security Management Specialist
             3.5   Premises & Facilities Manager
             3.6   Data Protection Officer
             3.7   Managers
             3.8   Employees

     4.      CCTV Schemes                                            10
             4.1  Principles
             4.2  Data Protection Legislation
             4.3  Targeted Observation
             4.4  Installation
             4.5  Subject Access
             4.6  Procedures for Accessing subject Access
                  Requests
             4.7  Breaches of this Policy
             4.8  Compliance Procedures

     5.      Training and Training Needs                             13

     6.      Monitoring and Review                                   13

     7.      Dissemination and Implementation                        14

Appendix 1   CCTV Schemes Currently in Operation                     15
Appendix 2   Installation Checklist                                  16
Appendix 3   Access to View or Copy Recordings - Police & CFSMS      17
Appendix 4   Application for Access to Recorded Images               18




                                                                   Page 2 of 22
1.        Introduction

1.1       Rationale

          The purpose of this policy is to ensure:
         That the use of Closed Circuit Television (CCTV) adheres to the principles of the
          Data Protection Act 1998, Human Rights Act 1998, Regulation Investigatory
          Powers Acts 2000 and other relevant legislation.
         That any CCTV system is not abused or misused.
         That CCTV is correctly and efficiently installed, operated and monitored.


1.2       Policy Key Points

         How decisions are made regarding the need for a CCTV scheme.
         Who has the responsibility for managing CCTV schemes.
         How CCTV schemes are monitored to ensure they adhere to national guidance.
         What standards need to be achieved to ensure the schemes are valid.

1.3       Supporting Documentation

         Appendix 1 – CCTV Schemes Currently in Operation
         Appendix 2 – Access to View or Copy Recordings – Police and Public
         Appendix 3 – Installation Checklist



2.        Aims and Objectives

          This policy describes the Heywood, Middleton & Rochdale PCT approach to
          identifying needs, installation and use of CCTV to ensure compliance with the
          Data Protection Act 1998, Human Rights Act 1998, Regulation Investigatory
          Powers Acts 2000 and other relevant legislation

          The policy is binding on all employees of Heywood, Middleton & Rochdale PCT
          and applies also to other persons who may, from time to time and for whatever
          purpose, be present on any of its premises.

          The direct management of external CCTV cameras on sites which are not
          managed by Heywood, Middleton & Rochdale PCT but from which its services are
          provided will be the responsibility of the accountable NHS Trust, or the Landlord of
          the property and not of Heywood, Middleton & Rochdale PCT.




                                                                                   Page 3 of 22
      The purpose of CCTV schemes are to help reduce the fear of crime for staff and
      service users/carers (particularly those who are entering and leaving PCT
      premises during the hours of darkness) and to protect PCT staff and premises
      from criminal activities. The particular purposes of all schemes unless specifically
      identified as directed monitoring (Section 4.3 refers) are in accordance with the
      following rationale:

             To assist in the prevention and detection of crime against both persons
              and property;
             To facilitate the identification, apprehension and prosecution of offenders
              in relation to crime;
             To enhance the security of PCT employees and visitors and property
              belonging to Heywood, Middleton & Rochdale PCT.

3.    Roles and Responsibilities

      Heywood, Middleton & Rochdale PCT

3.1   It is the responsibility of Heywood, Middleton & Rochdale PCT as overall owner of
      all schemes:
              To ensure compliance with this Policy;
              To ensure that the operating procedures for all schemes are complied
                with at all times;
              To ensure that the purposes and objectives of all schemes are not
                exceeded;
              To notify all persons on PCT property where CCTV is installed and that a
                CCTV scheme is in operation;
              To facilitate formal subject access requests of any images captured under
                the terms of the Data Protection Act 1998;
              To provide copies of this Policy when required to do so.


3.2   Health, Safety & Security Committee

             Approve all CCTV schemes to be initiated, installed, moved or replaced.
             Review on a regular basis the policy, its operation and the operation of the
              CCTV schemes in association with the Local Security Management
              Specialist (LSMS).
             Investigate any breaches of this policy, using appropriate mechanisms
              which may include the Incident Management, Reporting and Investigation
              Policy or Disciplinary Procedure.




                                                                                Page 4 of 22
3.3   Caldicott Guardian and Senior Information Risk Owner (SIRO)

      Each NHS Trust and Board has an appointed Caldicott Guardian and SIRO who
      have strategic roles for the management of patient information. The Guardian’s
      and SIRO's key responsibilities are to oversee how staff use personal health
      information and ensure that service users’ rights to confidentiality are respected.
      For Heywood, Middleton and Rochdale PCT, the Medical Director is the Caldicott
      Guardian supported by the SIRO.

3.4   Local Security Management Specialist (LSMS)

      The LSMS is a nationally accredited post that has the responsibility for all security
      issues within an NHS Trust and will:

             Assess the appropriateness of, and reasons for, use of CCTV or similar
              surveillance equipment. The assessment process and the reasons for the
              installation of a scheme will be clearly documented;
             Assessment/findings will be shared with the Department involved and
              when agreement is gained forwarded to the Health, Safety & Security
              Committee for approval;
             The purpose of the scheme will be documented in accordance with
              current legislation;
             Asses any request for non-security related personnel to view recorded
              images;
             Ensure viewing of any recorded images occurs within a restricted area;
             Images retained for evidential purposes are stored in a secure place;
             Ensure that any recorded images handed over to the Police or NHS
              Counter Fraud and Security Management Service (CFSMS) in the
              process of their enquires is recorded with the name, station of the police
              officer together with a crime incident or reference number and signature
              are acquired and retained prior to release. The name, address and
              telephone number of the NHS CFSMS must also be obtained. Ensure
              two copies are made, one to be retained by Heywood Middleton &
              Rochdale PCT. In the event of the recording being required for evidence,
              it will be retained for a period recommended by those involved with the
              case;
             Ensure the use of all CCTV is monitored;
             Undertake regular audits and provide advice and guidance on their use;
             Review on a regular basis the policy, its operation and the operation of the
              CCTV schemes in association with the Health, Safety & Security
              Committee;
             Contact the Data Protection Officer immediately of any request to access
              the PCT CCTV systems, stating the nature of their relationship with the
              Trust (for example employee, former employee, patient, visitor,
              contractor).


                                                                                Page 5 of 22
3.5   Head of Estates will:
             Be responsible for the installation and maintenance of approved schemes;
             Ensure cameras and recording equipment are properly maintained in
              accordance with manufacturer’s guidance to ensure clear images are
              recorded;
             Ensure damaged or faulty equipment is repaired or replaced within a
              specified time period and oversee and monitor the quality of the
              maintenance work;
             Maintenance by 3rd party provider organisations are covered under
              separate maintenance contract to the Trust in accordance with this policy;
             Ensure a comprehensive maintenance log is kept of all
              adjustments/alterations/ servicing/non-availability of all individual
              schemes;
             Any tapes on which images have been recorded will be replaced when it
              has become apparent that the quality of images has deteriorated;
             If the system records location/time/date these will be periodically checked
              for accuracy and adjusted accordingly. In the case of alterations due to
              British Summer Time’ the system should, as a matter of course, be
              checked for accuracy;
             At the request of the Manager of a site where tapes are used, ensure an
              adequate supply of labelled media back-up tapes to ensure that a back-up
              cycle can be achieved;
             Ensure a system is in place on those sites where tapes are in use to log
              and retain a copy of the record when (date and time) and who changed
              the back-up tape against the identified tape;
             All back-up tapes to be kept in a secure place and appropriately protected
              against damage from fire, theft, tampering or inappropriate use from either
              members of staff or uninvited visitors;
             Tapes will not be retained for any longer than 31 days from the date of
              recording, erased then re-used. Once a tape has reached its maximum
              use its contents will be erased prior to disposal;
             Liaise bi-annually with all external providers of CCTV Schemes in order to
              monitor the adherence to the agreed SLA;
             Contact the Data Protection Officer immediately of any request to access
              the Trust’s CCTV systems, stating the nature of their relationship with the
              Trust (for example employee, former employee, patient, visitor,
              contractor).




                                                                              Page 6 of 22
3.6   Data Protection Officer (DPO)

      The Data Protection Officer will ensure compliance with the Data Protection Act in
      respect of CCTC and the handling of personal data.

      The PCT, as data controller, is required to comply with the eight principles of good
      information handling (the Data Protection Principles), and to tell the Information
      Commissioner about the types of information held and the purposes for which
      they process personal data.

      In relation to this policy they will:
      In response to a formal request from the data subject, the DPO will permit subject
      access to the images monitored by the system, either in hard copy format or by
      informal viewing. In instances where no recorded images are retained
      (instantaneous viewing only) data subjects will be informed that the system
      produces no recordable images and that subject access in these particular
      instances can only be granted for the purposes of determining the extent of the
      CCTV monitoring range only.

3.7   Manager

      Principal responsibilities of managers are to ensure:

             All security incidents are reported to the LSMS by telephone as soon as
              possible and reported via the incident reporting system;
             Damaged or faulty equipment is reported immediately to the Premises
              and Facilities Manager and recorded on the incident reporting system
             For those sites were tapes are used to record images, ensure a log is kept
              and retained to record when (date and time) and who changed the back-
              up tape against the identified tape;
             Ensure an adequate supply of labelled media back-up tapes to ensure
              that a back-up cycle can be achieved;
             Report the existence of any faulty tapes or if it has become apparent that
              the quality of images has deteriorated; to the Facilities and Premises
              Manager to arrange replacement and disposal;
             All back-up tapes to be kept in a secure place and appropriately protected
              against damage from fire, theft, tampering or inappropriate use from either
              members of staff or uninvited visitors;
             Tapes will not be retained for any longer than 31 days from the date of
              recording, erased then re-used. Once a tape has reached its maximum
              use its contents will be erased prior to disposal;
             Contact the Data Protection Officer immediately of any request to access
              the Trust’s CCTV systems, stating the nature of their relationship with the
              Trust (for example employee, former employee, patient, visitor,
              contractor).


                                                                               Page 7 of 22
3.8   Employees

             Report all security incidents immediately to their Line Manager and in
              accordance with the Incident Management, Reporting and Investigation
              Policy.
             Report any damaged or faulty equipment to their Line Manager
             Do not tamper with, modify or otherwise interfere with any security
              equipment provided.
             Inform their Line Manager and contact the Data Protection Officer
              immediately of any request to access the Trust’s CCTV systems, stating
              the nature of their relationship with the Trust (for example employee,
              former employee, patient, visitor, contractor).


4.    CCTV Schemes

      All CCTV schemes are owned and operated by Heywood, Middleton & Rochdale
      PCT. All cameras, monitors and data collection and retention processes are
      maintained operationally by named individual staff (see Appendix 1). Any further
      maintenance by third party provider organisations are covered under separate
      maintenance contract to the PCT in accordance with this policy. The Local
      Security Management Specialist will monitor the use of all CCTV, undertake
      regular audits and provide advice and guidance on their use

      No CCTV scheme should be initiated, installed, moved or replaced without prior
      approval by the Health, Safety & Security Committee, or someone delegated to
      approve such schemes. The Data Protection Officer must also be informed.


4.1   Principles

      The following principles will govern the operation of all schemes:
           All schemes will be operated fairly and lawfully and only for the defined
              purposes set out in Section 2 and in accordance with Section 4.2.
           All schemes will be operated with due regard for the privacy of all
              individuals at all times.
           Any change to the purposes for which any scheme is operated (Section 2
              & 4.2) will require the prior approval of the Health, Safety & Security
              Committee or a specifically nominated officer.
           All schemes will be monitored and managed in accordance with this policy
              and must be formally approved (as above) prior to any installation.




                                                                            Page 8 of 22
             The person(s) or organisation(s) who are responsible for ensuring the
              day-to-day compliance with the operational requirements of such
              schemes and this policy will be documented.
             The Estates & Facilities Manager is responsible on a day to day basis for
              the appropriateness of CCTV schemes.


4.2   Data Protection Legislation

      Heywood, Middleton & Rochdale PCT will identify and include all its schemes
      within the annual ‘Notification’ process required by the Data Protection Act 1998.

      All schemes will operate in accordance with the guidelines set out in the ‘CCTV
      Code of Practice’ and additional guidance published by the Information
      Commissioner, a copy of which is available from the Data Protection Officer or
      direct from the Information Commissioner’s website
      www.informationcommissioner.gov.uk/eventual.aspx?id=437.

      The Trust must adhere to the following guidelines, to conform to this Code of
      Practice:

      Managers operating such schemes within premises will be responsible for
      overseeing that monitoring of all images, backup, retention, destruction and
      maintenance of all storage media is conducted in accordance with this policy.

      Cameras will not be hidden from view and appropriate steps must be taken, e.g.
      by signing and displaying posters, to inform the public of the presence of the
      system and its ownership at all times.

      To ensure privacy the cameras are fixed and focussed only upon Heywood,
      Middleton & Rochdale PCT property, which must be demonstrable upon specific
      request. Images from the cameras are appropriately recorded in accordance with
      this policy.

      There is no sound recording undertaken from any part of the system.

4.3   Targeted Observation

      Only for specifically defined instances and in accordance with the declared
      purposes and objectives of these schemes, may such surveillance equipment be
      used for targeted observation. The Regulation of Investigatory Powers Act 2000
      regulates the use of covert/directed surveillance of this type and is subject to a
      strict code of practice. Use of CCTV in these instances or for any other reason
      other than that authorised in accordance with this policy is not permissible at any
      time or circumstance. Covert Surveillance is not permitted.



                                                                                Page 9 of 22
4.4   Installation

      The installation of all schemes in accordance with Section 4.2 will remain
      appropriate to its original identified and documented business purpose in
      accordance with this policy.

4.5   Subject Access

      Only the Data Protection Officer, in response to a formal request from the data
      subject, will permit subject access to the images monitored by the system either in
      hard copy format or by informal viewing. In instances where no recorded images
      are retained (instantaneous viewing only) data subjects will be informed that the
      system produces no recordable images and that subject access in these particular
      instances can only be granted for the purposes of determining the extent of the
      CCTV monitoring range only.

      Individuals wishing to access images from the system or formal subject access
      requests specifically relating to CCTV must write to Heywood, Middleton &
      Rochdale PCT; Data Protection Officer.


4.6   Procedures for Accessing Subject Access Requests

      Subjects who wish to access Heywood, Middleton & Rochdale PCT CCTV
      systems must contact the PCT Data Protection Officer and must state the nature
      of their relationship with the Trust (for example employee, former employee,
      patient, visitor, contractor).

      Any member of staff receiving such a request must forward it immediately to the
      Data Protection Officer.


4.7   Breaches of this Policy

      Heywood, Middleton & Rochdale PCT, via the Health, Safety & Security
      Committee, will investigate any breaches of this policy, using appropriate
      mechanisms which may include the Incident Reporting Policy or Disciplinary
      procedure.

      As a major purpose of these schemes is in assisting to safeguard the health,
      safety and security of staff, service users and visitors (Section 2 refers), it should
      be noted that intentional or reckless interference with any part of any monitoring
      equipment, including cameras/monitor/back-up media, may result in disciplinary
      action and may also be a criminal offence.


                                                                                 Page 10 of 22
4.8   Complaints Procedure

      Grievances and complaints regarding the operation of Heywood, Middleton &
      Rochdale PCT CCTV system should in the first instance be progressed by the
      PCT complaints process.


5.    Training & Training Needs

             All operators of CCTV equipment will be trained in their responsibilities in
              accordance with this Policy.

             All staff involved in the handling of the CCTV equipment, both directly
              employed and contracted, will be made aware of the sensitivity of
              handling CCTV images and recordings.

             Guidance in the requirements of the law on Data Protection will be given
              to staff who are required to manage and work the CCTV systems

             Staff will be fully briefed and trained in respect of all functions, both
              operational and administrative relating to CCTV control operation.

             Training by camera installers will also be provided as appropriate.


6.    Monitoring and Review

      The effectiveness of this policy will be monitored by Incident Reports and analysis
      submitted to the Health, Safety & Security Committee and the Quality Committee.

      This Policy will be reviewed on an regular basis by the Health, Safety & Security
      Committee, or subject to any change in legislation or national directives.

      Incidents involving a breach of the DPA and anonomised statistics of subject
      access requests will be presented to the Information Management Group for
      monitoring or action.




                                                                                  Page 11 of 22
7.   Dissemination & Implementation

     The policy will be placed on the policies section of the PCT Intranet site. All staff
     will be notified of the policy via the Team Briefing and via their Heads of Service.

     A general awareness of this policy will be promoted via the Risk
     Management/Health & Safety training but it is the responsibility of all Managers to
     ensure staff understanding and implementation of this policy. The Local Security
     Management Specialist will attend Team Briefings/Team Meetings to delivery
     further training if required.




                                                                                Page 12 of 22
    APPENDIX 1




    CCTV Schemes Currently in Operation

                                          No of        No of
                                                                                  Date       Operational        3rd Party
Scheme                                    Recordable   Viewing
          Location/Address   Purpose                             Scheme Manager   Scheme     Responsible        Maintenace
Ref No.                                   Cameras      only
                                                                                  Approved   Officer(s)         Contractor
                                                       Cameras




                                                                                                       Page 13 of 22
  APPENDIX 2



  Installation Checklist
                                                                 Date
The Health, Safety & Security Committee or persons
with delegated responsibility has approved the
installation/alteration of the camera site.
The purpose for the installation/adjustments have been
clearly documented
The organisation that is legally responsible for the
CCTV scheme has been established
Equipment is situated so it can only monitor the
intended area of coverage as defined in scheme
proposal
The cameras are not positioned anywhere that would
be considered private e.g. office, toilet
Signs are in place showing that CCTV systems are in
operations and that the owner of the systems name
and contact details are clearly displayed
Cameras have been positioned to avoid capturing the
images of persons not visiting the premises
The recorded images are stored securely with strictly
controlled access procedures in place
The recorded images are stored securely and for no
longer than 31 days
A procedure is in place for operational equipment to be
checked regularly to ensure it is in working order
Images will only be made available to law enforcement
agencies involved in the prevention and detection of
crime and no other third party, appropriate procedures
in place via referral to the PCT DPO
A procedure is in place for dealing with individuals
requesting access to CCTV footage. (Not law
enforcement agencies)
An appropriate confidential disposal procedure of tapes
is in place where appropriate.


  Name: ……………………………………

  Designation: …………………………….

  Date: …………………………………….




                                                              Page 14 of 22
APPENDIX 3


Access to View or Copy Tapes – Police and CFSMS
Name and rank of person
making request:

Organisation:

Address:

Telephone Number:

Details of Tape/Recording to be Viewed
Date:

Reason:
(For police only)


Signed:                                              Dated:

Request Granted:                                     Request
                                                     Denied
                                                     (Reason):

To be completed if Tape Removed from Circulation
Tape No.

Issued To:

Crime No: (For police only)

Date Issued:

Issued By:

Return Date:

I acknowledge receipt of the above tape/recording:

Signed:                                              Date:

Original signed copy to be kept on file.

                                                                 Page 15 of 22
                                                                                            APPENDIX 4




APPLICATION FOR ACCESS TO RECORDED IMAGES (subject access request)

         SECTION 1                  About you

The information requested below is to help Heywood Middleton & Rochdale PCT to:
   a) satisfy itself as to your identity and
   b) find any relevant images you have requested


             Title (tick box)         Mr            Mrs               Miss             Ms
        Other title (e.g. Dr, Rev
        etc)
        Surname/family name
        First name/s
        Maiden name/former
        name
        Sex (tick box)                  Male                           Female
        Height
        Date of birth
        Place of birth               Town
                                     County

        Your current home
        address (to which we will
        reply)
                                      Post code
        A telephone number will       Tel No:
        be helpful in case we
        need to contact you

If you have lived at the above address for less than 10 years, please give your previous address(es) for
this period

        Previous address(es)



        Dates of occupancy           From                           To



        Dates of occupancy           From                           To




                                                                                              Page 16 of 22
SECTION 2               Proof of identity


To help establish your identity, your application must be accompanied by TWO official
documents that, between them, show your name, date of birth and current address and
recent photograph

For example, birth/adoption certificate, driving licence, medical card, passport or other
official document that shows your name, address and recent photograph.

The PCT may ask for further evidence if it is not satisfied as to your identity.

Failure to provide this proof of identity may delay your application


SECTION 3                Supply of information


You have a right, subject to certain exceptions, to receive a copy of the information in a
permanent form. Do you wish to:

    a) view the information and receive a permanent copy

   b) only view the information

Delete as appropriate

SECTION 4               To help us find the information

Are you (tick below):

The person reporting an (alleged) offence or
incident

The witness to an (alleged) offence or incident

The victim of an (alleged) offence

The person accused or convicted of an offence

Other – please explain




                                                                                     Page 17 of 22
        SECTION 4 - cont/d…



       Date(s) and time(s) of
       incident
                                      Building
       Place incident happened
                                      Street

                                      Town

                                      Post Code


       Brief details of incident




        SECTION 5           Declaration
        DECLARATION (To be signed by the applicant)

        I have read and understood the accompanying Policy explaining Heywood, Middleton &
        Rochdale's policy in relation to the purpose of CCTV surveillance and the arrangements
        for access to recorded images.

        I certify that the information that I have supplied in this application is true and accurate
        and that I am the person to whom it relates.

        I understand that it is necessary for Heywood, Middleton & Rochdale to confirm my
        identity and that it may be necessary to obtain more detailed information in order to
        locate the correct information.

        I enclose a non-refundable payment of £10 for the search to be completed.

        Signed by
                                                 Date
        WARNING: A PERSON WHO IMPERSONATES OR ATTEMPTS TO IMPERSONATE
        ANOTHER MAY BE GUILTY OF AN OFFENCE


        Please ensure that all Sections are completed before returning the form



Use separate sheets if required

                                                                                                  Page 18 of 22
        Before returning this             Have you completed ALL sections of this form?
        form, please check:
                                          Have you enclosed TWO identification documents?

                                          Have you signed and dated the form?

                                          Have you enclosed the £10.00 (ten pound) fee?

                                          Have you included a stamped addressed envelope for
                                           the return of proof of identity/authority documents
                                           (where appropriate)?

NOTE: Heywood, Middleton & Rochdale PCT reserves the right to obscure or suppress information
relating to other third parties (under the terms of the Data Protection Act 1998)



        Further information:

Further information and advice may be obtained from:

                        Information Commissioner
                        Wycliffe House
                        Water Lane
                        Wilmslow
                        Cheshire
                        SK9 5AF
                        Tel: (01625) 545745


Please note that this application for access to information must be made direct to Heywood, Middleton &
Rochdale PCT and NOT to the Data Protection Commissioner.



A written response to your application will be made within 40 days.




                                                                                            Page 19 of 22
              Equality Impact Assessment Initial Screening Tool
 This Initial Screening Tool is the first step in completing an Equality Impact Assessment
 (EIA) of your ‘activity’ (strategies, functions, policies, procedures, projects, services etc).
 Once this is completed, it will be apparent whether or not a full EIA is required.
 This proforma should be used in conjunction with the EIA Guidance and the Trust’s
 Single Equality Scheme, and copies of some already completed EIAs.

 Please note: this document will be published on the internet/intranet with your policy.

1. Directorate                                  Commissioning
2. Department                                   Clinical Quality & Standards
3. Name of ‘activity’ being assessed            CCTV Policy
4. Job title of person completing this form     H&S Advisor/LSMS
5. Date                                         09/11/10
6. Data & stats – this section explain who are the population who are affected
Patient                                         Staff
To ensure that the PCT staff understand and To ensure that the PCT staff understand and
comply with legislation including the Data      comply with legislation including the Data
Protection Act; Human Rights Act 1998,          Protection Act; Human Rights Act 1998,
Regulation Investigatory Powers Acts 2000       Regulation Investigatory Powers Acts 2000
and other relevant legislation and that CCTV and other relevant legislation and that CCTV
systems are not abused or misused.              systems are not abused or misused.

                                  7. Which of the following Equality     8. Could this ‘activity’
   Equality Target Groups
                                   Target Groups will this ‘activity’    have a positive and/or
           (ETGs)
                                  impact on? (see Guidance pg 3)           negative impact?
    (see Guidance pg 2)
                                        Yes                  No          Positive* Negative*
A. Age                                  X                                    X
B. Disability                           X                                  X
C. Gender/incTransgender                X                                  X
D. Race inc                             X                                  X
Gypsy/Roma/Traveller
E. Religion/Belief                     X                                 X
F. Sexual Orientation                  X                                 X
G. Carers
H. Lower socio economic                X                                 X
groups
I. Pregnancy/maternity                 X                                 X
9. Consultation/Involvement – during the development of this activity? (see Guidance pg 3)
Who have you worked with to develop this policy?
Issued for comment to: Information Governance Manager; IT Security Manager; Health,
Safety & Security Committee, Nurse Director/Director of Clinical Quality & Innovation; Head
of Operations & Facilities Management; Head of Estates, IT Security Manager, Deputy
Chief Operating Officer CHC HMR; CHC HS&S Committee; JNCC


                                                                                    Page 20 of 22
10. Details of positive and negative impacts
Positive Impacts                                Negative Impacts
Implementation of this policy will ensure
Data Protection and Human Rights
legislation is not breached, whilst assisting
in the detection and prevention of crime and
enhancing staff security and safety.
11. Give details of actions required to remedy any negative impact(s) identified above.
                          Action                                Who              Target Date
A. n/a
B.                 n/a


 12. If the actions in 11 above are
                                                             A     B    C    D    E    F    G    H     I
 completed… (Mark with ‘x’ for Yes)
                   1. Will the activity present any
                   problems or barriers to any
 Negative Impact




                   community or group?
                   2. Will any group of people be
                   excluded as a result of your activity?
                   3. Does the activity have the potential
                   to worsen existing discrimination and
                   inequality?
                   4. Will the activity have a negative
                   effect on community relations?
                   Objective Justification
                   If you are saying yes to any of the above questions then can you justify it here – it
                   may be absolutely the right thing to prioritise one group over another but you need to
                   explain why and justify it here so that we are clear about this. It is illegal to
                   discriminate against anyone so we need to be thorough here. An example might be if
                   we realise that more young women smoke and we want to specifically target activity
                   at that group because evidence shows that we need to to reduce health inequalities
                   then say that and show the evidence.
                   Could the activity reduce
                   inequalities? Will it… (Mark with ‘x’     A     B    C    D    E    F    G    H     I
                   for Yes)
 Positive impact




                   5. Promote equality of
                   opportunity?
                   6. Eliminate discrimination?
                   7. Eliminate harassment?
                   8. Promote good community
                   relations?
                   9. Promote positive attitudes
                   towards disabled people?
                                                                                             Page 21 of 22
   10. Encourage the participation of
   disabled people?
   11. Consider more favourable
   treatment of disabled people?

Decision
Work through the flowchart, to determine whether you need to complete a Full EIA or not.

Full EIA required? Yes           No X                Date completed        09/11/10
   12. Promote and protect human
   rights?




                                                                            Page 22 of 22

								
To top