Camera code of practice

1 Definitions

In this code of practice the following definitions are used:c

2 Introduction

Closed Circuit Television (CCTV) plays an important role in helping the council maintain a safe and secure environment for everyone. This code of practice explains how we use CCTV systems across our sites and public spaces to support community safety, prevent and detect crime, and manage our services effectively.

We are committed to using CCTV responsibly, lawfully, and transparently. This means making sure that any images we capture are handled in line with data protection laws and only used for legitimate purposes. We also want to make sure that residents, visitors, and staff understand how and why CCTV is used, and what their rights are.

This code of practice uses the term “CCTV” to refer to all forms of surveillance camera systems as this is the term most widely known by the public.

2.1 Purpose of this code of practice

The primary purpose of the use of CCTV is to contribute to improving public safety and security, protecting both people and property, prevention and investigation of crime and to be used as evidence in order to seek justice related to unlawful acts. CCTV shall only be used as a necessary and proportionate response to identified problems.

The council have established this code of practice which sets out the governance arrangements that all surveillance schemes must comply with. This ensures the principles, purposes, operation, and management adopted by the main public-space CCTV systems are mirrored across all council service delivery areas. Use of such systems should be used responsibly with effective safeguards in place to maintain public trust and confidence.

Public space CCTV monitors locations throughout the town centre and public open spaces. Operations are managed from a secure, centralised control and monitoring centre (CMC) located at a Blackpool south shore location. The CMC is based within an access controlled facility and is staffed by trained and accredited personnel, with support being provided by police vetted volunteers.

By following this code of practice, Blackpool Council will:

• Help ensure that those working with CCTV comply with the relevant legislation and the wider regulations
• Make sure that the information captured is usable and can meet the objectives of any CCTV system operated by the council
• Reduce reputational risks by working within the law and avoiding regulatory action or penalties
• Reassure those whose image or information is being captured by the system
• Help to generate the wider public trust and confidence in the use of CCTV

This code of practice governs the operation of public space CCTV by Blackpool Council, as well as any other council-owned systems that record images or data capable of identifying individuals. It applies to camera- related surveillance equipment, including but not limited to the following devices:

• Town centre CCTV system;
• Automatic Number Plate Recognition (ANPR);
• Body worn video cameras (BWVC);
• Stand-alone systems in council offices or at council assets such as Customer First, libraries, leisure centres or car parks
• Cameras in council owned vehicles; including wholly owned company fleet vehicles such as the ones used by Enveco
• Cameras used to assist in traffic flow management and maintaining highways

This code of practice also covers the use of images or information captured by the Blackpool CCTV systems when they are provided to the media.

This code of practice:

• Does not apply to covert (hidden) cameras or direct surveillance
• Does not apply to schools within the Blackpool area as schools are data controllers in their own right

2.2 Regulatory framework

All of the council’s surveillance camera systems will be operated on a lawful basis and will be fully compliant with the requirements of the Data Protection Act 2018 (DPA) and the UK General Data Protection Regulation (UK GDPR). This code of practice also helps CCTV operators meet their legal and regulatory duties, including organisational obligations under the following relevant laws.

• Data (Use and Access) Act 2025
• Human Rights Act (HRA) 1998
• Freedom of Information Act (FOI) 2000
• The Human Rights Act (HRA) 1998
• The Protection of Freedoms Act (POFA) 2012
• The Crime & Disorder Act (CDA) 1998
• Criminal Justice and Public Order Act (CJPO) 1994
• Regulation of Investigatory Powers Act (RIPA) 2000

CCTV systems will be operated with respect to all individuals, without any discrimination on the grounds of gender, race, colour, language, religion, political opinion, national or social origin or sexual orientation.

2.3 Ownership, accountability and maintaining transparency

The CCTV systems are owned by Blackpool Council who are responsible for its management and security. To ensure compliance with data protection legislation and the requirements of the Home Office’s Surveillance Camera Code of Practice, Blackpool Council will:

• Make this code of practice available to the public
• Tell people how they can make a subject access request; and
• Tell them how to raise concerns or complain about the operation of CCTV

We will let people know that we are operating CCTV by placing signs in the areas where this is in place. Signs will be prominently placed to advise people that CCTV cameras are in operation and the signs will indicate its presence, who is responsible and a point of contact for the council.

For the town centre system, we will place clear and prominent signage on street furniture such as lamp posts. Where CCTV is in use in areas where there is a higher expectation of privacy, such as a council building or facility such as a leisure centre, we will ensure there is appropriate signage at the entry points.

Where CCTV or ANPR is in more permanent use on the road network or car parks within Blackpool, we will ensure that appropriate signage is in place. We will endeavour to ensure that these do not affect road safety and we will consider the time that a driver has to read the information on the signs.

2.4 Point of contact

To ensure that CCTV systems are compliant with this code and in order to avoid scenarios of misuse, the council have the following points of contact:

• Data protection officer - PO Box 4, Blackpool, FY1 1NA dataprotectionofficer@blackpool.gov.uk
• Security, CCTV and civil enforcement manager - PO Box 4, Blackpool, FY1 1NA dpa@blackpool.gov.uk

3 Blackpool Council CCTV

While CCTV contributes to public safety, it also raises considerations regarding privacy. Blackpool Council remains dedicated to ensuring CCTV usage complies with legal standards and is managed responsibly, maintaining an appropriate balance between security and individual rights.

3.1 Why we use CCTV

The overarching purpose of the camera systems operated by Blackpool Council is to assist with making Blackpool a safe environment for its residents, visitors and the business community.

Other additional purposes for operating various types of CCTV include:

• Reducing fear of crime and provide reassurance to the public
• Supporting public safety in places where people live, work, shop, and visit
• Helping protect council staff and elected members
• Support the investigation of crime, antisocial behaviour, and public disorder
• Assisting the police and council in gathering evidence for legal action
• Managing town centre activities and traffic flow
• Supporting Blackpool’s economy and tourism
• Responding to emergencies and national security concerns such as acts of terrorism

3.2 What we aim to achieve

Our key goals for using CCTV include:

• To improve the perception of the public in respect of the safety of the town centre
• To help reduce the amount of crime, including vehicle crime and shoplifting
• To help reduce the number and type of antisocial street activities, g. flyposting, begging, illegal street ttrading, vandalism, drunken behaviour
• To support a better detection of crime in areas covered by CCTV cameras and provide evidential material
• For any subsequent prosecution in court
• To assist in traffic management (this excludes speed cameras)
• To assist the council in its enforcement and regulatory functions within Blackpool
• To improve general security within council, both in terms of personal security and security of the buildings and assets
• To improve general security in the main retail streets, both in terms of personal security and security of buildings and premises
• To assist in making the town and town centre a more attractive place in which to work, shop and play
• To assist with visitor economy g. lost children, the management of major events held within the town
• To maintain the basic fundamentals of an individual’s right to privacy, dress and reasonable behaviour

3.3 When and why we use CCTV

Blackpool Council recognises that using CCTV can affect people’s privacy, so it does not install cameras just because it is possible, affordable, or popular. Instead, the council carefully considers whether CCTV is the right solution for a particular problem. For example, if cars are being damaged in a car park, the council might consider whether better lighting would be more effective than installing cameras.

The council has undertaken a Data Protection Impact Assessment (DPIA) for its use of CCTV and regularly reviews it. This assessment looks at why the cameras are needed, what problems they are meant to solve, what benefits they will bring, whether there are other ways to achieve the same result, and what impact the cameras might have on people’s privacy. The council also considers whether it needs to consult with people who will be affected and whether there are any risks in collecting, storing, or sharing the images.

Once a CCTV system is in place, the council regularly reviews whether it is still needed and whether it is being used appropriately. The council follows the data protection principles (see Appendix 1) and the Home Office’s Surveillance Camera code of practice (see Appendix 2).

3.4 Breach of this code of practice

System users who operate cameras shall adhere to the highest standards of integrity, ensuring that all camera usage and recordings are strictly limited to the purposes and objectives outlined in this code of practice.

Any misuse of CCTV, monitoring or recording equipment including taking pictures or downloading material for unauthorised use or unlawful sharing is prohibited and could lead to disciplinary action, result in dismissal or a criminal prosecution.

3.5 Blackpool Council – data protection registration

Blackpool Council is obliged to comply with the UK General Data Protection Regulation and Data Protection Act 2018, and is registered with the Information Commissioner’s Office (ICO) as it handles personal data, including images and information captured by CCTV.

The registration number is Z5720508

4 Governance

4.1 Who’s responsible

Blackpool Council is responsible for all CCTV systems it operates. We are the system operator and data controller as defined in the DPA 2018 and UK GDPR, which means we:

• Decide how CCTV is used
• Ensure it complies with data protection laws

For some of the CCTV, more than one organisation will be involved. The day-to-day operation of the public spaces CCTV is in partnership with Blackpool Business Improvement District (BID) and Lancashire Constabulary.

The council may provide a ‘live feed’ to the Lancashire Constabulary control room or allow relevant staff to access the control and monitoring centre (CMC) when it relates to a high profile event or an ongoing incident.

When we share live footage we make sure:

• Partners are registered with the Information Commissioner’s Office (ICO)
• We enter into a suitable written data sharing agreement (DSA) or contract that defines how information will be transferred, includes guarantees about storage and security of the images and all staff are properly trained
• Everyone involved understands their responsibilities and obligations

If the council enters into a contract with another organisation or company to assist with processing the images, for example, if they need to be edited or blurred before disclosure, this contract will include specific instructions on the processing, define responsibilities, require audits or inspections to ensure compliance, and detail an appropriately named individual for the contract.

4.2 Defining our procedures

We have clear procedures for each type of CCTV system. These include:

• Why the cameras are used
• How footage is handled and stored
• Who can access the footage
• How disclosures are managed
• Who is responsible for compliance
• How we carry out regular checks and audits

We also follow guidance from national regulators like the Information Commissioner’s Office (ICO) and the Biometrics and Surveillance Camera Commissioner.

4.3 Management, operation and information sharing of CCTV

4.3.1 Use of equipment

Blackpool Council is aware that using CCTV has the potential to be intrusive on an individual’s privacy and therefore we carefully consider the use of the different types of systems available before using them.

For public spaces CCTV equipment operates in colour and information produced is of a suitable quality to meet the purpose that it was installed for. The council use both fixed cameras and those that have pan, tilt and zoom facilities.

• Pan - can be moved from left to right through 360 degrees
• Tilt - can be moved up or down
• Zoom - enables the system operator using a ‘joystick’ as a control console to view close up images to obtain greater detail or for a panoramic perspective

Upon installation and routine maintenance checks of any equipment, we will we ask:

• If the CCTV produces clear, quality information that is maintained throughout the recording process
• Whether we need to compress the recorded material and if so, determine if this will result in a lower picture quality
• If we have set up the recording systems in a way that prevent inadvertent corruption
• Whether the date and time stamp on recorded images to ensure it is accurate
• What the maintenance regime should be and if it is sufficient to maintain high quality information
• If any wireless transmissions we use are secure and if we have the ability to encrypt the information
• If the ANPR systems used for matching information are accurate

We will ensure that images and information will be protected, including technical, organisational and physical security measures to assist with this. Such measures include:

• Protect any wireless transmissions to safeguard it from interception
• Apply software updates to the CCTV when necessary
• Restrict who can make copies of information
• Ensure that the deletion process is effective and adhered to
• Secure the control room and the facilities where the information is stored digitally
• Train those using the CCTV in security procedures and sanction those who misuse the CCTV
• Ensure those using and operating CCTV are aware that they could be committing a criminal offence if they misuse the CCTV

4.3.2 Camera locations

The decision to use any surveillance camera technology must be consistent with a legitimate aim and will only be deployed when it is a justified and proportionate response to protect members of the public. It will not be used for arbitrary or unlawful forms of surveillance.

To assist our decision making process for the use of the public spaces CCTV system, we regularly review assessments of the impact of CCTV on an individual's privacy. This is undertaken through the Surveillance Camera Commissioner's Self-Assessment process and through the completion of a Data Protection Impact Assessment (DPIA). These assessments enable us to consider the wider context as well as the legislation. Access to these assessments.

Once CCTV is in use, we will regularly evaluate the continuing use of the particular system to determine if it is still justified and the DPIA will be updated to reflect changes with cameras or technology.

A general description of the locations of the council’s public area cameras can be found within the ‘Public space CCTV data privacy impact assessment’. Please note, these cameras do not record sound.

4.3.3 Storing of CCTV information

Blackpool Council will store any images captured in a way that maintains the integrity of this information and in line with nationally recognised standards.

CCTV footage is stored digitally on secure digital video recorders (DVRs) and other electronic storage devices, which are encrypted when possible. These storage devices are located within council buildings or assets where access to both the physical building and the storage device is restricted. The council takes all reasonable steps to prevent unauthorised access to images and information.

As the council’s CCTV includes different types of equipment including mobile devices, we are required to download and store images captured by these devices. When the images are downloaded from such devices, they are stored on encrypted electronic storage.

4.3.4 CCTV retention

Generally, the council retains CCTV images and information for one month from the date of capture, or twelve months for retrospectively downloaded footage. Retention periods may change if footage is required as evidence. Any variation due to different types of CCTV will be indicated in specific procedures. After the applicable retention period expires, footage is deleted either automatically through CCTV system settings or manually if automation is not available.

Information about retention is detailed in the corporate retention schedule which is published on the council website.

4.3.5 Viewing CCTV information

General operational viewing of the images and information, i.e. live or real-time viewing, will be managed securely within the council buildings or assets, and will require dedicated software to facilitate viewing directly from the system. It will be restricted to the System Users and where appropriate, other authorised persons.

Viewing monitors will not be placed in locations which can be viewed by the public.

4.3.6 Disclosure

The council will manage the disclosure of information from its CCTV system in accordance with the specified purposes for which it is used. Access to retained images and related information shall be strictly limited, with explicit procedures governing who may access such data and the reasons for granting access. Disclosure will only occur when necessary to fulfil these purposes or for law enforcement requirements.

The council reserves the right to decline requests for information disclosure unless a legal duty exists—such as statutory information access rights (e.g., Subject Access Rights, Freedom of Information) or compliance with a court order.

Decisions regarding disclosure rest solely with Blackpool council, which acts as the data controller for CCTV. Comprehensive records of all disclosures made to third parties must be maintained.

4.3.7 Law enforcement requests

The police may request, through the police officer in charge, that a particular time/area be viewed by the CCTV operator in the following circumstances:

• To assist in the event of a major incident or emergency
• To assist in the detection of crime
• To assist in an arrest and gathering of evidence so that offenders may be prosecuted in relation to criminal or public order incidents
• To provide information in relation to traffic flow within town centres
• To assist in the search for very young, old or mentally ill individuals

CCTV requests received from Lancashire Constabulary are processed and shared (if applicable) via the use of NICE’s Digital Evidence Management system. Access is by an individual portal account log where an email and password is required. Details within the CCTV request application requires the requestor to include their name, collar number, phone number, email address and the details of/reason for the request. Each request is considered by the CCTV control room manager or another designated manager and the lawful basis for sharing recorded with disclosure undertaken only when it is established that the request is reasonable, legitimate, necessary and proportionate.

Once the council have disclosed images or information to another, they will become the data controller for their copy. It is then their responsibility to comply with all relevant legislation to keep this copy safe and secure.

4.3.8 Subject access requests

Individuals whose images and information are recorded by CCTV have a right under the DPA and UK GDPR, to be provided with a copy of this. This is known as a Right of Access or, more commonly a Subject Access Request or SAR.

The council must respond within one month, or up to three months if the request is complex. The person making the request must provide enough information to identify themselves and the relevant time and place. If other people appear in the images, their faces may be blurred to protect their privacy.

Examples where editing may or may not apply are:

• People entering an office or reception are more likely to have a higher expectation of privacy and confidentiality and the images of another third party will need to be edited or blurred before

• The images of a group of friends waving at a town centre camera can be released to one of the group if they request this, without editing or blurring their friend’s images as they have a lower expectation of privacy. The reason is that their actions indicate that they knew the camera was there and they are in a public space.

In summary, the council will ensure that all subject access requests are handled in line with its own procedures and that these comply with the legislation.

4.3.9 Freedom of information requests

As a public authority, Blackpool Council is required to comply with requests for information submitted under the Freedom of Information Act (FOI) 2000.

We have members of staff trained to handle and respond FOI requests who understand the council’s responsibilities to respond within the legislated timescale of 20 working days from receipt of the request.

For the CCTV service, the majority of FOI requests are for an individual’s image captured by the CCTV system. These can fall into two categories and are considered in conjunction with Section 40 of the FOI:

• If the images or information is the personal data of the person making the request, then it is exempt from FOI and will be treated as a Subject Access Request
• If the images or information are personal data of another person, a third party, then this will only be disclosed if this would not breach the data protection principles

In these instances, the council will consider if disclosure is appropriate but it is generally unlikely that others images will be disclosed as this would mean that the images could then be used for any purpose and this would be outside the registered purpose of the CCTV and the individual’s expectations.

All other requests, for example, where a person asks about the costs of the CCTV or the operation of it, will be dealt with under FOI. Disclosure will be subject to any exemptions that may apply.

4.3.10 Regulation of Investigatory Powers Act (RIPA) requests

From time to time, the council will receive a request that has been authorised under the Regulation of Investigatory Powers Act (RIPA) 2000. These requests will outline particular circumstances and locations for camera placement to capture images or gather information, which may include covert operations.

All covert surveillance carried out by public authorities where that surveillance is likely to result in the obtaining of private information about a person will be processed using the appropriate level of authority for the specified recording and subsequent disclosure. An audit record of all such requests will be maintained.

More information regarding Blackpool council's use of RIPA policy can be found in our covert surveillance policy and guidance.

5 Other technologies

As video surveillance technology develops, it is now more common to see innovative solutions driven by increased security needs such as smart doorbells and wireless cameras. Traditional closed circuit television (CCTV) also continues to evolve into more complex Artificial Intelligence (AI) based surveillance systems. This includes connected databases utilising Automatic Number Plate Recognition (ANPR) or the use of Facial Recognition Technology (FRT) in public spaces.

5.1 Body worn video cameras (BWVC)

Body worn video cameras (BWVC) are small, visible devices that are worn as an attachment on the body of the staff member. They are used to capture both video and audio evidence when staff are attending any enforcement related activities. The position of the camera allows for those viewing the footage to see the situation from the staff’s perspective. The camera acts as an independent witness to interactions in an unbiased and secure recording.

The council acknowledges that BWVC’s may have a greater impact on privacy compared to traditional CCTV and will ensure that privacy considerations are reviewed prior to deployment. All system operators will receive training in the use of BVWC’s. They will also be provided with a ‘Body Worn Video CCTV Policy’ and services will also receive a bespoke body worn video procedure. This will include all practical use of the equipment, guidance and best practices. It will also include when to commence and cease recording and the law around the use of BWVC’s as a mobile surveillance camera system.

Because these types of CCTV are portable, we will ensure that there are robust technical and physical security measures in place to protect the images and information captured, and prevent unauthorised access.

When the employees return to their office, the images and information are downloaded to a secure storage facility, and later deleted in line with our published retention schedule.

5.2 Automatic Number Plate Recognition (ANPR)

Blackpool Council recognises that ANPR can collect a considerable amount of information and therefore, it will only be used where this is justified following consideration of the impact that the use may have on an individual’s privacy.

ANPR use is a staple in traffic management and bus lane enforcement. It uses high-speed image capture to identify number plates as they pass by an infra-red camera. The license plates are then cross-referenced against a database, checking for inconsistencies, information, or usage, depending on the application. Many council car parks use ANPR to monitor the length of time a vehicle was parked and if the parking fee was paid, which can be done by connecting the system to the database from the car park ticket machine.

The council will ensure that individuals are informed where ANPR is in use in fixed locations such as a car park entrance/exit barrier. This will be through signage that explains ANPR is in use, and stating that the council is the data controller.

5.3 Stand-alone CCTV

Blackpool Council operates CCTV in its offices and facilities, including libraries, leisure centres, and the household waste recycling centre, managed by Enveco.

Some of these are connected to the main control and monitoring centre (CMC) and images or information is recorded on the main digital video recorder (DVRs). However, a number of these are stand-alone CCTV. This means that the recordings are held within the particular office or asset and can only be accessed by authorised council employees trained to operate that system.

Where we use stand-alone CCTV, we avoid continual monitoring of the images as far as possible. We will access the recordings to view and provide copies of the images and information when this is necessary and in line with legislation.

5.4 Vehicle cameras

Some Blackpool Council vehicles are fitted with cameras that record externally from the vehicle. Its use is primarily to assist in the collection of evidential material for use in insurance claims, but can be used for other purposes such as the prevention and detection of crime.

Vehicle cameras will be installed when appropriate in vehicles and are set up in a way that ensures that there is minimal intrusion of privacy, and that any intrusion is justified. The recorded images are held for 30 days before being wiped. Footage that is part of an investigation is kept for at least 3 years for insurance claims.

5.5 Traffic monitoring cameras

To assist with the management of traffic flow and the provision of traffic information to those who drive in Blackpool, the council has a number of cameras that capture block images of traffic (no specific personal details are captured). This information is utilised in the update information provided on the electronic information signs located around the town.

The images from these cameras will be captured on a 10 second recording loop which is automatically over- written. We cannot provide images from these cameras.

6 Other responsibilities

6.1 Informing the public

We make sure people know when CCTV is in use by placing clear signs in relevant areas.

• Town centre: Signs are placed on lamp posts and other street furniture
• Council buildings: Signs are displayed at entrances and reception areas

Signs include:

• A clear message that CCTV is operating
• Blackpool Council’s name as the system owner
• Contact details (phone number or website)
• Appropriate size and visibility for the location

6.2 Road signage

Where cameras (including ANPR) are used on roads or in car parks:

• We install signs that are easy to read and don’t distract drivers
• Signs clearly state that cameras are in use and who operates them
• If we use authorised signs under the road traffic sign regulations, we will ensure that these are permitted under the Town and Country Planning (control of advertisements) Regulations 2007

6.3 Protecting your rights

The council acknowledges that there are further key rights that individuals have under data protection legislation (DPA 2018 and UK GDPR) which the council will make the system users aware of. We train our staff (System Users) to understand and respect your rights under data protection laws, including:

• The right to prevent processing that causes distress
• The right to prevent automated decisions that affect you

If an individual exercises these rights, the council’s information governance team will advise on how to process the requests.

The service can be contacted by telephone on: 01253 478980, available from 9.00am to 4.00pm, Monday to Friday. By email at informationgovernance@blackpool.gov.uk or by Post at Blackpool Council, PO Box 4, Blackpool, FY1 1NA.

6.4 Licensing and compliance

Most council CCTV covers public spaces. To comply with the law:

• Staff operating public space CCTV must hold a valid licence from the Security Industry Authority (SIA).
• Any contractors we use must also be properly licensed under the Private Security Industry Act

Appendix 1

The guiding principles of the surveillance camera code of practice

System operators should adopt the following 12 guiding principles:

1. Use of a surveillance camera system must always be for a specified purpose which is in pursuit of a legitimate aim and necessary to meet an identified pressing need
2. The use of a surveillance camera system must take into account its effect on individuals and their privacy, with regular reviews to ensure its use remains justified
3. There must be as much transparency in the use of a surveillance camera system as possible, including a published contact point for access to information and complaints
4. There must be clear responsibility and accountability for all surveillance camera system activities including images and information collected, held and used
5. Clear rules, policies and procedures must be in place before a surveillance camera system is used, and these must be communicated to all who need to comply with them
6. No more images and information should be stored than that which is strictly required for the stated purpose of a surveillance camera system, and such images and information should be deleted once their purposes have been discharged
7. Access to retained images and information should be restricted and there must be clearly defined rules on who can gain access and for what purpose such access is granted; the disclosure of images and information should only take place when it is necessary for such a purpose or for law enforcement
8. Surveillance camera system operators should consider any approved operational, technical and competency standards relevant to a system and its purpose and work to meet and maintain those
9. Surveillance camera system images and information should be subject to appropriate security measures to safeguard against unauthorised access and use
10. There should be effective review and audit mechanisms to ensure legal requirements, policies and standards are complied with in practice, and regular reports should be published
11. When the use of a surveillance camera system is in pursuit of a legitimate aim, and there is a pressing need for its use, it should then be used in the most effective way to support public safety and law enforcement with the aim of processing images and information of evidential value
12. Any information used to support a surveillance camera system which compares against a reference database for matching purposes should be accurate and kept up to date