CCTV policy

Introduction

The Marlowe Trust has a number of CCTV cameras across its estate and acts as the data controller for the video footage that is recorded on these cameras.

This CCTV policy forms part of The Marlowe Trust’s Privacy Policy.

CCTV System Overview

The Marlowe’s CCTV system is in operation at three sites. The Marlowe Theatre, Chaucer House and the Marlowe Kit.
Those sites operate as follows:

Marlowe Theatre
59 cameras are physically on this site cover: theatre foyers, auditorium(s) door entrance’s, the Green Room café/restaurant, all three theatre bars, the forecourt, the Sunley Terrace outside of stage door, the outdoor loading bay and the entrance to the theatre’s yard.
Footage recorded by this system is stored on a DVR (Digital Video Recorder) that is located in the Theatres server room.
Individuals that are recorded by this system include staff, audiences, public visitors to the theatre site, visiting artists and visiting contractors.

Chaucer House
One camera physically on this site which covers the Marlowe Theatre forecourt only. Footage recorded by this system is stored on a DVR (Digital Video Recorder) that is located in the theatres server room.
Individuals that are recorded by this system include staff, audiences, public visitors to the theatre site, visiting artists and visiting contractors.

The Marlowe Kit
16 cameras cover all public areas that include the exhibition space, two workshop rooms (known as the white and black rooms), entrance and exit to the escape room, the chapel and the great hall.
Footage recorded by this system is stored on a DVR (Digital Video Recorder) that is located in the theatres server room.
Individuals that are recorded by this system include members of the public, staff, artists, and visiting contractors.

Show relay system

The Marlowe operates a show relay system which is used by staff to see what is happening on stage.

Two cameras are in operation, one in the Main House and one in the Studio.

Recording does not take place unless there is a specific reason to do so, such as making archive recordings of work to be reviewed by creative teams. Individuals that may be recorded by this system are artists on our stages and our staff.

Purposes & Uses Of The CCTV system

Our CCTV system is used for the following purposes:

To meet the requirements of our premises licence for the prevention of crime and disorder, public safety, the prevention of public nuisance and the protection of children from harm in our buildings.
For the prevention of crime, by dissuading those who are considering undertaking criminal activity on our site.
To investigate any criminal activity that may have taken place on our premises and to support government departments, such as but not limited to, Police, Fire Brigade, and the Ambulance Service.
To supply footage to law enforcement agencies if requested to do so.
To supply footage to local authority (Canterbury City Council) if requested to do so.
To support operational management needs, allowing the Marlowe Theatre team to monitor crowd flow and behaviour and to identify and respond to any incidents on our premises when they take place.
To manage parking on the Marlowe Theatre’s site, including ingress and exiting to and from the Marlowe Theatre’s yard.
To support the training and management of the Marlowe Theatre’s staff team. Footage will be used to identify and review performance of individual staff members (such as the Front Of House team), to illustrate correct team practices and to train the team on crowd management practices. CCTV footage may also be used for staff disciplinary investigations.
To manage visiting contractors and the work that they are undertaking, to ensure that all contractors are always acting in a safe and appropriate manner when on the Marlowe Theatre’s site.
To enable the theatre team to remotely view footage of the theatre’s spaces, to allow for building maintenance and problem solving to be undertaken as and when required.
To enable the live relaying of activity on our stages to members of our team.

Monitoring

CCTV footage from the Marlowe Theatre’s video cameras are monitored through:
Static monitoring of live footage undertaken by our Duty Managers, Duty Technicians, Stage Door Keepers and Building Services Team.

Data Quality

The Marlowe Trust will endeavour to ensure that the CCTV images used are clear and of a high quality.

Data Security

The nominated individual for The Marlowe Trust, designated as the Systems Manager will ensure that CCTV data is secure by doing the following:

Ensure that the CCTV system is regularly checked to ensure that it is working correctly.
Ensure that the CCTV system can only be accessed by authorised individuals.
Ensure that the CCTV system and recordings can only be accessed by named post holders.
Ensure that recordings from the CCTV are secure, either as a cloud based system (with appropriate encryption), or when on a DVR hard drive system in the theatre (where it is locked and secure).
Ensure that access to the CCTV system and recordings is protected, via usernames and passwords.
Ensure that all staff are properly trained on the appropriate use of the CCTV system.
Footage where individuals can be identified will not be shared with another individual or organisation, apart from requests from law enforcement agencies.

Who Can Access Footage And How Do They Do This

Only designated team members are allowed to access and view CCTV live footage and recordings.
Designated team roles who are allowed to operate the CCTV system are as follows: Our Duty Manager, Duty Technicians and Stage Door Keeper.
Designated team roles who are allowed to access recordings from the CCTV system are as follows: Our Technical Director, Director of Operations, Stage Door Keeper, Assistant Stage Door Keeper and Systems Manager.
Downloaded footage will only be viewed by staff members deemed appropriate by a member of the Marlowe SMT or Executive.
Footage will only be accessed for the reasons outlined in Section 4.

Compliance With Data Protection Legislation & Ensuring Fair Processing

To ensure that The Marlowe Trust’s use and operation of its CCTV system is complying with the General Data Protection Requirements 2016/679 (GDPR) the following measures will be undertaken:

The Marlowe Trust is registered with the Information Commissioners Office as a Data Controller.
We will inform all individuals who visit our building about our use of CCTV.
Where areas are covered by a CCTV camera, prominent signage will be displayed to inform individuals of this.
The Marlowe Theatre’s CCTV policy will be made available on the Marlowe Theatre’s website, as part of its privacy policy.
The Marlowe Theatre’s privacy policy will include a summary of what our CCTV cameras are used for, with a link to the full policy.
Marlowe staff members will be informed of the Marlowe Theatre’s CCTV policy, ensuring that they are aware that they may be recorded whilst undertaking their role at our theatre and what those recordings will be used for.
A Data Protection Impact Assessment has been undertaken on the use of CCTV cameras.
We have clear guideline for how individuals can access CCTV footage that features them.

Nominated individual who is responsible for the CCTV System

The nominated person who is responsible for the usage of the Marlowe Trust’s CCTV system is the postholder of Technical Director.
The Technical Director and the Systems Manager will be responsible for ensuring the following:

That the CCTV system is used appropriately at all times.
That the CCTV system is working correctly.
That only designated members of The Marlowe’s team have access to the CCTV system.
That the CCTV system is only used for the purposes that are outlined in Section 4 of this document.
That staff training is undertaken with all individuals who access the CCTV system, so that they are clear on what their responsibilities are and what is the permitted usage of the system.
That all recordings held by the CCTV system are deleted within 21 days, unless they have been downloaded in line with section 4.
That staff are properly trained in how to operate the CCTV system and cameras.
That staff are trained on how to recognise and respond to requests for CCTV information and images.
That the CCTV images used are clear and of a high quality.

Applications for disclosure of images

Requests are made to:
Technical Director
The Marlowe Theatre,
The Friars, Canterbury,
Kent, CT1 2AS
Email Euan Maybank
In your request, please outline what data you wish to view and in what format to wish to receive it.
Your request will then be reviewed by the Technical Director and the Data Protection Officer and you will receive a reply within 30 days.
You also need to provide two official ID documents with your request so that we can confirm your identity. Our timescale of 30 days to respond to your request will begin once proof of ID is received.

How We Will Respond To Your Request

Once a request has been received and your identity proven, the theatre team will then make all reasonable to access the footage from the required time and date.
Once the footage has been located, the theatre team will then consider the following, in line with guidance from the Information Commissioner’s Office:

Does the request require disclosing information that identifies another individual.
Has/have the other individual(s) provided consent for their personal information to be shared.
Is it reasonable to disclose without consent.

If the footage that you are requesting does not contain images of any other third parties;
You will be supplied with the footage as an encrypted video file.

If the footage that you are requesting contains images of third parties, where consent for sharing can be obtained:
Once permission has been received by the third parties concerned, you will be supplied with the footage, as an encrypted video file.

If the footage that you are requesting contains images of third parties, where consent for sharing is not possible to obtain;
We have a responsibility to protect the data of individuals shown in CCTV footage, particularly of audiences visiting our theatre that include adults, young people, children, and vulnerable groups.

If the footage required, features identifiable third parties (such as members of the public), then the footage will not be supplied as a video file to the individual making the request. This is to protect the data of the third party individuals and to ensure that the video file is not inadvertently shared further or placed online in the public domain.

In these instances, the individual’s request will be discussed with the Information Commissioners Office and advice will be sought on how to provide a fair and appropriate resolution to this.

Recording Of Requests Made & Their Resolution

The Technical Director will ensure that all requests for access to CCTV footage will be logged including:

The date that the information was requested.
Evidence received to prove the identity of the individual.
Assessment of whether the footage contains data on third parties.
Decision on how the footage will be supplied (as video files or access via an appointment for online viewing).
When the footage was supplied to the individual.
Any further questions or requests from the individual and their resolution.
Any advice that has been received by the Information Commissioners Office.

Procedures For Supplying CCTV Footage

Once agreement has been made to supply video footage, the following procedures will be followed:

Footage will be identified and downloaded by those identified in section 8.
Once located, the video footage will be downloaded as a video file.
The video file will then be encrypted and uploaded to the theatre’s secure Microsoft Teams system.
The individual requesting the footage will be sent a password protected link to the footage, for them to download.

Retention of images

Recordings of footage from our CCTV cameras will be kept for maximum of 30 days after which time all recordings will be permanently deleted.
Footage maybe retained for longer than 30 days if it has been requested by the relevant authorities as evidence for part of a criminal investigation or for staff improvement and or disciplinary investigations.

Complaints Procedure

If anyone wishes to make a complaint, or has a question, regarding the use of CCTV then they should be addressed to
Paul Turner
Chief Operating Officer
The Marlowe
The Friars,
Canterbury,
Kent, CT1 2AS
Email Paul Turner

Monitoring compliance

The Marlowe Trust will ensure compliance with its CCTV policy by doing the following (for which the Technical Director is responsible):

Keeping logs of who has requested to review CCTV footage.
Keeping logs of the outcomes of requests to review CCTV footage, including the recording of how and when access was granted.
Regular monthly checks to ensure that CCTV footage has been deleted.
Monthly checks undertaken to ensure that all public signage is in place, to inform visitors and staff of the existence of CCTV cameras.
Monthly checks to ensure that the CCTV system is working and that recordings are of a high quality.

Policy Review

The Marlowe’s Trust CCTV policy will be reviewed annually by the Technical Director and the nominated Data Protection Officer.
Any changes to the policy will be reviewed and signed off by the Executive Team.

Policy created: May 2024
To be reviewed: May 2025