The Marlowe
CCTV policy

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 GDPR policy.

CCTV System Overview

The Marlowe’s CCTV system consists of four different systems that combine to provide coverage of the theatre estate.
Those four systems are as follows:

Coverage Of Main Theatre Spaces
The theatre’s main system that covers areas inside and outside of the theatre building.
Areas that this system covers are: theatre foyers, The Green Room café/restaurant, all three theatre bars, 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 Switch Room in the theatre’s basement.
Individuals that are recorded by this system include staff, audiences, public visitors to the theatre site, visiting artists and visiting contractors.

Coverage Of Backstage Areas
This system covers backstage areas inside the theatre building.
Areas that this system covers are: the entry and exit to Stage Door, the backstage lift corridor and the fire exits located next to Stage Door.
Footage recorded by this system is stored on a DVR (Digital Video Recorder) that is located in the Stage Door roof area.
Individuals that are recorded by this system include staff, public visitors to the theatre site, visiting artists and visiting contractors.

Coverage Of Theatre Yard Area
This system covers the theatre’s yard outdoor area.
Three cameras cover the yard, the lift corridor and the entrance to backstage.
Footage recorded by this system is stored on a DVR (Digital Video Recorder) that is located in the Stage Door roof area.
Individuals that are recorded by this system include staff, visiting artists and visiting contractors.

Coverage Of The Marlowe Kit
This system covers public areas in The Marlowe Kit building.
16 cameras cover 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.
Three cameras cover the yard, the lift corridor and the entrance to backstage.
Footage recorded by this system is stored on a cloud based recording system.
Individuals that are recorded by this system include members of the public, staff, artists, Canterbury City Council staff and visiting contractors.

Show relay system
This system covers the stage and is used for staff to see what is happening on the stage.
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 are recorded by this system are artists on our stages.

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.
  • 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 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’s site, including ingress and exiting to and from The Marlowe’s yard.
  • To support the training and management of The Marlowe’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 acting in a safe and appropriate manner at all times when on The Marlowe’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’s video cameras are monitored through:
Static monitoring of live footage undertaken by our Duty Managers, Duty Technicians and Stage Door Keepers.

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 Director Of Technical & Building Services 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 Head Of Operations, Stage Door Keeper and Director Of Technical & Building Services.
  • To access footage a username and password is required that is unique to each team member who is permitted to access the system.
  • Footage will not be viewed by any team member or individual whose role is not designated as having a right to access it.
  • Footage will only be accessed for the reasons outlined in Section three.

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’s CCTV policy will be made available on The Marlowe Theatre’s website, as part of its privacy policy.
  • The Marlowe’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’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 Director Of Technical & Building Services.
The Director Of Technical & Building Services 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 3 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 30 days.
  • 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

If you wish to obtain a copy of CCTV footage that features you, then please contact:
The Director Of Technical & Building Services
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 Head Of Technical & Building Services 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 requesting the information will be offered the opportunity to view the footage via a weblink, with a member of The Marlowe Theatre team in attendance who will control the playback of the footage.

If the individual does not accept the opportunity to view footage as a reasonable response, then they should inform the Director of Technical and Building Services of this, at the contact details listed above.  In this instance, the Data Protection Officer will promptly seek advice from the Information Commissioners Officer on how to provide a fair and appropriate resolution to this.

Recording Of Requests Made & Their Resolution

The Director Of Technical & Building Services 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 the Technical Manager
  • 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 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.

Complaints Procedure

If anyone wishes to make a complaint, or has a question, regarding the use of CCTV then they should be addressed to
John Baker
Director of Marketing And Communications
The Marlowe
The Friars,
Canterbury,
Kent, CT1 2AS
Email John Baker

Monitoring compliance

The Marlowe Trust will ensure compliance with its CCTV policy by doing the following (for which the Director Of Technical & Building Services 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 after 30 days.
  • 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 Director Of Technical & Building Services and the nominated Data Protection Officer.
Any changes to the policy will be reviewed and signed off by the Executive Team.

Policy created: March 2021
To be reviewed: March 2022