National Security Inspectorate Sentinel House, 5 Reform Road, Maidenhead, SL6 8BY E: nsi@nsi.org.uk | W: nsi.org.uk Page 1 of 23 © NSI 2016 Dated: 26 September 2016 To: 1. All NSI Guarding Gold and Silver approved compa nies holding approval for the provision of contracted remote CCTV control centres for the management and operation of CCTV schemes 2. Applicant Companies who wish to gain approval for the above scope of approval 3. NSI ARC Gold approved companies holding approval as Remote Video Response Centres (RVRCs) in relation to BS 8418 TECHNICAL BULLETIN No: 0034 Guidance on the implementation of BS 7958:2015 Annex E Contracted remote CCTV control centre responsibilities within BS 7958, the British Standard Code of Practice for Management and Operation of Closed Circuit Television (CCTV) (Supersedes BS 7958:2009 Annex A) BS 7958:2015 shows a publication date of the 31st August 2015 and is available through licensed outlets including NSI who can supply copies at a discounted rate. Annex E of BS 7958:2015 identifies recommendations for the management and operation of CCTV schemes for contracted remote CCTV control centres providing CCTV control centre facilities and monitoring services, operating such schemes on behalf of the owner, in areas where the public are encouraged to enter or have a right to visit. Annex E applies also to commercial CCTV schemes covering areas where the public do not have the same rights of access that are either operated by the owner of the area (property) or on their behalf. Organisations that demonstrate compliance with Annex E, and also satisfy the relevant NSI criteria for approval, will be approved for the following scope: “The provision of contracted remote CCTV control centres for the management and operation of CCTV schemes, in accordance with the requirements of BS 7958:2015 Annex E and BS 7858:2012”. NSI Technical Bulletin No. 0034 Page 2 of 23 © NSI 2016 The 2015 edition of BS 7958 will now be applied to all NSI approval schemes where the criteria for approval requires compliance with BS 7958 as a condition of NSI approval. Annex E of the Standard will be applied with immediate effect, subject to the additional clarifications and guidance contained within this Technical Bulletin. Implementation timescale for Applicant Companies With immediate effect Applicant Companies will be audited against Annex E of the 2015 edition and any Improvement Needs recorded against clauses of the Standard will have to be satisfactorily addressed before approval can be granted. Implementation timescale for existing Approved Companies Companies holding NSI approval to Annex A of BS 7958:2009 will be expected to upgrade to Annex E of BS 7958:2015 by the end of June 2017. NOTE REGARDING THE STATUS OF BS 7958:2015 Although issued as a code of practice by the British Standards Institution, it is important to note that compliance with the recommendations given in BS 7958:2015 is regarded as mandatory for all companies wishing to maintain an NSI approval with respect to the provision of CCTV services; subject to any additional clarifications and guidance included within this Technical Bulletin or issued subsequently. The recommendations given in BS 7958:2015 Annex E must therefore be regarded as requirements in relation to NSI approval for the provision of contracted remote CCTV control centres for the management and operation of CCTV schemes. Note regarding BS 7958:2015 and BS 8418:2015 Sub-clause 10.1 of BS 8418:2015 calls for remote video response centres (RVRCs) to be managed and operated in accordance with BS 7958:2009, Annex A. However this is simply part of the NSI ARC Gold audit schedule and does not lead to NSI Guarding Gold or Silver approval unless a company wants to apply for the Guarding approval. Annex E of BS 7958:2015 may take over from Annex A of BS 7958:2009 in relation to BS 8418:2015. However this has not been clarified. For the time being, therefore, NSI ARC Gold audits of RVRCs will continue to apply Annex A of BS 7958:2009 and we will endeavour to seek clarification in due course from British Standard Institution regarding the status of Annex E of BS 7958:2015 in relation to BS 8418:2015. NSI Technical Bulletin No. 0034 Page 3 of 23 © NSI 2016 DETAILS OF THE CHANGES (Highlighted under the clauses of Annex E of the new Standard) Comments under each clause of BS 7958:2015 Annex E consist of a summary of the main changes when compared with the corresponding clause within BS 7958:2009 Annex A. Where Annex E refers to a clause within the main body of the standard then changes to that clause are relevant along with any changes to Annex E itself. Where the actual wording of the standard is quoted it is reproduced in bold text. Where it is considered relevant to further clarify the specified requirement, additional guidance is included in italics. We will consider alternative methods of achieving compliance with specified requirements where these can be demonstrated to be equivalent. CONTENTS The contents page of BS 7958:2015 shows that the ten numbered sections have been retained. The heading for section 6 reflects a change of terminology from ‘ CCTV Image Receiving Centre ’ to CCTV control centre and the heading for section 7 reflects a change of terminology from ‘ Response ’ to Incident handling . New annexes have been added and numbering of annexes have been changed as follows: Where previously Annex A (normative) of BS 7958:2009 related to Contractor responsibilities within BS 7958; Annex A (informative) of BS 7958:2015 now covers Surveillance Camera Code of Practice – 12 guiding principles. Where previously Annex B (normative) of BS 7958:2009 related to Management and operation of CCTV traffic enforcement cameras, Annex B (informative) of BS 7958:2015 now covers Data Protection Act 1998 – 8 guiding principles. Annex C (normative) of BS 7958:2015 now covers Contractor responsibilities within BS 7958. Annex D (normative) of BS 7958:2015 now covers Management and operation of CCTV traffic enforcement cameras. Annex E (normative) of BS 7958:2015 is a new annex covering Contracted remote CCTV control centre responsibilities within BS 7958. These responsibilities were understood to lie within Annex A of the previous standard whereas they are now clarified in the new Annex E. NSI Technical Bulletin No. 0034 Page 4 of 23 © NSI 2016 Annexes C, D and E are normative which makes them a formal part of the standard (where applicable to the services provided). The new List of tables consists of two tables: Table A.1 – 12 guiding principles of the Surveillance Camera Code of Practice and Table B.1 – 8 guiding principles of the Data Protection Act 1998. FOREWORD BS 7958:2015 was prepared by BSI Technical Committee GW/3 (Manned security services). The Foreword clarifies that the 2015 edition is a full revision of the Standard, which has been updated to reflect current good practice, and that it supersedes BS 7958:2009, which is withdrawn . INTRODUCTION The introduction includes references to the Protection of Freedoms Act 2012 [4] and the Regulation of Investigatory Powers Act 2000 [5]. A statement has now been included that monitoring for traffic offences does not require a SIA (Security Industry Authority) Licence. However, if operators monitoring for traffic offences, who are employed by organizations providing the service under contract, provide an additional security service involving use of CCTV then they are required to hold the SIA CCTV (Public Space Surveillance) Operator Licence prior to being deployed in contractual security work . Attention is drawn to the Surveillance Camera Code of Practice [7] and its 12 guiding principles, which are applicable to public space CCTV systems. It is relevant to remind companies that it is a condition of any NSI approval that organisations comply with appropriate legislation and in particular if relevant individuals are not in possession of either the appropriate SIA front-line or non-front-line licences then unless appropriate dispensations have been granted, NSI approval cannot be recommended or maintained. The list of areas where CCTV schemes are used and the public would have a ‘right to visit’ include two new areas i.e. e) sports grounds where access is unrestricted and f) public arenas such as sports stadiums and public places where events are held as an alternative to regular activities in those locations . The following two paragraphs of text have been deleted from the Introduction and incorporated in other relevant places within the new standard: “ This British Standard aims to provide recommendations on best practice to assist users in obtaining reliable information that can be used as evidence. Whilst some schemes might not need to meet the NSI Technical Bulletin No. 0034 Page 5 of 23 © NSI 2016 DPA [1] criteria, compliance with the code of practice is strongly recommended, particularly where schemes include an element of observation of the public. “ The clauses on the processing of data within this British Standard are applicable to the storage of recorded images/data from CCTV systems designed to operate normally in observation mode, e.g. garages, small shops, private businesses and private transport. ” 1. SCOPE The clarification of the scope is the inclusion of a sentence under the first paragraph to show that the standard now also applies to the monitoring of and management of public spaces, including automatic number plate recognition (ANPR) and traffic enforcement cameras . The second paragraph now includes the reference to BS 8591 as well as BS 5979. The scope has now been changed to cover also traffic enforcement schemes . The scope now includes that This British Standard takes due regard of the 12 guiding principles of the Surveillance Camera Code of Practice [7] (see Annex A) and the Information Commissioner’s CCTV Code of practice [8] and the Data Protection Act 1998 [1] princi ples (see Annex B). References to the Principles of the Surveillance Camera Code of Practice and the Principles of the Data Protection Act are given throughout the standard. 2. NORMATIVE REFERENCES BS 8591 the code of practice for remote centres receiving signals from alarm systems has been added to the list of reference documents. 3. TERMS AND DEFINITIONS A number of changes have been made in this area. The previous list of 36 definitions has been decreased to 30 by removing definitions not needed. Therefore the reference numbers for some definitions have changed. The new headings and any changes are listed below. 3.1 New title and definition for CCTV control centre (previously CCTV Image Receiving Centre) secure central location for a CCTV scheme, where images are collected, used, disclosed, retained or disposed of The 2009 edition of BS 7958 only included a definition for a “central location for a CCTV scheme, where live images are monitored in real time and which has processing facilities”. NSI Technical Bulletin No. 0034 Page 6 of 23 © NSI 2016 3.2 CCTV scheme There are no changes except the Note has been moved to 3.3. 3.3 CCTV system There are no changes except the Note has been added from 3.2. 3.4 clean tape No change. 3.5 Definition for contractor has been simplified: party contracted by the owner to undertake agreed services 3.6 controlled environment The definition of controller (see 3.6 in the 2009 edition) has been deleted and replaced with staff (see 3.27 in the 2015 edition). Consequently there are changes to the numbering of definitions. The definition for controlled environment has now been replaced with: location in which data that might be offered as evidence are received, stored, reviewed or analysed, including at the CCTV control centre . 3.7 customer No change. 3.8 data No change. 3.9 evidence copy The title of the definition has changed from evidential copy to evidence copy and the word ‘second’ has been removed from the definition, which is as follows: copy taken from the master copy with a clear audit trail which is offered as evidence 3.10 hard print copy No change. 3.11 Definition for incident has been simplified: activity that warrants a response NSI Technical Bulletin No. 0034 Page 7 of 23 © NSI 2016 3.12 New definition for local procedures : documents relating to the processing of aspects of the CCTV scheme 3.13 Slight change to title of definition for manager(s) as there might be more than one manager. 3.14 Revised definition for master copy first copy to be produced, that is designated and documented as such and then stored securely pending its production (if required) at court as an exhibit NOTE All use and movement of the master copy is logged in an audit trail. 3.15 Slight change to the definition for monitoring period as there might be more than one procedure. length of time during which monitoring is carried out as defined by local procedure 3.16 operator No change (was 3.18 in 2009 edition). 3.17 New definition for operator’s log record, including date and time, for a workstation that also includes details of any events, plus details of activities such as maintenance and use 3.18 Revised definition for organization : sole or principal provider of CCTV monitoring services to a particular customer 3.19 owner No significant changes. 3.20 New definition for privacy impact assessment assessment of the impact a CCTV system has on an individual’s right to privacy NOTE Attention is drawn to the Human Rights Act 1998 [2] and the Data Protection Act 1998 [1]. Further guidance can be found in the Information Commissioner’s Conducting privacy impact assessments code of practice [9]. 3.21 There are no significant changes to the definition for process . However the definition has been made clearer: obtaining, recording or holding information or data or carrying out any operation or set of operations on the information or data NOTE This definition is taken from the Data Protection Act 1998 [1]. NSI Technical Bulletin No. 0034 Page 8 of 23 © NSI 2016 3.22 Definition for recorded material has been simplified any data recorded on any medium that has the capacity to store data 3.23 Added wording “irrespective of time” to end of definition for recording material : any medium that has the capacity to store data and from which data can later be recalled, irrespective of time 3.24 Revised definition for recordings : electronic capture of images or data 3.25 remote centre No change. 3.26 secure storage No change. 3.27 New definition for staff personnel involved in the management and operation of CCTV 3.28 Definition for supervisor has been simplified person designated and trained to ensure the required operation of the CCTV scheme and to meet any procedural instruction issued by the owner or manager 3.29 temporary systems No change. 3.30 Definition for working copy has been simplified: copy of recordings which is used for review. NOTE Also referred to as the “slave copy”. Some definitions from the 2009 edition have been deleted because they are no longer used and some of the definitions have been re-numbered. NSI Technical Bulletin No. 0034 Page 9 of 23 © NSI 2016 Annex E (Normative): Contracted remote CCTV control centre responsibilities within BS 7958 (previously Annex A of BS 7958:2009) Sometimes the Annex states that the recommendations of a particular clause of BS 7958 should be followed in which case this Technical Bulletin draws attention to the changes in the clause compared to the previous 2009 edition of BS 7958. Commentary on Annex E The first three paragraphs have been removed from A.1 (General) of BS 7958:2009 and included in a new Commentary on Annex E of BS 7958:2015. This text is informative and references to the Protection of Freedoms Act 2012 and the Surveillance Camera Code of Practice have been added. E.1 General The last paragraph of A.1 (General) of BS 7958:2009 regarding underlying objectives (including items a), b) and c)) have been retained in E.1 General of BS 7958:2015. This text is normative and references to Principle 4 of the Surveillance Camera Code of Practice and the NPCC policy have been included. E.2 Principles and management of the CCTV scheme E.2.1 Objectives The recommendations of 4.1 should be followed as stated in the contract. The section on objectives has been expanded to cover 4.1.1 Use, 4.1.2 Effectiveness, 4.1.3 Transparency and 4.1.4 Standards. 4.1.1 Use This clause contains revised requirements with emphasis on the CCTV scheme needing to have a clearly defined purpose in pursuit of a legitimate aim. This reflects the content of the Surveillance Camera Code of Practice. The objectives of a CCTV scheme should have a clearly defined purpose or purposes in pursuit of a legitimate aim. The data held should be appropriate for those objectives and the owner should have reasonable cause to hold the data. The purpose or purposes should be clearly documented against which the ongoing use of the system and any images or other data can be assessed. A new NOTE 1 draws attention to Principle 1 of the Surveillance Camera Code of Practice. NOTE 2 is moved here from 4.2.1 of the 2009 edition. NSI Technical Bulletin No. 0034 Page 10 of 23 © NSI 2016 4.1.2 Effectiveness This clause contains new requirements reflecting the content of the Surveillance Camera Code of Practice. A CCTV scheme should capture, process, analyse and store images and data at a quality which is suitable for its defined purpose. The data or images should not be held for longer than necessary in accordance with the scheme’s objectives. NOTE 1 identifies that recording sound in a public place, where a conversation might be private, might not be appropriate. Where the purpose of the CCTV scheme includes crime prevention, detection and investigation, it should be capable of delivering images and other data which are of evidential value to the criminal justice system. Effective safeguards should be put in place to ensure the forensic integrity of recorded images and data including meta data (e.g. time, date location) are recorded reliably and any data compression does not compromise the data below the quality required to meet the defined purpose. A record should be kept as an audit trail of how images and data have been handled if they are likely to be used as exhibits for the purpose of criminal proceedings in court. NOTE 2 draws attention to Principle 11 of the Surveillance Camera Code of Practice and Principles 3 and 4 of the Data Protection Act 1998. 4.1.3 Transparency This clause contains new requirements reflecting the content of the Surveillance Camera Code of Practice. The commentary on 4.1.3 states that surveillance by consent is dependent on the system operator being transparent and accountable. Measures should be taken so that persons who are being monitored are made aware that such activity is taking place, who is undertaking the activity and the purpose of the activity; this is an integral part of overt surveillance and is a legal obligation. In the development or review of a CCTV scheme, consultation and engagement are an important part of assessing whether there is a pressing need and a CCTV system is a proportionate response; consultation should be undertaken with all relevant parties and partners. The NOTE draws attention to Principle 3 of the Surveillance Camera Code of Practice and Principle 6 of the Data Protection Act 1998. 4.1.4 Standards This clause contains new requirements reflecting the content of the Surveillance Camera Code of Practice. NSI Technical Bulletin No. 0034 Page 11 of 23 © NSI 2016 Where appropriate, system operators should base their policies and procedures around approved standards. NOTE 1 indicates that policies and procedures can apply not only to the design, installation, operation and maintenance of the CCTV system, but also where applicable to any additional standards which cover advanced capabilities such as ANPR, body-worn video, facial recognition and video analytics. NOTE 2 draws attention to Principle 8 of the Surveillance Camera Code of Practice. E.2.2 Policy The recommendations of 4.2 should be followed as stated in the contract. 4.2.1 General The content of this clause has been re-organised and is substantially the same as before. There is a change to the policy or policies regarding the safety and integrity of the scheme. This should cover the physical security of the system, the IT security and resilience of the system and the vetting and training of staff using the system. A new statement is included that policies should reflect best practice and should be regularly reviewed . A new NOTE draws attention to Principle 5 of the Surveillance Camera Code of Practice and Principle 5 of the Data Protection Act 1998. 4.2.2 Policy and scheme review The first paragraph has been re-worded as follows: Regular reviews should be undertaken, at least annually, to ensure that the scheme still meets the specified purpose and to minimize the effects on individuals and their privacy. An additional final paragraph has been added as follows: If the objectives of the scheme change then the CCTV system should be reviewed. If the objectives of the scheme are no longer valid, then the CCTV system should be withdrawn. A new NOTE draws attention to Principles 2 and 11 of the Surveillance Camera Code of Practice and Principles 4 and 5 of the Data Protection Act 1998. E.2.3 Procedures E.2.3.1 Information security The recommendations of 4.3.1 should be followed in so far as they apply to the contracted remote CCTV control centre. NSI Technical Bulletin No. 0034 Page 12 of 23 © NSI 2016 The recommendations of 4.3.2 should be followed. Clause 4.3.2 on Methods for receiving and viewing data has been revised and expanded into clauses on 4.3.2 Information Security, 4.3.3 Access to data and 4.3.4 Supporting data. 4.3.1 General The last paragraph from the 2009 edition has become the first paragraph of the 2015 edition and has been re-worded as follows: Responsibility and accountability for all CCTV system activities should be clearly set out, and management and reporting functions should be regularly reviewed and audited. NOTE 1 draws attention to Principle 4 of the Surveillance Camera Code of Practice and Principle 7 of the Data Protection Act 1998. Where a CCTV system is used for more than one purpose (for example, crime prevention and detection and also for traffic management), those accountable for each purpose should be identified to facilitate effective joint working and decision making. Other than this, the requirements are unchanged. 4.3.2 Information security This is a new clause containing the following requirements: Policies and procedures should be designed to ensure that any images or data are protected from unauthorized access and retained only until the purpose they have been retained for has been met, after which they should be destroyed. Retention lengths vary due to the purpose of the system but should be proportionate. These timescales should be reviewed on a regular basis in the light of changes to the aims and purpose of the system and in the light of experience. The CCTV scheme should have regard for the physical security of equipment used to store and process images and data. It should also have regard for IT security to ensure that unauthorized access is denied unless the user has the appropriate access level. Each scheme needs to build policies and procedures in terms of both physical and IT security to secure the data being held. These should be reviewed on a regular basis. A new NOTE draws attention to Principles 6 and 9 of the Surveillance Camera Code of Practice and Principles 7 and 8 of the Data Protection Act 1998. E.2.3.2 Access to data The recommendations of 4.3.3 should be followed. This is a new clause containing the following requirements: NSI Technical Bulletin No. 0034 Page 13 of 23 © NSI 2016 Policies and procedures should be created to ensure that access to recorded images and stored data is restricted. These should also define who can gain access and under what circumstances access is approved and by whom. NOTE 1 states that access to images and data may be provided where permitted by legislation, for example where non-disclosure would be likely to prejudice the prevention and detection of crime or for national security purposes or where disclosure is authorized by a court of competent jurisdiction. There might be other limited reasons where disclosure of images to a third party is appropriate. Attention is drawn to the Data Protection Act 1998, particularly Principle 6. Policies and procedures should be in place to meet requests from individuals about images of themselves to manage those images where third parties are included. In addition there should be policies and procedures to deal with requests from public bodies for data information. The owner should not disclose data without a record of the request and the authorization, which should be retained for a minimum period of 2 years. NOTE 2 draws attention to the Freedom of Information Act 2000 and Principle 7 of the Surveillance Camera Code of Practice. E.2.3.3 Supporting data The recommendations of 4.3.4 should be followed. This is a new clause containing the following requirements: Where data collected by a CCTV scheme are to be used to provide meta data (for example vehicle registration numbers from ANPR cameras or face recognition), the accuracy of information generated or provided from elsewhere such as databases should be regularly assessed to ensure that such data are fit for purpose. Reference data should only be retained for as long as necessary to fulfil the legitimate aims of the scheme. The inclusion of personal information from a reference database might be deemed to be covert surveillance; policies and procedures to identify when this might be the case and methods to manage surveillance should be implemented in schemes where this is appropriate. A new NOTE draws attention to the Regulation of Investigatory Powers Act 2000, Principles 7 and 12 of the Surveillance Camera Code of Practice and Principles 4 and 5 of the Data Protection Act 1998. E.2.3.4 Annual report The contracted remote CCTV control centre should provide the scheme owner with information necessary to enable the scheme owner to provide an annual report in accordance with 4.3.6. This information supplied should be set out in the contract. Previously 4.5 in the 2009 edition. NSI Technical Bulletin No. 0034 Page 14 of 23 © NSI 2016 There are no changes except for additional requirements to be included in the assessment of the scheme’s performance as foll ows: 4) • an assessment of the scheme’s impact on its objectives, including: • the number of privacy impact assessments completed; • the number of reviews of footage by police and authorized agencies; and • the number of incidents per camera for the previous twelve months. A new NOTE 2 draws attention to Principle 10 of the Surveillance Camera Code of Practice. E.2.3.5 Audit The contracted remote CCTV control centre should provide information to the owner as necessary in accordance with 4.3.7 as it applies to the contracted service (i.e. it is not an independent audit of the contracted remote CCTV control centre, but an audit of the monitoring part of the owners CCTV system). NOTE Attention is drawn to Principle 10 of the Surveillance Camera code of Practice [7] and Principle 2 of the Data Protection Act 1998 [1]. Previously 4.4 in the 2009 edition. There are no changes except for a new NOTE 2 that draws attention to Principle 10 of the Surveillance Camera Code of Practice. E.2.4 Management responsibilities E.2.4.1 General The recommendations of 4.4.1 should be followed as stated in the contract. NOTE Attention is drawn to Principle 7 of the Surveillance Camera Code of Practice [7] and Principle 2 of the Data Protection Act 1998 [1]. Previously 4.6.1 in the 2009 edition. There are no significant changes except that NOTE 2 in the 2009 edition has been converted into normative text: The owner may appoint a manager as their representative but should give the manager clear objectives and authority. These objectives should not be changed without the formal approval of the owner and they should be reviewed on a regular basis, at least annually. A new NOTE 2 draws attention to Principles 4 and 5 of the Surveillance Camera Code of Practice. NSI Technical Bulletin No. 0034 Page 15 of 23 © NSI 2016 E.2.4.2 Manager The recommendations of 4.4.3 should be followed, in so far as they are applicable to the contracted remote services. Previously 4.6.3 in the 2009 edition. There is a slight change to item g) where “data media” replaces “data medium, e.g. tapes;” . There are no other changes apart from the addition of two new notes. NOTE 1 draws attention to the Surveillance Camera Code of Practice and Principles 4, 5 and 7 of the Data Protection Act 1998. NOTE 2 draws attention to the Data Protection Act 1998 in relation to the data controller. E.2.4.3 Supervisor The recommendations of 4.4.4 should be followed. Previously 4.6.4 in the 2009 edition. There is a slight, but important, change to the wording in the first paragraph of 4.4.4 of the 2015 edition whereby it is clearer that the supervisor should bring to the immediate attention of the manager any matter affecting operation of the CCTV scheme, including any breach (or suspected breach) of the policy, procedural instructions, security of data or confidentiality . The list of items to be included in data recording systems has been shortened by removal of items a) the tape, or media, register; f) faults and maintenance records; and g) the security of data. The focus is on items that need to be recorded/logged. However the following item has been added to the list; d) the maintenance log Also the following Note has been added: A new NOTE 2 draws attention to Principles 4 and 7 of the Surveillance Camera Code of Practice and Principles 4 and 7 of the Data Protection Act 1998. E.2.4.4 Operator The recommendations of 4.4.5 should be followed. Previously 4.6.5 in the 2009 edition. The first paragraph of 4.4.5 of the 2015 edition incorporates a change whereby the operator should work under the direction of the owner, manager or supervisor and in accordance with the policy and procedural practices. NSI Technical Bulletin No. 0034 Page 16 of 23 © NSI 2016 The addition of the word “supervisor” is intended to ref lect true circumstances. This clause has been re-structured to some degree with re-organisation of the order of the text plus some changes to the text as follows: become proficient has been replaced with be proficient . This obviously reflects the need for operators to be proficient rather than at some later time. The following sentence has been added: Operators should have been appropriately screened for handling personal data and images. The kind of screening may vary depending on the requirements of other parties such as the police. A new NOTE draws attention to Principles 2, 6, 7, 8, 9 and 11 of the Surveillance Camera Code of Practice, Principles 1, 2, 3, 7 of the Data Protection Act 1998 and the Private Security Industry Act 2001. The following paragraph has been added: The operator training and screening undertaken should be appropriate to the nature of surveillance camera system they are operating. The wording be trustworthy has been deleted from a different paragraph. This does not mean that operators should not be trustworthy. However it is difficult to detect lack of trustworthiness until something has happened. Therefore trustworthiness was not easily auditable. E.2.5 Personnel The recommendations of Clause 5 should be followed. 5.1 Security screening There are no significant changes other than the inclusion of the word images in relation to employment that might involve the acquisition of such information. This emphasises the significance of “images” in the context of CCTV and the need to security screen all personnel whose employment involves access to images as well as other kinds of information. 5.2 Recruitment and selection There are no changes. NSI Technical Bulletin No. 0034 Page 17 of 23 © NSI 2016 5.3 Training The previous sub-clause headings 5.3.1 (General) and 5.3.2 (Plan) have been removed to leave the main heading (5.3) and the order of the text has been changed. The 2009 edition used the terms “ employees ” and “ staff ” and these were not defined. In order to provide a clearer set of requirements t he term “staff” has been defined (see 3.27 in the 2015 edition) and the term “employees” has been withdrawn. The new clause 5.3 opens with a revised paragraph as follows: New staff should be supervised until the training is complete. Training should be carried out by suitably qualified persons. The 2009 edition stated that there should be a formal training plan that includes information on the following and in a sense it was difficult to draw the line in terms of what formal means. This position has been simplified to Training should include the following and then there is a list of items to be included. The list of training items is the same as in the 2009 edition apart from the following: Expansion of item e): e) all relevant legal issues and codes of practice, e.g. the Surveillance Camera Code of P ractice [7] and the Information Commissioner’s CCTV Code of Practice [8]; Removal of item f): f) the progression to nationally recognized qualifications, e.g. NVQ, SVQ, City & Guilds; The NOTE has been revised: NOTE 1: BS 7499, BS 5979 and BS 8591 give further guidance on training. The following statement has been deleted: “ A minimum period of training should be stated that is appropriate to ensure at least the minimum competence to carry out the specified duties. ” This has been replaced with a clearer statement: The period of training should be sufficient to ensure that staff are able to carry out the specified duties . NOTE 1 in the 2009 edition has been converted to normative text: Good training is essential to achieve effective and proper use of CCTV; the operator should be trained to be able to react to potential incidents, to monitor the event accurately and not lose information that could be pertinent to any future investigation. NSI Technical Bulletin No. 0034 Page 18 of 23 © NSI 2016 A new NOTE 2 draws attention to the Criminal Procedure and Investigation Act 1996, which lists procedures that ensure all relevant information, including that which could substantiate the case for the defence, is catalogued. E.2.6 CCTV Control Centre The recommendations of Clause 6 should be followed. 6.1 General References to CCTV Image Receiving Centre have been replaced with CCTV control centre . The following change of text has been made: Toilet and kitchen facilities for CCTV control centre staff should be provided. The standard does not stipulate these facilities need to be inside the CCTV control centre. There is a new second paragraph which states: The needs of lone workers in single staffed CCTV control centres should be taken into account. NOTE 1 See BS 8484 for guidance on the provision of lone worker device services. This would include means for raising the alarm in case of a medical emergency affecting a lone CCTV control centre operator. There is a change of text from “have the means for direct communication with the law enforcement agencies” to have the means of communication with the emergency services . This avoids the need to interpret the meaning of “direct”. The need to sign a visitors’ log now applies to entering and exiting the CCTV control centre. The standard now states law enforcement agency officers should be granted the right to enter the CCTV control centre at any time for liaison and security objectives. The following note has been added: NOTE In a centre which conforms to BS 5979 and BS 8591, adherence to the access protocols is required by law enforcement agencies. This means law enforcement agencies must adhere to the access protocols just like any other party. 6.2 Ergonomics There are no changes apart from an update to Note 2 which now draws attention to the Equality Act 2010. NSI Technical Bulletin No. 0034 Page 19 of 23 © NSI 2016 6.3 Health and safety The first paragraph has been re-worded as follows: The shift patterns should be documented and sufficient breaks should be included to ensure the health and productivity of the operating staff. The main change here is the requirement to document shift patterns and show how sufficient breaks are included. A new NOTE 2 draws attention to the Health and Safety (Display Screen Equipment) Regulations 1992, Regulation 4. A new NOTE 3 draws attention to the Working Time (Amendment) Regulations 2002. E.2.7 Response The recommendations of Clause 7 should be followed. The title has been changed from “Response” in the 2009 edition to “Incident handling” to reflect the correct scope of this section of the standard. Clause 7.6 “Result of a successful response to the incident” has been deleted because the success or otherwise of the response is usually outside the control of the CCTV control centre. 7.1 General This clause, previously called “Guiding principle”, has been simplified: When an incident is captured by a CCTV system, the procedures detailed in 7.2 to 7.5 should be followed. 7.2 Incident policy There are no significant changes. 7.3 Incident response The title has changed from “Making the response”. The text has been simplified: The local procedures should identify who is responsible for making the response to an incident. A new NOTE states, depending on the incident, the response might be by emergency services, private security, roadside assistance, etc. NSI Technical Bulletin No. 0034 Page 20 of 23 © NSI 2016 7.4 Timescale of the incident notification The title has changed from “Timescale of the response”. The second paragraph has been deleted. 7.5 Incident observation and/or recording The title has changed from “When observation and/or recording is needed”. The text has been simplified: The local procedures should indicate the times at which incident observation and/or recording is needed. A new NOTE states the local procedures might include the time immediately after an incident (direct incident response), for example: a) until arrest/curtailment; or b) during a whole incident, initiated by an alarm. E.2.8 Privacy and disclosure issues The recommendations of Clause 8 should be followed and the requirements of data disclosure should be detailed in the contract with the owner. 8.1 Privacy The word “surveyed” has been changed to “viewed”. The NOTE now draws attention to Principle 6 of the Data Protection Act 1998 and Principle 2 of the Surveillance Camera Code of Practice. 8.2 Disclosure of data 8.2.1 General A new NOTE draws attention to BS ISO 27001 for guidance on information security. 8.2.2 Request to disclose data There are no significant changes. NOTE 1 has been converted into a commentary. A new NOTE 3 draws attention to Principle 6 of the Data Protection Act 1998 and Principle 7 of the Surveillance Camera Code of Practice. NSI Technical Bulletin No. 0034 Page 21 of 23 © NSI 2016 8.3 Subject access disclosure (a named subject) There are no significant changes. NOTE 1 has been converted into a commentary. The new NOTE 1 draws attention to Principle 6 of the Data Protection Act 1998 and Principle 7 of the Surveillance Camera Code of Practice. The last paragraph of the 2009 edition has been merged with NOTE 3 in the 2009 edition to create NOTE 2 in the 2015 edition as follows: NOTE 2 A search request needs to contain sufficient information to locate the data requested (e.g. in 30 min slots for a given date and place). If inadequate or inaccurate information is provided, a data controller may refuse a request until sufficient information is provided. 8.4 Media disclosure There are no significant changes. A new NOTE draws attention to Principle 6 of the Data Protection Act 1998 and Principle 7 of the Surveillance Camera Code of Practice. E.2.9 Recorded material management The recommendations of Clause 9 should be followed. Clause 9.2 Quality of the 2009 edition has been deleted. 9.1 General New requirements have been added as follows: The CCTV system should be capable of meeting the objectives of the CCTV scheme. The CCTV system should be maintained in good working order and in accordance with the manufacturer’s recommendations. Details of maintenance should be recorded from the date of purchase and be available for inspection. Details of the recording and monitoring equipment used should be recorded. The sentence about the electronic document management system conforming to BIP 0008-1, BIP 0008-2 and BIP 0008-3 has been converted into NOTE 1. The following text has been deleted: “ Data should not be released to organizations outside the ownership of the CCTV scheme, other than under guidelines referring to the release of information for the purposes of identifying alleged NSI Technical Bulletin No. 0034 Page 22 of 23 © NSI 2016 offenders or witnesses, in accordance with the particular CCTV control room’s policy and procedure (see Clause 8). ” The reason is that privacy and disclosure issues are dealt with under clause 8. The original NOTE 1 from the 2009 edition has been deleted because “hard copy print” is defined. A new NOTE 2 draws attention to Principle 5 of the Data Protection Act 1998 and Principle 6 of the Surveillance Camera Code of Practice. 9.2 Media use, storage and disposal Previously 9.3 in the 2009 edition. The last paragraph of 9.3 of the 2009 edition has been moved to become the first paragraph of 9.2 of the 2015 edition. The text recommending reuse of tapes a maximum of 12 times has been converted into a NOTE: NOTE 1 No more than 12 times reuse is often recommended, because the quality of the recording degenerates considerably with each reuse. 9.3 Recorded material register Previously 9.4 in the 2009 edition. Clauses 9.4.1 “Videotape” and 9.4.2 “Digital register” have been merged under the main heading “recorded material register” to create single set of requirements for all media. The revised 9.3 opens with the following requirements: A CCTV system should have a register showing the life of the media at all stages whilst in the owner’s possession; such a register might also show itself to be useful in enabling evaluation of the CCTV scheme. Also NOTE 1 has been deleted. 9.4 Making recordings Previously 9.5 in the 2009 edition. There are no significant changes. The word “efficiently” has been changed to “correctly” so 9.4 a) reads as follows: a) Before recording, test that all equipment is working correctly. The last paragraph in the 2009 edition has been split into a requirement and a NOTE. The requirement reads: NSI Technical Bulletin No. 0034 Page 23 of 23 © NSI 2016 All documentation should be auditable. The NOTE reads: NOTE When using digital CCTV systems, see the processes outlining the export of media in Digital imaging procedure [16] and UK Police Requirements for Digital CCTV Systems [17]. 9.5 Tape loading/unloading for analogue CCTV systems Previously 9.6 in the 2009 edition. There are no changes. E.2.10 Documentation The recommendations of Clause 10 should be followed. 10.1 General The final paragraph of 10.1 of the 2009 edition has been converted into a NOTE as follows: NOTE 2 If records are maintained on an electronic document management system, see BIP 0008-1, BIP 0008-2 and BIP 0008-3 for guidance. 10.2 Logs There are no significant changes. The word contractual has been deleted from item 10.2 d). 10.3 Administrative documents The NOTE has been converted to a commentary. A new NOTE draws attention to Principle 6 of the Data Protection Act 1998 and Principle 7 of the Surveillance Camera Code of Practice.