ACCS/Info Bulletin 05/24

1. CCTV in Schools Update.

2. Updated Template Protected Disclosure Policy and Notification Form.

The Secretary,

Board of Management and

School Principal in

each Community and Comprehensive School.

Members of the Executive of ACCS.

ACCS/Info Bulletin 05/24.

Re: 1. CCTV in Schools Update. 2. Updated Template Protected Disclosure

Policy and Notification Form.

1. CCTV in Schools Update

Recently we have seen an increase in queries from schools in relation to the

appropriate use of CCTV.

The recording of individuals by any means is a form of personal data processing,

and so is governed by the GDPR and the Data Protection Act, 2018. CCTV usage

should be considered in line with all other types of personal data processing carried

out in schools, i.e. the school Data Protection and Data Retention policies apply.

Students and staff have a fundamental right to privacy which must be balanced

against a school’s requirements and obligations.

As with any processing of personal data, the appropriate use of CCTV requires:

a) a legal basis for carrying out recording, e.g. public interest (prevention of

crime), compliance with a legal obligation (ensuring a safe working

environment);

b) a clear and transparent purpose for use of CCTV; and

c) consideration of the necessity and proportionality of the recording, balanced

against the right to privacy. The locations of cameras are therefore very

relevant, as is the consideration of having an audio recording feature on your

CCTV system. A balancing test must always be considered.

It is a legal requirement for you to be transparent about your use and purpose for

CCTV. You can help meet this requirement by having clearly displayed signage in

your school and providing your CCTV policy to data subjects on request.

We recently updated our CCTV Policy template and CCTV Signage template, both of

which are available on the ACCS website here .

These updates include broader purposes for use of CCTV, and additional provisions

in relation to the location of cameras.

For any queries in relation to this, please contact Hilary Treacy, Data Protection and

Legal Advisor on htreacy@accs.ie and 083 3474562.

2. Updated Template Protected Disclosure Policy and Notification Form.

Please find attached an updated Template Protected Disclosure Policy and

Notification Form for schools. This update takes account of the changes to the

original Protected Disclosure Act, 2014 which commenced in 2023.

The updates are to the range of categories of “Relevant Wrongdoings” which may be

reported under the Act.

Also, there are new prescribed timelines for communicating with a person making a

report, where a school is in receipt of a Protected Disclosure.

The attached template policy and the template Notification Form reflect the updated

legislation.

Is mise,

le mór mheas,

____________________

John Irwin,

GENERAL SECRETARY.

Addendum:

ACCS Template Attempted Disclosure Policy and Notification Form