General use of CCTV and Audio
We have CCTV and audio installed in Ty Seren, which is principally used for observation and assessment purposes, but also to aid an effective response to, or investigation of, safeguarding concerns.
CCTV remains on at all times in the corridors and communal areas of the centre and therefore there will be a record of all visitors (although this may not be actively monitored in real-time).
There is no audio in corridors or communal areas except there is audio in the two communal downstairs lounges.
Visitors will be asked to sign in and out on entering and leaving the premises and this includes a statement to inform visitors that there is CCTV and audio monitoring used within the service.
CCTV and Audio for observation and assessment purposes
CCTV and/or audio may be on within families’ bedrooms. At the start of the placement, CCTV and audio will be on permanently within a family’s bedroom. Our standard approach – unless otherwise agreed prior to the placement – will be for a member of staff to be in the same room as the baby all of the time (24/7) save for when the parent(s) are asleep, when the baby will be monitored remotely by the same dedicated member of staff on CCTV and audio (i.e. on a one member of staff / one baby basis).
As parents progress positively through placement (evidenced via weekly Placement Updates and Family Risk Assessments), CCTV and audio observations will reduce. During stages 1 & 2 of placement, even when the CCTV and/or audio is not being monitored live, the CCTV and audio will always be recording and can be made available should there be a concern (within a reasonable timeframe) that needs investigating.
During stages of 3 and 4 of placement, CCTV and Audio will not be recording constantly, but will be used at set times only, to check in on families for agreed amounts of time, or for assessment purposes (reviewing targeted observations e.g. bedtime routine, or mealtimes), adding another layer to our ability to assess how families are consistently able to implement positive parenting practices. The amount of time families are observed via CCTV will depend on identified risks and support needs, as outlined in the Family Risk Assessment and Weekly Placement Update.
When CCTV and audio is no longer deemed necessary for observation or assessment purposes, this will be “turned off” in the individual’s room meaning that the camera is not recording but staff can still access the “live view” function to see quickly what is happening in a family’s room in response to a potential safeguarding concern.
All of our families are made aware, prior to admission and reminded during their stay, that if we were concerned, or a safeguarding issue was to arise, at any stage of placement, CCTV and/or audio could be turned back on without their immediate prior consent in the short term, whilst longer term safeguarding measures are implemented. The rationale for this would be fully documented and shared with all involved parties.
For the avoidance of doubt, where there is a safeguarding concern that requires additional monitoring of the baby – where for example staff would need to rapidly attend to the baby – the Centre’s practice is ordinarily to provide in-person monitoring and observation (not the use of CCTV and audio).
Only staff trained, and assessed as competent in the use of CCTV, will be allocated to CCTV duties (i.e. staff at band 2 or higher). We have a dedicated CCTV room which provides staff with a quiet space, free from distraction, in which to monitor CCTV on a focused basis. In addition to viewing the baby on their own laptops, there is a bank of monitors on the wall, providing a view of all communal areas and rooms being monitored. Where families are being monitored via CCTV, a general summary is made by the member of staff of the observation and recorded in our case recording system.
CCTV and Audio Agreement
All families, and commissioners, are made aware of the detailed arrangements relating to the use of, processing, storing and deletion of CCTV and audio within the placement and this is set out in a CCTV and Audio Agreement that is signed before the placement commences.
It is illegal to keep CCTV and Audio recordings beyond the required timeframe for the intended purpose. In simple terms, this means that footage relevant to the parenting assessment is extracted from the system so it can be made available to parents, statutory representatives and/or the Court. Other footage is deleted in agreed timeframes.
Changes from historic approaches used when the centre was operated as Family Crosspoint
As PfP, we have changed the way we use CCTV in Ty Seren in relation to monitoring families. We no longer have staff members monitoring CCTV in the Centre on a 24/7 basis as this was not effective from a safeguarding perspective. Having CCTV on 24/7 with multiple families being monitored at the same time was neither safe nor effective and, we believe, enabled stakeholders to have a misleading impression about the type of harm that can be prevented. As a remote monitoring tool, there are inherent limits to how effective CCTV systems can be in preventing harm to children compared to in-person support.
We have therefore changed our model to one that values in-person support in situations where the assessed and commissioned needs of each family require this. As such CCTV is no longer used on a 24-hour basis for all families, and instead will be used proportionately, in response to identified risks, as outlined above.
As per the Information Commissioner’s Office guidance, all individuals have a right to privacy where their dignity and autonomy is respected. This includes ensuring the use of CCTV for observation purposes should always follow the least restrictive practice possible, as long as this is assessed as safe for the child.