GUIDELINES ON THE USE OF CLOSED-CIRCUIT TELEVISION (CCTV) SYSTEMS IN COLEGIO DE SANTA ANA

OBJECTIVE

To establish clear guidelines on the utilization of CCTVs in Colegio de Santa Ana in ensuring the security of school vicinity, property and entity, with due regard to the privacy and personal rights of all people entering the premises as covered by said system.

RATIONALE

The installation of CCTVs in Colegio de Santa Ana serves the following purposes:

1. Security of Property and vicinity – to help deter offenders in entering the campus and performing illicit acts such as trespassing, robbery, etc.

2. Provide a safe space for stakeholders and ensure order – to help promote integrity, honesty and discipline

3. Discourages misconduct and inappropriate behavior of students – to provide evidence for investigations

INSTALLATION AND RECORDING

The CCTV system of Colegio de Santa Ana covers a vast amount of space where most of the school activities are done. The places where there are CCTVs are:

1. Classrooms

2. Hallways

3. Quadrangle

4. Gymnasium (two cameras, one camera with audio)

5. Offices (excluding the Principal’s Office and Director’s Office)

There are no cameras installed in places where there is heightened expectation of privacy:

1. Comfort rooms

2. Conference rooms

3. Resting rooms, check-up and examination rooms in the Clinic

Monitoring and recording devices are installed in the Principal’s Office. Recordings are stored for 20 days only, after which the previous records are overwritten by new recording.

AUTHORIZED PERSONNEL

The CCTV monitoring and recording devices are installed inside the Principal’s Office; as such, only authorized personnel are allowed inside. Access to the CCTV System is protected by password only known to authorized personnel. The authorized personnel are called Personal Information Controller (PIC) and Personal Information Processor (PIP).

The Personal Information Controller (PIC) controls the collection, holding, processing or use of personal information, via assigned authorized personnel (Personal Information Processor, or PIP)

The Personal Information Processor (PIP) operates the CCTV and is responsible for the viewing, playback, screenshots or downloading of data from the recorder, as permitted by the PIC and in accordance with the policies herein.

Mrs. Lennie A. Montevirgen – School Principal, Personal Information Controller

Ms. Joana Carla D. Olores – Principal’s Office Staff, Support IT

Mr. Edwin S. Tapas – IMT Officer

Ms. Olores, being a permanent staff of the Principal’s Office, is the primary PIP. Mr. Tapas takes the role for when Ms. Olores is unable to perform.

GUIDELINES FOR REQUEST TO ACCESS

Request for access to recorded data should not be contrary to law, morals or public privacy. For access regarding concerns on behaviour, discipline and incidents of misconduct, a primary investigation should be done first. Access may be granted if such investigations need further evidence and cannot be fulfilled in less intrusive means.

To obtain access to recorded data, the subject concerned should fill up a request form from the Principal’s Office. Sufficient details will be needed for a request to be granted:

a. Name of subject/person concerned (the data subject in the recorded video). If the subject/person concerned is a student, the name of the adviser (or the subject teacher during the time of incident) is required.

b. Specific location, date and time

c. Purpose of request for access

Once approved, only the requesting party and the PIP shall be allowed to enter the monitoring area and view such information. No photographs, recording or any kind of reproduction is allowed when such access is permitted. 

THIRD PARTY ACCESS REQUEST

Third party request is a request made by a person other than the data subject involved in the footage or the latter’s representative or relations (for students, the parents or guardians). The PIC will determine if such access is necessary, and if granted, they will need to sign a non-disclosure agreement. No photographs, recording or any kind of reproduction is allowed when such access is permitted.

Third party request may also be granted to law enforcement and courts of law, as well as media entities, subject to Section 8 of NPC Advisory No. 2020-04 (Guidelines on the use of Closed-Circuit Television (CCTV) Systems) and Section 12 and 13 of R.A. 10173 (Data Privacy Act of 2012).

OBTAINING A COPY OF THE CCTV FOOTAGE

The requesting third party may be given a copy of the CCTV recording provided:

- A request letter detailing the reason for such request, the name of the requesting party and relationship with the data subject (the person or student in the recording), or the name of the department of law and order or court, with signature affixed

- An I.D. to be presented for verification purposes only (no photocopy needed)

- The requesting party need to sign a waiver that states that they will be responsible for the data that was given to them, and that they should comply with the Data Privacy Act and other related issuances of the National Privacy Commission in relation to any processing of personal data involved in the CCTV recording that they requested

- The PIP may request for a USB Flash Drive to store the requested recording

- In circumstances where there is technical difficulty in providing a copy of the recording in video format, PIPs and PIC may provide still images as alternative, providing as much image as possible for the duration of the requested recording.

DENIAL OF ACCESS

Requests for CCTV access shall be evaluated with greater scrutiny to prevent violation of privacy rights, taking into consideration the general principles of the freedoms and rights of the data subjects recorded by the CCTV system, and a lawful basis for processing and access. Request for access may be denied due to the following reasons:

a. Incomplete information regarding the requested footage. Request may be amended to provide more specific information;

b. Access request is done by a person not involved in specified detail of coverage, unless it is for an investigation of a case or misdemeanor;

c. Request is done by a student or minor. Only persons in authority, persons of legal age, and persons of the law may be granted access pursuant to DPA and NPC Guidelines;

d. The requesting party, or its representative, is unavailable, or is lacking in necessary documentation;

e. The access request is frivolous or vexatious, or when such request would be unreasonable or involve disproportionate effort on the part of the PIP;

f. The recording has already been deleted by the time the request is received (should be within 20 days from present date);

g. PIPs are unable to perform their office due to other pressing matters. Request may moved to a different date;

h. Disclosure may affect an ongoing criminal investigation – without proper documentation from law enforcers and courts.

Should the PIPs or PIC deny a request for CCTV access, they shall provide the requesting party with a justification for such denial. Any doubt in the reasonableness of denying or limiting access to CCTV footages shall be liberally interpreted in a manner that would uphold the rights and interest of the individual whose personal data is processed. 

PENALTY

The misuse of obtained recorded data shall carry criminal, civil, and administrative liability pursuant to the provisions of R.A. 10173 (Data Privacy Act of 2012) and related issuances of the National Privacy Commission or any applicable law of the land.

Date approved: June 4, 2025