French Watchdog Advises on Privacy Issues for School-Based Surveillance
Installing security cameras in schools must not infringe on the privacy rights of students and staff, French watchdog CNIL said Friday in a document that detailed deployment issues and touched on restrictions on who could view footage and how long it should be held.
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There are several kinds of video devices, but not all of them can be used in schools, it noted. Protection cameras outside schools, which partially film the public highway at entry and exit points, are permitted under certain circumstances for security and anti-terrorism, CNIL said.
Similarly, surveillance cameras used in school corridors, entrance halls and elsewhere to promote the safety of pupils, staff and equipment can also be installed under certain conditions.
Cameras that add a software AI "overlay" and make it possible to automatically analyze images by recognizing shapes and objects can't be installed on public roads to protect a school in the absence of a law authorizing it.
Schools that install video surveillance devices can film entry, exit and traffic spaces in the building, the watchdog said. They can't, however, film school living spaces, such as courtyards, classrooms and toilets during school hours.
Schools can keep people and property safe via less-intrusive means, CNIL said. Camera use must remain limited and complement other security measures, such as staff monitoring.
In nursery or elementary schools, the local government and the academic director of national education services decide whether to use cameras. In middle and high schools, the decision belongs to the head of the establishment after consultation with board directors on security matters.
The school chief must inform and involve the data protection officer, CNIL said. It recommended that relevant data controllers adopt a plan for the use of video surveillance that involves all actors, including the administration, staff, and parents' representatives.
Only people authorized to conduct surveillance, such as the head of the school, may review recorded images, the watchdog said. They must be trained and made aware of the rules governing video surveillance systems, and access to the images must be made secure to prevent unauthorized viewing.
The individual responsible for surveillance cameras must decide how long images can be kept. However, duration should be linked to the objective of the surveillance. In general, keeping images for a few days should be adequate to perform the necessary checks in the event of an incident and to allow required procedures to be set in motion.
If there is a proceeding, the images must be extracted from the device and kept for the duration of the procedures by the entity in charge of the process.
Pupils, parents and staff "must be informed that the place is under video surveillance," CNIL added. Any school that violates the rules can be reported to the National Commission on Information Technology and Freedoms, the police or the public prosecutor, it added.