Webcam Policy

1 Introduction

“A device that can convert a component video feed into either a series of digital still images or an IP based video feed.”

The facility to use webcams to transmit images can potentially be applied to any RVR activity.

RVR webcams can be divided into two primary purposes which are essentially governed by their use. The two purposes are webcams for publication purposes (referred to as publication webcams) and those webcams which are operated for “business as usual” purposes which in most instances do not record images for publication purposes, although this is not a hard and fast rule (referred to as non-publication webcams).

Examples of where the station uses publication webcams are:
1. webcams inside RVR broadcasting studios;
2. Traffic webcams (generally owned by third parties);
3. Webcams at live events/outside broadcasts;

Examples of the station’s business as usual non-publication webcam use:
1. Webcams used for surveillance.

As you can see from the above, there may be instances where webcam usage may fall into both publication and non-publication purposes. Due care should therefore be taken when considering the purpose for which a webcam is engaged.

This policy is specifically aimed at ensuring the appropriate use of webcams throughout RVR either by establishing policy, or by directing users to the appropriate policy already governing specific purposes for which webcams may be used.

The station acknowledges that webcams can make a significant contribution to enhancing radio programmes and activities, as well as allowing the station to conduct its business in line with the operating requirements of modern business which includes the need for video conferencing and similar activities. However, it is important to ensure that the use of webcams by the station does not compromise the right to privacy of individuals. Those affected include presenters and performers, RVR volunteers, pennine acute staff and freelancers who support the production of programmes and internet broadcasts, casual workers, agency and temporary staff, visitors to the RVR station and members of public (whether intentionally or inadvertently).


2 Effect of UK Legislation
The Data Protection Act 1998, the Information Commissioner’s Code of Practice on the use of CCTV and the Human Rights Act 1998 (which gives individuals a right to privacy) will, in certain circumstances, impose restrictions on the use of webcams without prior consent of the individuals being captured by the webcams.
Individuals can include RVR volunteers, pennine acute staff, performers and presenters, casual workers, freelancers, contractors, agency and temporary staff, visitors to RVR premises and members of the public.


3 Installations of Webcams
Publication webcams should only be installed or used on any RVR service where a clear editorial benefit to the station can be identified. A publication webcam should be installed and used for a particular and defined purpose and once the reason for its installation comes to an end it should be disconnected or removed.


4 Notification
Signs indicating the presence of publication webcams should be clearly visible and legible to the public within or at the entrance to the area covered by the publication webcam.

Use of Webcams in Roch Valley Radio Studios
Publication webcams should be installed in RVR studios only for use in the broadcasting area, and their location and purpose should be clearly indicated.

The following information should be available to all persons who might come within the field of view of
publication webcams:
• The purpose of the webcam (including archiving) and the internet site it will appear on; and
• A permanent display of the relevant internet page on a PC, or monitor, which is easily accessible.

Appearance on a studio webcam is voluntary, and there will be no requirement or pressure for anyone to participate against their will. No action must be taken against a volunteer who refuses to enter the field of view of a publication webcam. The producer of a radio programme must alert all persons (including participants) who are likely to enter a webcam area, of the presence and purpose (including archiving) of webcams well in advance of entering the studio area.

In the case of interviewees, guests and artists, this should be before they arrive at the station and specific (and where practicable, written) consent should be obtained from them prior to their appearance on the publication webcam. If they do not consent to this then the view of the webcam should be changed (such that it still complies with this guidance) or the second studio is used where there is no active webcam installed.


5 Use of Webcams for Traffic Reporting
The use of traffic webcams owned by third parties must be subject to written agreements with the third party owner, which must establish that the owner is entitled to license third parties to use his or her webcam(s) for broadcast purposes. If a webcam feed is taken from a third party, the third party must be a reputable provider, and particular care should be taken when taking feeds from outside the UK.

Equipment must only capture images relevant to the purpose of the monitoring, so if a system has been established to monitor traffic flow, the cameras should not capture details of the drivers or vehicles (e.g. individual number plates).


6 Use of Webcams at Live Events/Outside Broadcasts
If individuals are likely to be identifiable in publication webcam images/footage of live events or outside broadcasts, appropriate signs must be placed outside event/outside broadcast premises to give the public reasonable warning that they are entering a zone covered by publication webcam equipment. This is because the use of publication webcams is not as obvious to the public as the use of television cameras at live events or outside broadcasts.

Advance notification in addition to signage may be appropriate depending on the size and/or nature of the event by, for example, including reference to the presence of webcams on posters/tickets for the event. In such cases, the posters/tickets should state what the presence of the webcams will mean, e.g.;
• “This event may also be transmitted worldwide over the internet on”.


7 Children
A greater degree of consideration must be given to the editorial reasons for installing publication webcams in areas primarily occupied by children if there is any chance of either the children, or the location, being easily identified.

If publication webcam images are proposed to be transmitted on a RVR website which is principally intended to feature individually identifiable children, it will normally be appropriate to seek the written consent of the children’s parents or legal guardians. The younger or more vulnerable the child, the more likely it is that consent will be essential. However, if children are to take part in a publication webcam transmission during school hours, it will normally be possible to gain consent from the school Headteacher, who can act in loco parentis.

A child’s own consent should always be sought about being involved in webcam transmissions where they would be clearly and individually identifiable, and a child’s refusal to take part should not be overridden.

Explanation to children about the purpose of the webcam transmission should be in a language and terms that they can understand. In deciding when a child can give consent, the stage of development and degree of understanding as well as chronological age should be taken into account. The consent of under 16s should be in addition to, not instead of consent from the parent or guardian, or Headteacher during school hours.


8 Retention/Exploitation of Images
The station must not retain webcam images longer than necessary in relation to the purpose for which the camera is operated. Therefore, as a general rule, webcams that broadcast a live feed from the studio are retained for 4 hours before being wiped. During this time the recorded footage is publically available via the live stream on the stations website.

If the footage/content has been published, then the streams or images are deemed to be “in the public domain” and therefore suitable for archiving along with other RVR published content.


9 Sound
If a webcam has the ability to record sound, its ability should not be enabled except where it is being used for a webcast or if the recording of sound is otherwise editorially justified.