CCTV policy.
How CCTV is used, stored, and accessed at our centres, in line with privacy law.
The safety, rights and best interests of children are our paramount consideration in all decisions and actions.
Aim
To implement a mechanism which complies with the Australian Privacy Principles and can be used to help minimise or eliminate immediate risks to children, employees or visitors, or to support matters which may be investigated by the Police or Courts/Tribunals.
Our services (St Ives Chase Kindergarten, Normanhurst Child Care Centre, West Ryde Long Day Care Centre, Roseville Preschool Kindergarten) use closed-circuit television (CCTV) exclusively to enhance children’s safety and wellbeing; all operation complies with the Privacy Act 1988, state and territory surveillance legislation, the Education and Care Services National Law, and sector guidance on children’s digital rights (Early Childhood Australia, 2018; ACECQA, 2024). CCTV must never substitute active supervision; rather, it supplements vigilant, in-person practices that uphold each child’s right to privacy, dignity, and protection.
Implementation
We may install further CCTV cameras to help ensure the safety and security of children, employees and visitors to our service. Surveillance footage may be used to minimise or eliminate immediate risks to children, employees or visitors, or it may be used as evidence in any matter which involves the Police or Courts/Tribunals. Currently our CCTV is located in the outdoor areas and surrounding the exteriors of the buildings. We do not currently have CCTV covering the interior of the building or indoor classroom learning spaces.
If we install further CCTV cameras we will comply with privacy and other legislative requirements by:
notifying employees and families in writing at least 14 days before use:
that CCTV cameras will be used for security and safety purposes
when they will start recording
whether they will record footage continuously or intermittently
the period of surveillance ie a specific period or for an ongoing period
how long the footage will be kept
who has access to the footage – ie employees or owners who use it to ensure the safety of children, families or visitors, the Police, legal representatives in the event of a Court case, and employees or owners whose role it is to maintain or delete the video
when and how the footage will be deleted
that they may consult with the Nominated Supervisor about the conduct of the surveillance
displaying signs at each entrance telling people that CCTV cameras are in use and they may be recorded
recording vision but not sound
ensuring there is no external access to the footage eg families can’t log in and view it
ensuring there is no surveillance of adult or children’s toilets, bathrooms or change rooms and no surveillance of lactation rooms. This does not prevent CCTV vision of the entrance/exit to these areas.
During the 14 day notice period the Approved Provider or Nominated Supervisor will consult in good faith with employees and families who raise issues about the surveillance by giving them a genuine opportunity to influence the conduct of the surveillance.
Once any further CCTV is in operation, the Nominated Supervisor will provide new employees or families with a copy of the CCTV policy before they start at the service.
Staff at our service will:
Safeguard children by positioning cameras only in approved communal areas and exit points.
Collect, store, and share footage in strict accordance with the Australian Privacy Principles (APPs) and relevant surveillance laws.
Inform families, educators, visitors, and contractors of CCTV use through signage, enrolment information, and policy access.
Obtain written consent before using images or video for any purpose beyond security or incident investigation.
Review CCTV practices annually or sooner if legislative changes occur.
Legislative requirements
This policy reflects the legislative requirements for the use of CCVT and includes, but is not limited to:
Section/regulation Description Authority/Responsibility For
National Law s.165 Duty of approved provider, nominated supervisor, and educators to ensure adequate supervision.
National Law s.167 Duty to protect children from harm and hazards.
National Regulations r.168(2)(n) Requirement for a privacy and confidentiality policy (includes digital records).
Privacy Act 1988 (Cth) – APPs 1-13 Collection, storage, use, and disclosure of personal information (includes images).
Strategies
1. Installation and placement
Install fixed cameras only in indoor learning areas, entrances, and outdoor play yards; avoid change rooms, toilets, and staff rest areas.
Position cameras to minimise unnecessary capture of neighbouring properties or public spaces.
2. Access and use of footage
Restrict live viewing and playback to the approved provider, nominated supervisor, or delegated persons for incident investigation.
Record all access in a CCTV access log (date, time, reason, user, outcome).
3. Secure storage and data retention
Store footage on encrypted, password-protected servers located in Australia or on-site network-attached storage.
Retain recordings for 30 days unless footage is needed for a reportable incident, investigation, or legal proceeding; delete securely thereafter.
4. Communication and consent
Display clear signage at all entry points stating that CCTV is in operation for safety purposes.
Give staff and visitors notice that they may be recorded while on the premises.
5 Breach management and review
Report unauthorised access, disclosure, or loss of footage to the approved provider and nominated supervisor within one working day.
Conduct an incident review, notify affected parties, and lodge any required data breach notifications with the Office of the Australian Information Commissioner (OAIC).
Evaluate system performance and policy compliance annually, incorporating feedback from families and educators.
Roles and responsibilities
Role Authority / Responsibility Approved Provider Approving policy; funding, selecting, and maintaining CCTV system; ensuring compliance with legislation and APPs; authorising release of footage to external agencies.
Nominated Supervisor Implementing policy; maintaining CCTV access log; liaising with families and regulators; training staff on privacy obligations.
Early Childhood Educators Actively supervising children; reporting technical faults or privacy concerns; modelling respectful use of digital technologies.
Families Reviewing and acknowledging CCTV policy; raising concerns or requests regarding their child’s image; supporting privacy practices at home.
IT / Security Contractor Installing and servicing CCTV equipment; ensuring data security controls meet Australian Standards; reporting vulnerabilities promptly.
Source
- National Quality Standard
- Education and Care Services National Regulation
- Education and Care Services National Law Act 2010
- Surveillance Devices Act 2007
- Workplace Surveillance Act 2005
- Privacy Act 1988 (includes Australian Privacy Principles)
- Centre Support
- CELA
This policy is the property of Eikoh Seminar Australia Pty Limited and must not be reproduced without the consent of management.