Personal information
Webcams
Editorial control of webcams
Editorial responsibility for webcams
Webcams and privacy
The British Council must not infringe privacy without good reason. In order to exercise our rights of freedom of expression and information, we must work within a framework that respects an individual’s privacy and treats him or her fairly.
Private behaviour, correspondence and conversation must not be brought into the public domain unless there is a clear public interest. The law also protects privacy in the United Kingdom, including the Human Rights Act 1998.
People trust the British Council and we must be transparent with them. We must make it clear to people how we intend to use their personal information even if it is simply an e-mail address or telephone number. Personal information is collected, for example, when people enter competitions, register with an interactive community or become part of a database of contributors. See section 16 (The Law) on data protection.
Contributors’ personal details, comments or other personal information must not normally be given to third parties without the consent of the contributor. If we have consent, a contract must require the third party to use the information only for the use agreed between the contributor and the British Council.
Activity managers may gather personal information about contributors and potential contributors via their websites before storing it in databases. This information must not normally be accessible to other departments outside the production area which has collected it. Any proposal to make an exception must first be referred to Legal Advisor.
Any proposal to collect personal information on a British Council publicly funded site, which might be disclosed to third parties, must be referred to the Senior Internet Business Development Manager who may consult Legal Advisor.
We must not send e-mails to people who have not agreed to receive them. If personal information is going to be used for promotion, marketing, research or any other secondary purpose, our users must 'opt in'. For example, we must not send promotional e-mails about our output when people have originally given us their e-mail address in order to enter a competition. See section 16 (The Law) on data protection. However, in some instances, we may wish to offer our users the opportunity to e-mail British Council online content to a friend.
When sending e-mails to a list of British Council subscribers, we must ensure that the e-mail addresses of the subscribers are not visible to others on the list. For more on e-mail, see section15 (Interacting with our audiences).
We must take particular care when collecting personal information from children. See section 7 (Children).
Webcams give our users access to a rich mix of additional information. But their use on our site raises a number of editorial and legal issues. Webcams and their feeds require an appropriate level of editorial control and responsibility. There are also important questions of privacy and consent. See below.
We must maintain editorial control of any webcam that transmits live to British Council sites. This will reduce the risk of harmful, offensive or unduly prominent images appearing on any of our sites.
Where this is not practical, the risk of allowing a third party’s live output to appear on a British Council site must be assessed carefully before we decide to transmit. This will depend partly on the source, the shot, the subject matter and the format.
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Taking a feed from a civic body of a static shot of a city skyline may be acceptable, with appropriate safeguards. |
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It is unlikely we would embed a live video stream feed from an event sponsor. Any such proposal must first be referred to the Senior Internet Business Development Manager. |
Activity managers must refer to the Senior Internet Business Development Manager before agreeing to put a third party’s webcam output on a British Council site or platform.
Whoever owns the webcam and the feed, we must retain editorial responsibility for monitoring the output if it appears on our site. This must lie with the person who has editorial responsibility for the British Council site or platform on which the output appears. The level of monitoring will partly depend on the circumstances.
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A website manager must be in a position to cut the feed from a live webcam if necessary. |
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We should normally only transmit live pictures from a webcam at times when we have the resources to monitor the feed. |
The Data Protection Act 1998 and the Data Protection Commissioner’s Code of Practice on CCTV restricts the use of webcams in some circumstances. Operators must think carefully in advance about privacy and consent issues. See section 16 (The Law) on the Data Protection Act.
The British Council must only operate a webcam for a clear reason. It must be removed when that purpose has been achieved. Webcams must not be installed to capture close-up images of private areas such as houses, gardens or offices without the written permission of the owner.
The need to warn people that they may be on camera does not arise if individuals are not identifiable from the webcam output. But where individuals are likely to be identifiable, for example where a webcam transmits a sufficiently high level of detail at a live event, staff responsible for the webcam must take all reasonable steps to warn members of the public that a webcam is being operated by the British Council within a defined area. This can be communicated by notices outside the venue and a line on posters or tickets.
If a webcam is to operate in a public space like a street or a park, the same rule applies. If individuals can be clearly identified, the operator must put a warning notice near the webcam.
More guidance on how the Data Protection Act and the Code of Practice on CCTV affect webcams can be obtained from Data Protection Officer and Legal Advisor respectively.
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