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Introduction to this document

CCTV policy

If you have CCTV cameras installed at work, or are thinking of installing them, you should have a CCTV policy in place and you should also read the Information Commissioner's Office Code of Practice for Surveillance Cameras and Personal Information. Our CCTV policy will help you get over the first hurdle.

Data protected

Images which are recorded and held about identifiable individuals are covered by the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 and therefore, if you're thinking of installing CCTV cameras in the workplace to routinely capture images of individuals, you'll need to comply with your data protection obligations. The Code of Practice for Surveillance Cameras and Personal Information sets out the Information Commissioner's Office good practice recommendations on how you can comply with the data protection principles. As CCTV is intrusive, the starting point is to consider whether you should use it in the first place, assessing what purposes you wish to use it for, what benefits you will gain, what better solutions might exist and what effect it may have on people's privacy. Your impact assessment will need to conclude that CCTV is justified in all the circumstances.

CCTV considerations

Once you have taken the decision to install CCTV, you’ll then need to consider matters such as:

  •       ensuring effective administration - who has responsibility for the control of the system, for example, deciding how the system is used, what is to be recorded and to whom the images may be disclosed
  •       selection and siting the camera - you’ll need to choose equipment and locations which achieve the purposes for which you’re using CCTV
  •       using the equipment - it’s important a CCTV system produces images that are of a suitable quality and it will need to be checked regularly to ensure it’s working properly
  •       looking after the recorded material and using the images - recorded material should be stored in a way that maintains the integrity of the image; you'll need to have clear rules on who can view the images and where and, in addition, the disclosure of images from the CCTV system must be controlled and consistent with the purpose for which the system was established
  •       retention periods - this should reflect your purposes for recording images and you should not keep them for longer than strictly necessary for those purposes
  •       letting people know - you must let people know they're in an area where CCTV surveillance is being carried out. With employees, this means having a CCTV policy, as well as having clear and prominent signage
  •       dealing with data subject access requests - individuals whose images are recorded have a right to view the images of themselves and to be provided with a copy of the images.

Our CCTV Policy covers all these issues. Finally, our policy includes an optional section on vehicle tracking and monitoring which you should include if you intend to fit in-vehicle camera systems to company vehicles. If you do this, only monitor the vehicle during business use and have a privacy button installed to enable the recording to be deactivated during private use.