Do You Have A Thorough CCTV Policy?

Apart from monitoring unwanted visitors with malicious intent, CCTV systems can be used for health and safety compliance, lone worker protection and even as a backup to existing intruder and fire detection systems.

"There are a whole host of reasons to install a CCTV system!"

But for any business, a clear CCTV policy goes a long way to ensuring everyone knows what is being recorded, why it's being recorded, and makes it very clear who will see the footage, how long it will be kept and what it will be used for.

Your CCTV Policy document should have a number of sections:

  1. The reasons for installing CCTV
  2. What internal controls and procedures the footage is subject to
  3. Who will maintain the systems and have access to the footage
  4. How the footage will be stored, how long for and how it will be disclosed in the event of a crime
  5. How the company advertises the use of CCTV at their premises and who to contact for further information.

The Data Protection Act 1998 (DPA) covers CCTV systems regardless of whether the cameras are internal, external or both. If people are to be filmed then the CCTV Code Of Practice must be followed at all times. The Information Commissioner's Office has also produced a guidelines document for the use of CCTV in the workplace.

Organisations in the public sector should be particularly aware of the right to privacy which their employees have under the EU Human Rights Act as it applies directly to them. However, it is still important for employers in the private sector to consider these rights, and to ensure their monitoring is not disproportionate or intrusive, as tribunals and courts are expected to take it into account when making their decisions in the event of employment disputes.

"What about covert monitoring?"

Should there be a need for covert monitoring (where an employee is not aware they are being filmed, remember, this will only be legally justifiable in exceptional circumstances where there are proper grounds to suspect criminal activity or malpractice.

Good practice means:

  • Senior management authorises its use
  • It is only carried out for a set timeframe and as part of a specific investigation
  • The risk of intrusion on innocent workers is considered
  • Areas where privacy is expected remain private
  • Limited numbers of people are involved.

If information obtained during covert monitoring inadvertently brings up evidence of other malpractice, this evidence should not be used against employees unless it is a case of serious gross misconduct. Where the misconduct is minor in nature, use of the 'secret' footage to discipline individuals will not be allowed.

"Remember to consider your employee's rights!"

Although the use of CCTV has its advantages, it can be very time consuming dealing with employee complaints and ICO investigations. It can also lead to reputational damage and mean that employers are prevented from relying on data which would otherwise have been very useful to them.

By carrying out a full impact assessment, communicating with employees and processing data in accordance with the DPA, a CCTV policy acceptable to all can be created, the adverse impacts can be avoided and the benefits maximised.

If you'd like to know more about creating a CCTV policy for your organisation then call us on 0845 287 3622. 

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