This policy describes how we comply with data protection legislation requirements in our use of CCTV.
Closed-circuit television (CCTV) is installed at the Practice premises for the purposes of staff, patient, and premises security.
The use of CCTV falls within the scope of the Data Protection Act 2018 (“the UK implementation of The General Data Protection Regulation (GDPR)”). This code of practice follows the recommendations issued by the Data Protection Commissioner in accordance with powers under Section 51 (3)(b) of the 2018 Act.
Ownership and operation of CCTV
Dr Manoj Bhardwaj has overall responsibility for CCTV at the practice and the images and data produced.
The CCTV is operational 24/7.
Purpose of CCTV
We use CCTV recording to:
- Protect the practice premises and property
- Increase the safety of practice patients, staff and visitors
- Deter criminal activity and anti-social behavior
- Assist in the apprehension, identification and prosecution of offenders
- Provide evidence to a court or tribunal
- Comply with a legal obligation.
Location of CCTV
CCTV cameras at the practice cover the following areas: waiting area, corridors, decontamination room, reception and surgeries.
The CCTV does not have audio recording capability, video footage only.
All CCTV cameras will be Overt Recording, and surveillance signage will be clear and prominent.
Use of CCTV recordings
In order to comply with The Data Protection Act 2018, data will be:
- Fairly and lawfully processed
- Processed for limited purposes and not in any manner incompatible with those purposes
- Adequate, relevant and not excessive
- Not kept for longer than necessary
- Processed in accordance with individuals’ rights
CCTV images and recordings are personal information and, when using or processing the information, we will respect the legal rights of the individuals shown in the recordings.
We will not share images or recordings except in the following circumstances:
- If requested by the local authority, police or courts for the investigation, prevention or prosecution of anti-social behavior or criminal activity
- For bringing or defending a legal claim
- To comply with a police warrant or an order given by a court or tribunal.
Access to the CCTV monitors and/or recorded images, for the purposes listed above, is restricted to Dr Manoj Bhardwaj.
The CCTV equipment will be checked regularly to ensure that it is in good working order and images recorded are of sufficient quality to be used for the purposes listed.
CCTV images and recordings will be kept for 7 days unless they are being used in the investigation of an incident (for example theft, damage or violence). After this time or following the conclusion of an investigation, the recordings will be destroyed and/or irretrievably deleted.
Requests for CCTV recordings
Requests by individuals for recordings of themselves will be processed in line with the practice policy and GDPR regulations on access to information (An Access Request Form needs to be filled in).
Requests by third parties (such as law enforcement agencies or lawyers) for practice CCTV recordings should be submitted in writing to Dr Manoj Bhardwaj / Practice Manager. This:
- Verifies the identity of the person/organization and takes a copy of any identification documents, if required.
- Decide whether providing the CCTV recording would satisfy one or more of the purposes listed in this policy.
- Considers the rights of the individuals shown in the CCTV, and balances the protection of these rights against the reasons for the request. Some images may require editing to protect the privacy of individuals (for example blurring images of individuals not involved).
- If appropriate, transfer the requested CCTV recordings/images securely to the third party.
- Keeps a record of the disclosures of CCTV to the third party.
- To meet the GDC’s ethical standards, personal information (including images) will only be disclosed without consent to protect patients or the public “in exceptional circumstances”.
This includes “if a patient puts their own safety or that of others at serious risk, or if information about a patient could be important in preventing or detecting a serious crime”.
If unsure about providing the requested information to a third party, Dr Manoj Bhardwaj / Practice Manager should seek advice from the Information Commissioner’s Office (ICO).
This policy will be reviewed annually
Any concerns or complaints about this policy should be raised with Dr Manoj Bhardwaj / Practice Manager. If the concerns cannot be resolved, the practice may seek advice from the ICO.