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3 December 2023

Overall rating

Your overall rating was amber.

  • 2: Not yet implemented or planned
  • 1: Partially implemented or planned
  • 6: Successfully implemented
  • 0: Not applicable

RED: not implemented or planned

Your business has a policy and/or procedure covering the use of CCTV and has nominated an individual who is responsible for the operation of the CCTV system.

 

Suggested actions

You should:

  • ensure that you have a policy in place to allow you to use CCTV consistently;
  • clearly define in the policy the specific purposes for the use of CCTV information and document procedures on how you should handle this information; and
  • include guidance in the policy on disclosures and how to keep a record of these.

Guidance

Surveillance Camera Commissioner website

Surveillance Camera Code of Practice, GOV.uk website

Surveillance Camera Code of Practice – Self Assessment Tools, GOV.uk website

Your business has established a process to recognise and respond to individuals or organisations making requests for copies of the images on your CCTV footage and to seek prompt advice from the Information Commissioner where there is uncertainty.

 

Suggested actions

You should:

  • establish a clear process for staff to follow when handling requests from individuals who wish to access copies of their own images. The process should help staff to:
    • recognise a request;
    • identify and obtain the requested footage;
    • provide the requested information in a secure and approved manner;
    • keep the necessary records about a request and how you handled; and
    • seek advice where necessary, whether internally or from the ICO.

Guidance

Surveillance Camera Commissioner website

Surveillance Camera Code of Practice, GOV.uk website

Surveillance Camera Code of Practice – Self Assessment Tools, GOV.uk website

Guide to the UK GDPR – Right of access, ICO website

AMBER: partially implemented or planned

Your business clearly informs individuals of your use of CCTV.

 

Suggested actions

Where measures have only been partially implemented, please select the appropriate actions from the detail below:

  • put up clearly visible signs to ensure that anyone likely to be captured by the cameras is aware of them;
  • ensure that signs include the contact details for the system’s owner; and
  • consider including a web address where you can provide more detailed information about the system, for example how to exercise their rights and how long you keep images for.

Guidance

Surveillance Camera Commissioner website

Surveillance Camera Code of Practice, GOV.uk website

Surveillance Camera Code of Practice – Self Assessment Tools, GOV.uk website

Guide to UK GDPR – Right to be informed, ICO website

 

GREEN: successfully implemented

Your business has identified and documented the potential impact on individuals’ privacy and taken this into account when installing and operating the CCTV system. You regularly review whether CCTV is still the best security solution.

Your business has paid the data protection fee to the Information Commissioner's Office (ICO).

Your business trains its staff in how to operate the CCTV system and cameras (if applicable) and how to recognise requests for CCTV information/images.

Your business only retains recorded CCTV images for long enough to allow for any incident to come to light (eg for a theft to be noticed) and to investigate it.

Your business has ensured that the CCTV images are clear and of a high quality.

Your business securely stores CCTV images, limits access to authorised individuals and regularly checks that the CCTV system is working properly.

 

 



Bespoke tools have been developed by the Surveillance Camera Commissioner
to help organisations prove their surveillance camera systems comply with the code of practice. This code applies to relevant public authorities in England and Wales, but others can adopt it voluntarily. Although, the Information Commissioner and the Surveillance Camera Commissioner have separate roles and powers, they liaise to make sure guidance and tools are consistent.

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