Video surveillance (including guidance for organisations using CCTV)

The steady growth of the use of video surveillance systems across public and private sectors, has led to both fixed and mobile cameras becoming more accepted in society. As video surveillance technology becomes more mainstream and affordable, it is now more common to see technologies such as smart doorbells and wireless cameras. Traditional closed circuit television (CCTV) also continues to evolve into more complex artificial intelligence (AI) based surveillance systems. These can process more sensitive categories of personal data.

The ways in which the technology is used also continue to develop. This includes connected databases utilising Automatic Number Plate Recognition (ANPR) or the use of Facial Recognition Technology (FRT) in public spaces. Often they process the personal data of large numbers of the general public for security, crime prevention or for other specified purposes such as digital advertising. However, some of these uses can be particularly intrusive, especially if processing takes place without the knowledge of the individual.

Building public trust and confidence is essential to ensuring that the benefits of any new technology can be realised. The public must have confidence that the use of surveillance systems is lawful, fair, transparent and meets the other standards set in data protection law. The rights and freedoms of individuals can be greatly affected where decisions are made about them based on particularly intrusive means of processing personal data. For example, recording in places individuals would not normally expect. In addition, these surveillance techniques can also play an influential role in how people may behave and move around freely in public spaces. It is therefore important that the use of surveillance is not seen as the cure to the problems that organisations may face. But instead, a helpful supporting tool where lawful, necessary and proportionate in the circumstances.

We have developed this guidance to help organisations in the public and private sector, who use video surveillance systems to collect and process personal data. It will help you to stay within the legal requirements of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018). This guidance will also be relevant to law enforcement authorities that are using video surveillance separately for any purposes under the UK GDPR.