The arrival of the GDPR in 2018 and the UK’s corresponding 2018 update to the Data Protection Act, highlighted the necessity of having secure procedures in place when dealing with Personally Identifiable Information (PII), and the importance of awareness when dealing with such data.
When talking about PII, the first thing that jumps to mind is email addresses, names, telephone numbers… but aren’t we forgetting something? Yes, that images are also PII.
When it comes to CCTV systems, this means that if you can identify individuals by the images captured on your video surveillance system, then your system must meet the same data protection requirements as any other system processing PII.
If you’re installing a new security system, or you have an existing one on your premises, you need to make sure that your recording of images has a lawful basis.
Which Lawful basis is applicable?
For most businesses, it’s likely that the appropriate lawful basis for using video surveillance will be the legitimate interest of the organisation. Examples of legitimate reasons for processing personal data include the prevention and detection of crime, safeguarding staff and visitors, ensuring compliance with health and safety procedures, and improving productivity.
In all cases, a business will still be required to justify the area under surveillance. As even inside a work premises, employees have a right to privacy.
One of the first things to think about is installing a visible, clear signage informing subjects that the area is under video surveillance and the purpose of this.
You should also make sure that there is a clear reason for installing cameras in an area, this reason should be reviewed routinely and whenever changes are applied to your security system.
The Information Commissioner’s Office (ICO) code of practice advises that you should regularly evaluate whether it is necessary and proportionate to use your CCTV system.
The latest CCTV code of practice addresses the growing public concern when it comes to the use of CCTV and the legal requirements for those who implement/adopt surveillance systems or/and live streaming cameras.
This blog post is merely an introduction to the legal requirements for CCTV, more information can be found on the ICO website.
If you need any further advice, please don’t hesitate to get in touch.
To receive the latest in terms of security, products reviews and expert advice, sign up to our quarterly newsletter.