If you are concerned about the security of your site, the safety of any customers and want to have video evidence that legally protects your company in case of any dispute, a CCTV installation can seem like an ideal solution.
Whilst it can help in many cases, there is also considerable responsibility that comes from operating a CCTV system, and several immutable golden rules will ensure that you balance your needs for security and surveillance with data protection and privacy rights.
With that in mind, here are the golden rules you should (and in some cases must) follow when installing your CCTV system.
Your CCTV Installation Should Be Reasonable And Justifiable
The first golden rule is that you need to have a good reason for your CCTV installation, one that considers how users of your building that may be captured by the cameras would be affected by it.
For example, CCTV is often required in offices or in retail venues to provide evidence of criminal activity such as shoplifting, but it should only be used for that purpose and not to monitor staff without their consent and without a strong justification.
The more intrusive the CCTV, the stronger the justification needs to be, and if you cannot provide a strong enough explanation for why you need cameras to be placed, you should consider alternative security systems.
All of this will need to be recorded in writing; you must prominently signpost where CCTV is being used and carry out an impact assessment if there is a major chance that it could affect people.
Your CCTV Installation Must Not Be Used Where There Is An Expectation Of Privacy
As well as this, unless there is an extremely strong justification to do so, you must not install CCTV in locations where someone would have a reasonable expectation of privacy.
Toilets, showers, changing rooms and hotel bedrooms are examples of places where a person would have a realistic expectation of privacy, and thus CCTV would be seen as being in breach of their rights.
This can not only affect the rooms where CCTV can be installed but their placement; a camera cannot be installed in such a way that it captures the inside of an area where a person has a reasonable expectation of privacy.
Your CCTV Installation Should Only Use Audio If There Is A Justification To Do So
Some CCTV systems incorporate audio recording as well as video recording, but doing so requires a much stronger justification, as recording conversations risks intruding on a person’s privacy.
It is rare for CCTV systems to have a justification for recording audio unless there is no alternative in order to protect staff and your company.
For example, a police interview room would use CCTV and recorded audio, as this is a necessary part of gathering evidence as part of a criminal investigation.
Similarly, if there is a high risk or previous cases of inappropriate or aggressive behaviour against staff by customers, audio CCTV may be considered justifiable, but it must be made clear that audio may be captured as well as video.
As well as this, continuous audio requires stronger justifications than audio that is switched on; in the latter example, it is more likely that the audio recording would be switched on only when required.
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