This policy describes how we comply with data protection legislation requirements in our use of CCTV.
Ownership and operation of CCTV
Gurpreet Duggal has overall responsibility for CCTV at the practice and the images produced.
Swann security is responsible for installing and maintaining the CCTV equipment and storing the images produced. It processes information on behalf of Gurpreet Duggal who is ultimately responsible for the information obtained from CCTV use at the practice.
The CCTV is operational between 24 hours a day
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 behaviour
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:
Front and rear exits and immediate surroundings
The CCTV does not have audio recording capability.
The CCTV monitors (screens) are located in the reception office
Use of CCTV recordings
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 behaviour 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 Gurpreet Duggal
The CCTV equipment will be checked regularly to ensure that it is in good working order and images recorded are of a sufficient quality to be used for the purposes listed.
CCTV images and recordings will be kept for 28 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 are will be processed in line with the practice policy on access to information.
Requests by third parties (such as law enforcement agencies or lawyers) for practice CCTV recordings should be submitted in writing to the practice owner. The practice owner:
Verifies the identity of the person / organisation and takes a copy of any identification documents, if required.
Decides 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.
If appropriate, transfers the requested CCTV recordings / images securely to the third party.
Keeps a record of the disclosures of CCTV to the third party.
If we are unsure about providing the requested information to a third party, we will seek advice from the Information Commissioner’s Office (ICO).
Any concerns or complaints about this policy should be raised with Gurpreet Duggal. If the concerns cannot be resolved, the practice may seek advice from the ICO.