DPA May 2018
ABM Fire & Security Ltd likes to keep in touch with all issue relevant to our industry and keep our clients both compliant and at the cutting edge of technology available to them.
In May 2018 there will be changes to the Data Protection Act (DPA) with regards to CCTV. We have highlighted the extract below.
If your organisation has CCTV systems in operation, you should consider the following:-
- Have you performed a Privacy Impact Assessment (PIA) and do all your CCTV cameras serve a legitimate purpose?
- Have you made sure the CCTV system has the ability to be switched on or off, if this is appropriate, so that recording of footage is not continuous? The system should also have the ability to stop capturing either footage and/or sound recordings both of which should work independently of each other. Capturing both could be deemed excessive and you would need to demonstrate clearly the reasons for recording both and what legitimate grounds you are relying on to justify this.
- If you capture sound recordings are they obtained when it is absolutely necessary and for this specific purpose? CCTV surveillance systems should not normally be used to record conversations between members of the public or members of staff as part of a working environment. Recording conversations is highly intrusive and unlikely to be justified and performance of a PIA would identify this.
- Are recordings from the CCTV system securely stored and are you able to restrict access to them?
- Are your CCTV recordings of sufficient quality to be fit for their intended purpose and is there a regular check that the date and time stamp recorded on images is accurate?
- Are you able to access recordings easily at particular locations or times in order to comply with a subject access request or police investigations?
- Are there sufficient security safeguards in place to prohibit interception and unauthorised access?
- Do you have an information retention policy which is documented and understood by those who operate the CCTV system?
- Do you ensure that you delete CCTV recordings when they no longer serve a purpose?
- Have you notified individuals with fair processing information including letting them know when they are in an area where a surveillance system is in operation and their right to access their recordings/images?
- Have you put in place appropriate CCTV policies and do your staff know how to respond to requests from individuals for access to CCTV recordings?
On of the best ways to meet the requirements of the new DPA legislation is to upgrade your CCTV system to a digital platform. This can include NVR recording, cloud recording and IP CCTV systems. We can also use your existing analogue infrastructure and upgrade the hardware with HD (High Definition) cameras and digital recording.
Use our contact form or call the office to discuss your specific requirements with one of our Fire & Security Consultants.