- Introduction
This policy is in place to confirm our responsibilities for CCTV (Closed-Circuit Television), how we use CCTV and how requests to view our CCTV footage will be responded too.
2. Legislation
Our CCTV system is used in accordance with: –
- Data Protection Act 2018 including chapter 2 “GDPR”
- Surveillance Camera Code of Practice 2022
3. CCTV Purpose & Locations
CCTV is installed and covers the following locations:
- 01- Front doors to the practice (facing the road)
- 03 – Front doors to the practice (facing the Car-Park)
- 09 – Front of the practice (facing the road)
- 06 – Waiting Area
- 08 – Ground Floor Doctors Corridor
- 07 – Ground Floor Nurses Corridor
- 11 – First Floor Corridor (Rooms 5-8)
- 12 – First Floor Corridor (Minor Surgery to Health Promotion Room)
- 13 – Minor Surgery Suite Corridor
- 14 – First Floor Corridor (PM’s Office to Room 4)
This has been installed for: –
- Safety and security of staff, patients, contractors and visitors
- To prevent and detect crime against the practice and may be used to support the prosecution of offenders
- To facilitate reflective learning for the practice team on practice incidents occurring within the monitored areas
CCTV will not be used for any other purpose other than those specified above.
4. CCTV Promotion
- CCTV signs on display in Waiting Area
- CCTV signs in Car Park
- CCTV sign on the front of the building (near front doors)
- Information on practice website
5. Responsibility for the CCTV
Please send queries & requests to:
- Practice Manager
When needed, expert advice will be sought from:
- Dr H Minhas – Caldicott Guardian
- Umar Sabat – Data Protection Officer & Information Governance Specialist
6. Retention of Images
- Images captured are not retained longer than necessary
- The CCTV automatically deletes images after 30 days
- Images required to support an access request or investigation are downloaded and kept securely
- Downloaded images will be deleted once they are no longer required
7. Security & Viewing of Images
- The images recorded are stored on a dedicated computer in the Server Room
- Server Room access is restricted to Partners of the practice, the Practice Manager and Administration Manager
- CCTV computer access is restricted to Partners of the practice, the Practice Manager and Administration Manager
8. Process for handling CCTV Access Requests
It is important that access to, and disclosure of, images recorded by CCTV is restricted and carefully controlled. This ensures that the rights of individuals are preserved, but also to ensure that the chain of evidence remains intact should the images be required for evidential purposes or to help prevent and detect crime. The following process will be followed:
- Access request to CCTV received
- Requester asked to provide all information needed using the CCTV Images Request Form (see below)
- Request is passed to the Practice Manager to assess
- Requester is contacted by the Practice Manager if further information is required to support decision making process
- Response provided to requester within 20 working – either images supplied or reason for refusing request explained
9. Access Request considerations
The Practice Manager will make a judgement about disclosing information in line with this policy and as a practice we have the discretion to refuse any requests for information unless there is an overriding legal obligation. Below are some issues we take into consideration:
- What amount of footage is requested?
- Which cameras is the footage needed from?
- Who has the request come from?
- Is it a third party and if so, do they have consent from any individual shown in the images?
- Is the request outside of our CCTV purpose?
- Is there a public interest reason for accessing the images?
- Will we breach other peoples confidentiality?
10. When information / images will be disclosed
Disclosure of recorded images will only be made in limited and prescribed circumstances and examples of these are detailed below which also includes our legal obligations:
- Request from police where the purpose is to prevent or detect crime
- •Public assistance is needed to help identify a victim, witness or perpetrator in relation to a criminal incident
- Request from a solicitor to support a criminal case
- Court order requesting images
- Images in relation to a data subject request
If required images include third parties / individuals within the recording, then arrangements will be made to disguise or blur so that they are not readily identifiable.
11. Complaints
Should a patient, visitor or contractor have a complaint about the practices CCTV, this will be addressed in line with the practice’s complaints procedure.