Is Your Business Complying With The Surveillance Camera Code Of Practice?
CCTV surveillance cameras can be hugely useful for business owners. For example, they can:
- Protect premises at night or when buildings are unoccupied
- Control access to certain parts of the building
- Provide valuable evidence if a crime is committed on the premises
- Detect or deter workplace theft by employees or members of the public
- Alert business owners when any criminal or unauthorised activities are taking place.
Essentially, surveillance cameras can be your eyes and ears within your business when you can’t physically be there. After all, you’re only one person and can only be in one place at once.
CCTV cameras also have another role to play in modern businesses, in addition to improving security. They can actually help to improve business practices, processes and working methods. Managers can review footage to identify and analyse trends, which can help positive changes to be implemented. For example, you can review the factory floor or a customer service area to see how efficiency and service can be improved.
Now for the important part…
The legalities of using a surveillance camera
If you plan to take advantage of the many benefits CCTV cameras can offer your business, it’s important to understand the legalities of surveillance in the workplace. It is perfectly legal to film parts of your business provided that you don’t invade the privacy of your employees or customers. This essentially means not placing cameras in any location where an individual may have a reasonable expectation of privacy.
There are other principles (if not exactly laws) that responsible business owners should follow in order to avoid getting into trouble with their CCTV cameras. Good practice is also essential for keeping employees, customers and business partners happy.
The 12 guiding principles of camera use
To make extra sure that business owners understand the rules and their own responsibilities with relation to cameras in the workplace, the government’s Surveillance Camera Commissioner has put together a set of handy self-assessment tools. There are 12 guiding principles and a brief self-assessment questionnaire, all available on the government’s website. But here are the 12 main points summarised here:
1. Use of surveillance cameras should always be for a specific purpose. Have you identified a pressing need for surveillance and have a legitimate aim in mind? For example, security. As a business owner, you’re worried about your premises at night when the building is unoccupied. You should come up with a brief set of objectives that you want your new CCTV system to achieve, all based on this specific need or purpose.
2. Take into account the effect of your surveillance camera system on individuals and their privacy. Carry out a review to assess the impact of your cameras on individuals and their privacy, ensuring you aren’t breaking any laws and you are minimising any disruption or inconvenience to individuals.
3. There should be as much transparency as possible about the use of surveillance cameras. You should consider installing signage informing people of the operation of cameras in that area, as well as ensuring you have a complaints procedure in place for individuals who aren’t happy with the surveillance. You may also want to be honest and upfront with your employees before installing cameras so that they don’t feel mistrusted.
4. Clear responsibility and accountability for all surveillance activities is essential. It needs to be transparent and obvious who is responsible for surveillance activities, with all staff aware of their responsibilities.
5. You must have a clear and comprehensive policy in place before using CCTV cameras. This means putting together rules, policies and procedures to cover every aspect of your new surveillance activities. If there is ever a problem, this is the essential documentation you will refer to. You may want to include these policies in your induction programme for new staff, and review your policies regularly.
6. You shouldn’t store footage and images beyond those strictly required for the stated purpose of using surveillance cameras. This means that if you have stated that security is the primary purpose for installing cameras, you shouldn’t store footage related to anything other than security – unless you are able to justify it in this context. Any additional footage should be deleted, and you should be auditing footage regularly.
7. Access to footage should be carefully controlled. Once you start filming and storing footage, you become subject to all kinds of data protection laws – especially if you have individuals on camera. You need a policy on who can and can’t access footage and must not disclose images or information to anyone else.
8. Anyone operating surveillance cameras should ideally meet certain technical and competency standards. This one is entirely up to you as the business owner, but you may want to consider additional training.
9. You must put security measures in place to protect stored images and footage. Just like in point 7, you need security safeguards to prevent unauthorised access or even theft of stored footage. You need to look closely at how secure your network or intranet is, as well as putting a whole series of preventative measures in place to prevent misuse of the footage.
10. Regular audits and reviews of all policies and procedures are recommended. For all of the principles mentioned above, you should have policies and procedures in place. It’s not enough to get these down on paper, however. You need to be reviewing regularly to ensure they still address the business’ needs and importantly, still justifies the use of the cameras.
11. The footage may need to be used by law enforcement, so it should be of sufficient quality. If you’ve complied with all of the above and are using cameras, there may come a day when the police or authorities need to use your footage for evidence. Quality, forensic integrity, auditing trails and how exportable the footage is are all important considerations.
12. Any information used to support your camera system should be accurate and up to date. This refers to reference databases for matching purposes (i.e. facial recognition technology) which is much too advanced for most businesses.