Businesses operating CCTV and remote monitoring systems must comply with relevant UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Key considerations include:
Necessity and proportionality: CCTV surveillance must have a clearly defined purpose and be necessary and proportionate to the security risks identified. Cameras should be positioned to capture only the areas required, avoiding unnecessary surveillance of neighbouring properties, public spaces or areas where individuals have a reasonable expectation of privacy.
Transparency and signage: Businesses must inform individuals when CCTV is in operation and explain why their personal data is being collected. Clearly visible signs should be displayed in monitored areas, supported by a more detailed privacy notice explaining how footage is used, stored and managed.
Organisations operating CCTV may also be required to pay the Information Commissioner's Office (ICO) data protection fee, unless an exemption applies.
Example of CCTV signage:
CCTV cameras are in operation for the purposes of safety and security.
Operated by: [Company name]
For further information about how CCTV footage is used and your data protection rights, contact: [email address / telephone number].
Employee monitoring: Workplace CCTV requires particular consideration to ensure employees' privacy rights are respected.
- Employees must be informed about CCTV monitoring and its purpose.
- Employers must establish an appropriate lawful basis for processing personal data and ensure monitoring is necessary and proportionate.
- Surveillance should be limited to what is required to achieve a legitimate objective.
- Footage collected for security purposes should not routinely be repurposed for employee performance monitoring without a separate lawful justification and appropriate transparency.
- Cameras should not normally be installed in areas where employees have a high expectation of privacy, such as toilets or changing rooms.
Employers should document their reasons for monitoring and consider whether a Data Protection Impact Assessment (DPIA) is required, particularly where surveillance is likely to present a high risk to individuals' rights and freedoms.
Customers and visitors: Businesses must provide clear information about CCTV monitoring, typically through visible signage supported by an accessible privacy notice.
Footage storage and retention: CCTV recordings should be stored securely, with access restricted to authorised personnel. Footage must not be retained for longer than necessary for its stated purpose. There is no universal 30-day retention requirement; businesses should establish and document an appropriate retention period based on their circumstances.
Further guidance is available from the Information Commissioner's Office (ICO).